EPA-905/2-79-003B
Do not WEED. This document
should be retained in the EPA
Region 5 Library Collection.
                             EVALUATION OF MOTOR VEHICLE
                          EMISSIONS INSPECTION/MAINTENANCE
                               PROGRAMS FOR MICHIGAN
                                    VOLUME II
                 Pacific Environmental Services, INC.

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                                                                                   r
                              DISCLAIMER
This air pollution report is issued by the U.S. Environmental Protection
Agency Region V to assist state and local air pollution control agencies
in carrying out their program activities.  Copies of this report may be
obtained, for nominal cost, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.

This report has been reviewed by the U.S. Environmental Protection
Agency Region V Air Programs Branch and approved for publication.
Approval does not signify, that the contents necessarily reflect the
views and policies of the Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement
and recommendations for use.
                                                                                  Q
            Region V Publication No.  EPA-905/2-79-003A-003B
                                                                                  Q

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                            TABLE OP CONTENTS

Section                                                           Page
1.  INTRODUCTION 	  1-1
    1.1  Objectives/Purpose 	  1-2
    1.2  Background 	  1-2
    1.3  Study Requirements 	  1-7
    1.4  Study Cost and Methodology	  1-9
2.  PROGRAM BENEFITS 	  2-1
    2.1  Emission Reduction Benefits 	  2-1
    2.2  Fuel Savings 	  2-4
    2.3  Effect on Vehicle Performance and Life 	  2-10
    2.4  Value of Warranty Repairs Performed 	  2-12
    2.5  Employment Generation and Other Economic Growth
         Effects 	  2-13
    2.6  Offsets and Emission "Banking" 	  2-15
    2.7  Intangible Benefits	  2-17
3.  INSPECTION MAINTENANCE (I/M)  PROGRAM REQUIREMENTS 	  3-1
    3.1  Administrative Options 	  3-1
    3.2  Test Modes 	  3-3
         3.2.1  Idle-Mode Test	  3-3
         3.2.2  Loaded-Mode Test	  3-5
         3.2.3  Engine Parameter/Device Inspection 	  3-6
    3.3  Optional Inspection (Safety and Noise) 	  3-8
         3.3.1  Safety Inspection 	  3-8
         3.3.2  Noise Inspection 	  3-10
    3.4  Geographic Area of Coverage 	  3-11
         3.4.1  Nonattainment Areas 	  3-11
    3.5  Vehicle Population 	  3-15
    3.6  Inspection Lane Requirements  	  3-16
         3.6.1  Lane Operation	  3-16
         3.6.2  Lane Output Analysis 	  3-17
    3.7  Personnel Requirements 	  3-18
    3.8  Related Issues 	  3-18
         3.8.1  State Legislation 	  3-18

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Section
         3.8.2  Public Information and Participation 	 3-19
         3.8.3  Mechanics Training 	»	 3-19
         3.8.4  Consumer Protection and Quality Assurance Issues . 3-20

4.  PROGRAM COST ELEMENTS AND METHODOLOGY 	 4-1

    4.1  Methodology	 4-1

    4.2  Initial Implementation and Capital Costs (I) 	 4-2

         4.2.1  Initial Implementation Costs 	 4-2
         4.2.2  Capital Costs (Construction) 	 4-5
         4.2.3  Capital Costs (Other) 	 4-6

    4.3  Annual Operating Costs (II) 	 4-7

         4.3.1  Facility Operating Costs 	 4-7
         4.3.2  Support Costs 	 4-7
         4.3.3  Quality Control Operating Costs 	 4-8

    4.4  Ancillary Program Annual Operating Costs (III)  	 4-9
         4.4.1  Mechanics Training 	 4-9
         4.4.2  Public Information Program  	 4-9
         4.4.3  Consumer Complaint	 4-9
         4.4.4  Vehicle Test Scheduling Costs  	 4-9
    4.5  Cost-Related Assumptions 	 4-9

    4.6  Operational Related Assumptions 	 4-11

5.  OPTION DEFINITION AND COSTING 	 5-1
    5.1  Base Options Definition 	 5-1

         5.1.1  Option Costs 	 5-4
         5.1.2  Option-Specific Benefits 	 5-5
    5.2  Option 1  	 5-8
         5.2.1  Option 1 - Definitions and  Requirements  	 5-8
         5.2.2  Initial Implementation and  Capital  Costs (One-
                Time Costs)  	 5-9
         5.2.3  Operations Cost (On-Going Costs)  	 5-9
         5.2.4  Annualized Program Costs 	 5-17
         5.2.5  Consumer Fees 	 5-17
         5.2.6  Benefits 	 5-17

    5.3  Option 2  	 5-21

         5.3.1  Option 2 - Definitions and  Requirements  	 5-21
         5.3.2  Initial Implementation and  Capital  Costs (One-
                Time Costs)  	 5-26
         5.3.3  Operations Cost (On-Going Costs)  	 5-26
         5.3.4  Annualized Program Costs 	 5-26
         5.3.5  Consumer Fees 	 5-26
         5.3.6  Benefits 	 5-26

    5.4  Option3  	 5-33

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Section                                                           Page
         5.4.1  Option 3 - Definition and Requirements  	  5-33
         5.4.2  Initial Implementation and Capital Costs  (One-
                Time Costs) 	  5-34
         5.4.3  Operations Cost  (On-Going Costs)  	  5-34
         5.4.4  Annualized Program Costs 	  5-42
         5.4.5  Consumer Fees 	  5-42
         5.4.6  Benefits 	  5-42

    5.5  Option 5 	  5-46

         5.5.1  Option 5 - Definitions and Requirements 	  5-46
         5.5.2  Initial Implementation and Capital Costs  (One-
                Time Costs) 	  5-48
         5.5.3  Operations Cost  (On-Going Costs)  	  5-48
         5.5.4  Annualized Program Costs 	  5-48
         5.5.5  Consumer Pees 	  5-57
         5.5.6  Benefits 	  5-57
    5.6  Option 7 	  5-59

         5.6.1  Option 7 - Definitions and Requirements 	  5-59
         5.6.2  Initial Implementation and Capital Costs  (One-
                Time Costs) 	  5-61
         5.6.3  Operations Cost  (On-Going Costs)  	  5-62
         5.6.4  Annualized Program Costs 	  5-62
         5.6.5  Consumer Fees 	  5-62
         5.6.6  Benefits 	  5-66
    5.7  Option 9 	  5-67

         5.7.1  Option 9 - Definitions and Requirements 	  5-67
         5.7.2  Initial Implementation and Capital Costs  (One-
                Time Costs) 	  5-68
         5.7.3  Operations Cost  (On-Going Costs)  	  5-68
         5.7.4  Annualized Program Costs 	  5-76
         5.7.5  Consumer Fees 	  5-76
         5.7.6  Benefits 	  5-76

    5.8  Option 17 	  5-78
         5.8.1  Option 17 - Definitions and Requirements  	  5-78
         5.8.2  Initial Implementation and Capital Costs  (One-
                Time Costs) 	  5-79
         5.8.3  Operations Cost  (On-Going Costs)  	  5-79
         5.8.4  Annualized Program Costs 	  5-87
         5.8.5  Consumer Fees 	  5-87
         5.8.6  Benefits 	  5-87

    5.9  Light-Duty Trucks 	  5-89

6.   COMPARATIVE ANALYSES OF I/M OPTIONS 	  6-1
    6.1  Cost Comparison of 24 Major I/M Program Options  	  6-2
    6.2  Test Mode Sensitivity 	  6-9
    6.3  Area Coverage Sensitivity 	  6-9
    6.4  Facility Cost Sensitivity 	  6-12
                                    111

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Section
                                                                 Page
    6.5  Stringency Factor Sensitivity - 10 to 50 Percent 	 6-12
    6.6  Administrative Option Sensitivity 	 6-18
    6.7  Statistical Sample Size Variation Sensitivity 	 6-18
    6.8  Vehicle Type Sensitivity 	 6-18
7.   ISSUE IDENTIFICATION AND OPTION ELIMINATION 	 7-1
    7.1  Safety and Noise Inspections 	 7-1
    7.2  Statistical Sample 	 7-3
    7.3  State Operated System 	 7-4
    7.4  Private Garage System 	 7-4
    7.5  Loaded-Mode Test	 7-5
    7.6  Engine Parameter/Device Inspection 	 7-6
    7.7  Selection of Candidate Options 	 7-7
    7.8  Conclusions 	 7-7
8.   GENERAL DEFINITIONS 	 8-1
APPENDIX A.  VEHICLE POPULATION DATA BY AREA OF COVERAGE  	A-l
APPENDIX B.  LEGISLATIVE CONSIDERATIONS 	 B-l
APPENDIX C.  PUBLIC INFORMATION STRATEGIES 	 C-l
APPENDIX D.  MECHANICS TRAINING FOR VALID REPAIR  	 D-l
APPENDIX E.  CONSUMER PROTECTION AND QUALITY ASSURANCE  	 E-l
APPENDIX F.  UNIT COST DATA USED IN COST ANALYSIS  	 F-l
APPENDIX G.  DETAILED TEST LANE REQUIREMENTS BY TEST MODE  	 G-l
                                   IV

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                         LIST OF ILLUSTRATIONS
Figure
1-1    Michigan Ozone Nonattainment Counties 	 1-6
2-1    Possible Post-Maintenance Deterioration Functions 	 2-11
3-1    Typical Inspection Station 	 3-4
3-2    Michigan Ozone Nonattainment Counties 	 3-12
3-3    Carbon Monoxide Nonattainment Areas 	,	 3-13
3-4    Michigan Urban/I/M Option Areas 	 3-14
6-1.a  Hydrocarbon Reduction vs Vehicle Rejection Rate 	 6-17
6.1.b  Carbon Monoxide Reaction vs Vehicle Rejection Rate 	 6-17

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                            LIST OF TABLES
Table                                                            Page

1-1    Administrative Approach Versus Method of Test 	 1-8
2-1    Inspection/Maintenance Program Results in Major Urban
       Areas in the Designated Nonattainment Region 	 2-2
2-2    Fuel Economy Results for Repaired Autos 	 2-5
2-3    Estimated Daily Vehicle Miles of Travel (VMT) 1987 by
       Light-Duty Vehicles by Study Area 	 2-7
2-4    Travel Weighting Factor Calculation for LDV 	 2-7
2-5    U.S. EPA MPG Specifications for LDV's and Average Fleet
       Mileage for LDV s Covered by I/M by 1988 	 2-8
2-6    Fuel Saved Daily by Area of Coverage in 1987, in Gallons
       and Dollars, Attributable to an I/M Program in Michigan .. 2-10
3-1    Engine Parameter/Device Test and Emission Relationships .. 3-7
3-2    Light-Duty Vehicle Population Figures 	 3-15
3-3    Other Vehicle Population Figures  (1977) 	 3-15
4-1    Common Set of Cost Elements 	 4-3
5-1    Administrative Approach Versus Method of Test 	 5-2
5-2    Characteristics of the Base Options Analyzed in Detail  .. 5-3
5-3    Station Requirements - Option 1: State-Operated, Idle
       Test 	 5-8
5-4    Personnel Requirements - Option 1: State-Operated, Idle
       Test 	 5-10
5-5    Referee Office and Regional Requirements - Option 1: State
       Operated, Idle Test 	 5-11
5-6    Initial Implementation Costs - Option 1: State-Operated,
       Idle Test 	 5-12
5-7    Capital Costs  (Construction) - Option 1: State-Operated,
       Idle Test 	 5-13
5-8    Capital Costs  (Other)  - Option 1: State-Operated, Idle
       Test 	 5-14
5-9    Annual Operating Costs - Option 1: State-Operated, Idle
       Test 	 5-15
5-10   Ancillary Programs Operating Costs - Option 1: State-
       Operated , Idle Test 	 5-16
5-11   Annualized Program Costs and Consumer Fee - Option 1:
       State-Operated, Idle Test 	 5-18
5-12   Station Requirments - Option 2: State-Operated, Idle
       Test with Safety and Noise Inspection	 5-21
5-13   Noise and Safety Equipment  	 5-22
5-14   Comparative Matrix Analysis for Brake Testing 	 5-22
5-15   Personnel Requirements - Option 2: State-Operated, Idle
       Test with Safety and Noise Inspection	 5-24
5-16   Referee and Regional Station Requirements - Option 2:
       State-Operated, Idle Test with Safety and Noise
       Inspection  	 5-25
5-17   Initial Implementation Costs - Option 2: State-Operated,
       Idle Test with  Safety and Noise Inspection, Year 1982  	 5-27
                                   VI

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Table
5-18   Capital Costs (Construction)- Option 2: State-Operated,
       Idle Test with Safety and Noise Inspection, Year 1982  .... 5-28
5-19   Capital Costs (Other) - Option 2: State-Operated, Idle
       Test with Safety and Noise Inspection, Year 1982 	 5-29
5-20   Annual Operating Costs - Option 2: State-Operated, Idle
       Test with Safety and Noise Inspection	 5-30
5-21   Ancillary Programs Operating Costs - Option 2: State-
       Operated, Idle Station with Safety and Noise Inspection  .. 5-31
5-22   Annualized Program Costs and Consumer Fee - Option 2:
       State-Operated,  Idle Test with Safety and Noise Inspection 5-32
5-23   Station Requirements - Option 3: Contractor-Operated,
       Idle Test 	 5-33
5-24   Personnel Requirements - Option 3: Contractor-Operated,
       Idle Test 	 5-35
5-25   Referee and Regional Station Requirements - Option 3:
       Contractor-Operated, Idle Test 	 5-36
5-26   Initial Implementation Costs - Option 3: Contractor-
       Operated, Idle Test, Year 1982 	 5-37
5-27   Capital Costs (Construction) - Option 3: Contractor-
       Operated, Idle Test, Year 1982 	 5-38
5-28   Capital Costs (Other) - Option 3: Contractor-Operated,
       Idle Test, Year 1982 	 5-39
5-29   Annual Operating Costs - Option 3: Contractor-Operated,
       Idle Test 	 5-40
5-30   Ancillary Programs Operating Costs - Option 3: Contractor-
       Operated, Idle Test 	 5-41
5-31   Annualized Program Costs and Consumer Fee - Contractor -
       Option 3: Contractor-Operated, Idle Test 	 5-43
5-32   Annualized Program Costs and Consumer Fee - State -
       Option 3: Contractor-Operated, Idle Test 	 5-44
5-33   Personnel Requirements - Option 5: Private Garage-
       Operated, Idle Test 	 5-47
5-34   Referee Station Requirements - Option 5: Private Garage-
       Operated , Idle Test 	 5-49
5-35   Initial Implementation Costs - Option 5: Private Garage-
       Operated, Idle Test, Year 1982 	 5-50
5-36   Capital Costs (Construction) - Option 5: Private Garage-
       Operated, Idle Test, Year 1982 	 5-51
5-37   Other Capital Costs - Option 5: Private Garage-Operated,
       Idle Test, Year 1982 	 5-52
5-38   Operating Costs - Option 5: Private Garage-Operated,
       Idle Test 	 5-53
5-39   Ancillary Programs Operating Costs - Option 5: Private
       Garage-Operated, Idle Test 	 5-54
5-40   Annualized Program Costs and Consumer Fee - State -
       Option 5: Private Garage-Operated, Idle Test 	 5-55
                                    VII

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Table
5-41   Annualized Program Costs and Consumer Fee - Private
       Garage - Option 5: Private Garage-Operated, Idle Test .... 5-56
5-42   Personnel Requirements - Option 7: State-Operated,
       Idle Test, 5 Percent Sample 	 5-60
5-43   Initial Implementation Costs - Option 7: State-Operated,
       Idle Test, 5 Percent Sample, Year 1982 	 5-61
5-44   Capital Costs (Construction) Option 7: State-Operated,
       Idle Test, 5 Percent Sample, Year 1982 	 5-61
5-45   Capital Costs (Other) - Option 7: State-Operated, Idle
       Test, 5 Percent Sample, Year 1982 	 5-62
5-46   Annual Operating Costs - Option 7: State-Operated, Idle
       Test, 5 Percent Sample 	 5-63
5-47   Ancillary Programs Operating Costs - Option 7: State-
       Operated, Idle Station, 5 Percent Sample 	 5-64
5-48   Annualized Program Costs and Consumer Fee - Option 7:
       State-Operated,  Idle Test, 5 Percent Sample 	 5-65
5-49   Station Requirements - Option 9: State-Operated, Loaded
       Test 	 5-67
5-50   Personnel Requirements - Option 9: State-Operated,
       Loaded Test	 5-69
5-51   Referee and Regional Station Requirements - Option 9:
       State-Operated,  Loaded Test 	 5-70
5-52   Initial Implementation Costs - Initial Implementation
       Costs - Option 9: State-Operated, Loaded Test, Year 1982  . 5-71
5-53   Capital Costs (Construction) Option 9: State-Operated,
       Loaded Test, Year 1982 	 5-72
5-54   Capital Costs (Other) - Option 9: State-Operated, loaded
       Test, Year 1982 	 5-73
5-55   Operating Costs - Option 9: State-Operated, Loaded Test .. 5-74
5-56   Ancillary Programs Operating Costs - Option 9: State-
       Operated, Loaded Test	 5-75
5-57   Annualized Program Costs and Consumer Fee - Option 9:
       State-Operated,  Loaded Test 	 5-77
5-58   Station Requirements - Option 17: State-Operated, Engine
       Parameter/Device Inspection	 5-78
5-59   Personnel Requirements - Option 17: State-Operated,
       EPDI Test	 5-80
5-60   Regional Station Requirements - Option 17: State-Operated,
       EPDI Test	 5-81
5-61   Initial Implementation Costs - Option 17: State-Operated,
       Engine Parameter/Device Inspection Test, Year 1982 	 5-82
5-62   Capital Costs (Construction) - Option 17: State-Operated,
       Engine Parameter/Device Inspection Test, Year 1982 	 5-83
5-63   Capital Costs (Other) - Option 17: State-Operated, Engine
       Parameter/Device Inspection Test, Year 1982 	 5-84
5-64   Operating Costs - Option 17: State-Operated, Engine
       Parameter/Device Inspection Test  	 5-85
                                   viii

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Table                                                            Page

5-65   Ancillary Programs Operating Costs - Option 17: State-
       Operated, Engine Parameter/Device Inspection Test 	 5-86
5-66   Annualized Program Costs and Consumer Fee - Option 17:
       State-Operated, EPDI Test 	 5-88
5-67   Cost Comparison of Seven I/M Program Base Options with
       and Without LDT]_ 	 5-90
6-1    Cost Comparison of 24 I/M Program Options 	 6-3
6-2    I/M Program Cost Sensitivities by Geographic Area of
       Coverage 	 6-10
6-3    I/M Facility Sensitivities by Number of Lanes	 6-13
6-4    I/M Program Sensitivities by Stringency Factor 	 6-15
6-5    I/M Program Sensitivities by Vehicle Type Per Vehicle 	 6-20
7-1    Administrative Approach Versus Method of Test 	 7-2

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                                   Section 1
                                 INTRODUCTION
     Inspection/Maintenance (I/M) is a term used to denote the mandatory,
periodic inspection of motor vehicles.  The purpose of an I/M program is to
identify vehicles whose emissions are in excess of acceptable levels.  Such
vehicles must be repaired or adjusted.  An I/M program is intended to supplement
the Federal Motor Vehicles Control Program which requires emissions control
equipment on new vehicles.

     As a result of the Clean Air Act Amendments of 1977, the State of Michigan
must consider I/M programs for implementation.  To assist the State in this
evaluation, the U.S. Environmental Protection Agency  (EPA), Region V, contracted
Pacific Environmental Services,  Inc.  (PES) and Systems Control, Inc. (SCI)
to provide the necessary technical analysis.

     The analysis has been separated into two volumes.  Volume 1 presents
basic information about I/M and defines alternative administrative approaches
and methods of test.  U.S EPA requirements and other related topics are  also
discussed.

     Volume 2 provides a detailed evaluation and comparison of the options
defined in Volume 1, and is separated into seven sections:

     Section 1 - Introduction - Presents background information.
     Section 2 - Benefits - Discusses the benefits which result from the
implementation of I/M.
     Section 3 - I/M Program Requirements  - Explains the principal elements
of the I/M options.
                                     1-1

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     Section 4 - Program Cost Elements and Methodology  - Describes  the cost
model and cost elements used in the analysis.
     Section 5 - Option Definition - Defines specific program benefits and
costs for basic options, including such items as  capital investments,  operating
costs, and consumer fees.
     Section 6 - Comparative Analysis - Summarizes  the  other I/M options and
discusses the cost-sensitivity of test modes, administrative approaches,
geographic area of coverage, and other issues.
     Section 7 - Issue Identification and Option  Elimination  - Provides the
basis for elimination of some options and identifies options for further
study.
1.1       OBJECTIVES/PURPOSE

    The overall objective of an I/M program is to reduce vehicle emissions.
The purpose of this study is to evaluate the alternative approaches and test
methods for an I/M program and determine which one is best suited for application
in Michigan.  The cost of the various alternatives is one of the main factors
determining the desirability of a program; however, other factors, such as
effectiveness, benefits, and ease of implementation, will also be considered.

    The Michigan Department of Transportation (MOOT) is responsible for
providing the technical analysis of an I/M program to the state legislature.
This study will provide the rationale behind the options chosen for further
analysis and possible implementation.
 1.2       BACKGROUND
     The Clean Air Act Amendments of 1977 require attainment of the ambient
 air  quality standards for carbon monoxide (CO) and ozone (0 )  by December 1982.
 If an area is unable to demonstrate attainment by that date, despite the
 implementation of all reasonable controls, an extension up to 1987 may be
 granted if the State meets certain requirements.  One such requirement is the
                                        1-2

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implementation of a vehicle emissions I/M program.  The Clean Air Act also
requires a State Implementation Plan (SIP) to explain how a State intends to
meet the ambient air quality standards.  The SIP must contain a schedule
including I/M implementation milestone dates in order to be acceptable.  These
milestones are to ensure progress toward actual start-up of the program.

     The Clean Air Act also requires that the State must have the legal author-
ity to implement the programs it specifies in the SIP.  This includes the
legal authority to implement I/M.  Since each state's SIP must have been
approved by July 1, 1979 in order to avoid santions specified by the Act, EPA
has stated that the legal authority to implement I/M must have existed by that
date in order for the state to have an approvable SIP.  Although the Clean Air
Act does not specifically provide for an extension of the date for legal
authority, EPA has issued policy guidance stating that a 1-year extension may
be granted if a state has not had sufficient opportunity to complete the
necessary technical analysis prior to considering I/M legislation.  The required
start-up date of the I/M program is December 31, 1981 for decentralized pro-
grams, and December 31, 1982 for centralized programs regardless of when legal
authority is obtained.  The State of Michigan will be seeking legal authority
for I/M in September of 1979 based on the recommendations of this study.

     The Clean Air Act does not specifically state what type of an I/M program
the states must implement.  That decision is made by the individual states.
The EPA has issued policy guidance outlining what they consider to be a mini-
mally acceptable I/M program, and this information was presented in Section 3
of the Task 1 report.  Briefly, all I/M programs must provide for regular and
periodic inspection of all vehicles for which emission reduction is claimed.
Additional emission reductions can be obtained by including heavy-duty vehicles
such as buses and trucks, but EPA does not require this inclusion.  The program
must require repair of failed vehicles and provide for adequate quality control.
Other policy requirements are determined by the type of program a state chooses
and pertain to recordkeeping and licensing of inspection stations.  EPA has
provided a method for calculating emission reductions for an I/M program which
was also discussed in Section 3 of Task 1.  These emission reduction esimates
apply to either an idle or loaded exhaust emission test, but not to a parameter
or device inspection approach.

                                     1-3

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     There axe two types of sanctions stated in the Clean Air Act.  They

include discretionary sanctions related to transportation and highway funding,

state agency grants, and sewage treatment facility grants; and nondiscretionary

sanctions relating to stationary source permits.  The following sections taken

from the Clean Air Act describe the sanctions:


     Permits:

     Sec. 110(a)  (2) - "(I) it provides that after June 30, 1979, no major
     stationary source shall be constructed or modified in any nonattainment
     area (as defined in Section 171(2)) to which such plan applies, if the
     emissions from such facility will cause or contribute to concentrations
     of any pollutant for which a national ambient air quality standard is
     exceeded in such area, unless, as of the time of application for a permit
     for such construction or modification, such plan meets the requirements
     of part D (relating to nonattainment areas);..."

     Transportation and State Agency Grants:

    "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 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 submitting such an implementation plan are not being
          made or, after July 1, 1982, in the case of an  implementation plan
          revision required under Section 172 to be submitted before July  1,
          1982."

     Sewage Treatment Grants:

     Section 316  (b) - "The administrator may withhold, condition, or restrict
     the making of any grant for construction...(of sewage treatment works)...if
     he determines  that...(2) the state does not have in  effect,  or is  not
     carrying out,  a State Implementation Plan  approved by the Administrator..."


     If a state's  SIP is not approved,  the nondiscretionary  sanctions will

become effective after July 1,  1979.  The other discretionary  sanctions will

become effective if the EPA administrator determines that a  state is not
                                    1-4

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making progress toward submitting or complying with a SIP.  Sewage treatment
grants are subject to restriction because increased sewage treatment capacity
is directly related to industrial, residential, and commercial growth.  All of
the Clean Air Act sanctions are tied to approval of or compliance with  the
applicable SIP.

     Recent ambient air quality data gathered by the Michigan Department of
Natural Resources (MDNR) indicate the 0  and CO concentrations in certain
areas of the State exceed levels prescribed by the National Ambient Air Quality
Standards  (NAAQS).  These nonattainment areas are shown in Figure 1-1.  Since
the Detroit metropolitan area is not expected to attain the standards until
after the 1982 deadline, the State of Michigan must implement an I/M program
in the Detroit area to avoid Clean Air Act sanctions.  Other metropolitan
areas in the State are expected to attain the standards by 1982.

     As a part of this study, the administrative approaches and methods of
test discussed in Task 1 will be evaluated.  In addition, other geographic
areas will be considered for inclusion in the program, and the following
questions will be discussed:

     1.   Which option is most desirable for area implementation?

     2.   Are the various scenarios technically feasible using current  technol-
          ogy, instrumentation, and technical personnel?

     3.   What are the costs to the State and to the vehicle owner?

     4.   What degree of participation will the State and private industry
          have in the management,  ownership, and operation of statewide
          facilities for various options?

     5.   What has been the reaction  of the general public in mandatory  inspec-
          tion programs in other states?

     6.   What benefits will the State and the public realize from this  program?
                                     1-5

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             NONATTAINMENT
             AREAS
                      43.  HXS
                      44.  1APEES
                      42.
                      46.  U3AHEZ
                      47.
                      43.  1=
                      49.  MM2CSAC
                      30.  JIACSffl— iffiTSO
                      51.  MAST3TSS
                      32.  XAPQOSTTS
                      33.  MtfOll
                      34.  .
                      55.  fflSCMTHS
                      26.
li.  USSIZH
12.  3RASC3
13.  3U2CUS
14.  3S3
13.  raaaavosc
IS.
IT.  C3X7STSA
                      53. MCNjtOE
                      39.
                      SO. >M»TMO«ESCf
                      52.  XSUAV33
                        .  3AXLAND-MSTSO
                      54.  ocaaa
                      S3.  CGS'JkW
22.  s
23.  SATOS
24.  3WET
23.
                      S7.  SCSOLA
                      S3.  OSCCDA
                      69.
                      70.  OTXHA
                      71.
                      72.  3CSCSMMCH
                      74.  SASIIAC
                      75.  scacctoan
                      75.
                      77.  ST.
                      73.  S?. JC5TW
                      79.  T=SC3IA
                      30.  7AH 3CTZ3
                      32. -JARIB - METSO
                      33. WE3TOU
                          Figure  1-1.    Michigan  Ozone  Nonattainment Counties
                                                        1-6

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     Briefly stated, this study evaluates the technical feasibility of various
I/M programs, identifies and quantifies program costs, describes total program
benefits, and defines candidate options for further study.
1.3       STUDY REQUIREMENTS

     One of the requirements of this evaluation is to discuss each of the
identified program options in terms of various issues and criteria.  Each of
the following issues requires analysis, and many of these issues will be the
subject of programmatic decisions that must be made during the planning process.
The most significant decisions surround the administrative approach and method
of test, but decisions relating to the other issues may mean the difference
between acceptance or rejection of the program by the general public.  The
major issues and criteria used in the evaluation are as follows:

     1.   Alternative administrative approaches and test methods  (Table 1-1)

     2.   Vehicle categories subject to inspection and maintenance  (I/M)
          a.   Light-duty vehicles (< 6,001 pounds): LDV and LOT
          b.   Medium-duty vehicles  (6,001 to 8,500 pounds): LDT
          c.   Heavy-duty (> 8,500 pounds) gasoline vehicles:HDGV
          d.   Heavy-duty (> 8,500 pounds) diesel vehicles:HDDV
          e.   Motorcycles:(M/C)

     3.   Geographic area of applicability
          a.   Statewide (83 counties)
          b.   Nonattainment counties (38 counties)
          c.   Nonattainment regions
                    Grand Rapids (Ottawa and Kent)
                    Lansing (Clinton, Eaton, and Ingham)
                    Flint (Genesee)
                    Detroit (Macomb,  Monroe, Oakland,  Washtenaw, and Wayne)
                                     1-7

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           Table 1-1.  ADMINISTRATIVE APPROACH VERSUS METHOD OF TEST
Administrative
   Approach
                                         Method of Test
       Idle
      Loaded
     Parameter/
  Device Inspection
State-
  operated
*With safety and
  noise

*Without safety and
  noise
With safety and
  noise

*Without safety and
  noise
With safety and
  noise

*Without safety and
  noise
Contractor-
  operated
Private-
  garage
With safety and
  noise
With safety and
  noise
                *Without safety and   Without safety and
                  noise                 noise
With safety and
  noise
With safety and
  noise
                *Without safety and   Without safety and
                  noise                 noise
With safety and
  noise

Without safety and
  noise

With safety and
  noise

Without safety and
  noise
Statistical
  sampling
*Base option
With safety and
  noise

*Without safety and
  noise
With safety and
  noise

Without safety and
  noise
With safety and
  noise

Without safety and
  noise
                                     1-8

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     4.   Program benefits
          a.   Expected reduction, in emissions
          b.   Fuel savings
          c.   Effect on vehicle performance and life
          d.   Value of warranty repairs performed
          e.   Employment generation and other economic growth effects
          f.   Offsets and emission "banking"
          g.   Intangible benefits

     5.   Program cost analyses
          a.   Initial implementation and capital costs
          b.   Annual operating costs
          c.   Ancillary programs annual operating costs

     6.   Costs and benefits of I/M program options

     7.   Consumer protection and mechanic's training

     8.   Public information program

     9.   Legislative requirements and state agency roles

     Note that in Table 1-1, both safety and noise testing are included as
auxilliary programs  under method of test.  Although safety and noise testing
are not required elements of an emissions testing program in the Clean Air
Act, another requirement of this study is to evaluate these auxiliary programs
for possible inclusion.  None of these programs is being considered as an
individual program for implementation.


1.4       STUDY COST AND METHODOLOGY

     A unit cost concept was used in the cost analysis of the options.  The
units used are one and two lane test stations.  The number of one and two  lane
stations is determined by the vehicle population of the geographic areas.  The
                                   1-9

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station operating and capital costs are estimated by direct multiplication of
the unit cost times the number of stations.

     Only seven of the 24 major program options listed in Table 1-1, are
unique.  These unique options are noted on the table.  The other 17 options
are combinations of elements of the seven unique options.  For this reason,
only the seven basic option costs are studied in detailed in Section 5; others
are summarized in Section 6 for comparison.   In Section 6, sensitivity factors
have been developed and applied to the base options to generate the approximate
program costs of the 17 nonbase options.  For example, the sensitivity factor
multiplied by the cost of a base option will determine if one of the nonbase
options is more or less costly than the base option, without going into the
detailed description of the base options.  All of the costs are presented  in
1978 dollars.  Actual costs and fees will depend on the inflation rate and the
year of program start-up.  A detailed discussion of the program costing analysis
is provided in Section 4.
                                    1-10

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                               Section 2
                           PROGRAM BENEFITS

     The primary purpose and principal benefit of an I/M program is the
reduction of vehicular emissions.  However, there are associated bene-
fits implicit in a successful I/M program that are reflected in mone-
tary savings and improved driveability for the individual, and growth
in employment for society at large.  The magnitude of these associated
benefits is generally - but not uniformly - a function of program con-
tent and coverage.
     In the discussion which follows, those I/M program benefits that
can be quantified for the State of Michigan at this stage of analysis
will be assigned a numerical value.  Those which cannot will be dis-
cussed in qualitative terms.  Where the magnitude of a given benefit is
sensitive to test mode or coverage, the variation will be noted.

2.1  EMISSION REDUCTION BENEFITS
     The extent to which an inspection/maintenance program reduces the
emissions from motor vehicles depends upon the specific features incor-
porated into the program.  Appendix N of 40CFR Part 51 (May 2, 1977)
lists the emission reduction expected utilizing I/M options.  Emission
reduction benefits resulting from I/M programs can also be calculated
using the MOBILE 1 program developed by EPA.  The State of Michigan, in
cooperation with the Southeastern Michigan Council of Governments, has
determined emission reductions that would result from an I/M program
for light-duty vehicles less than 8,500 Ibs gross vehicle weight insti-
tuted in the State's five nonattainment metropolitan areas.  These
results occur by assuming a 20 percent stringency factor (failure rate)
and training for mechanics repairing vehicles under the program.  Total
expected emission reductions for light-duty vehicles are shown in Table
2-1.  The totals shown are cumulative over the entire vehicle stream,
but per-vehicle emissions would be reduced only for those units that
have undergone repair following an inspection failure.
                                  2-1

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Table 2-1.   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
9.6
2,346,511
1,746,443
25.6

35.2,863
340,469
3J
204,066
159,350
21.9
Flint
168,420
146,679
12.9
92,333
58,196
37.0
HC
20,527
19,680
4.1
10,868
7,882
27.5
Lansing
135,129
117,530
13.0
78,492
49,401
37.0

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
Miles
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.
                                          2-2

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     If an I/M program were to be expanded to cover the entire 37-county
nonattainment region, or the state as a whole, percentage emission
reductions would be similar to those indicated for the Niles (Berrien
County) urbanized areas because of the similarities in vehicle charac-
teristics and travel.  Obviously, the actual reduction in emission inten-
sity or weight would be considerably less for each county outside the
metropolitan areas because of lighter travel densities and fewer inci-
dences of congestion which decreases travel speed, and in turn increases
per-vehicle emissions.
     Additional program benefits may be obtained if heavy-duty gasoline-
powered vehicle inspections are included.  U.S. EPA has established
revised emission standards for heavy-duty (greater than 8,500 Ibs gross
vehicle weight) gasoline vehicles, and they are investigating the recommen-
dation of test standards for these vehicles.
     There are two cogent arguments for including heavy-duty gasoline
powered vehicles in an I/M program.  The first is that, in the average
speed range common to most metropolitan areas, heavy gasoline vehicles
emit three to four times as much pollutant per unit distance traveled
as automobiles and light trucks.  This fact is attributable both to
the higher base emission characteristics of heavy gas vehicles and to
the usual case of an older, "dirtier" vehicle mix among heavy trucks
in the traffic stream.  The second argument is that the frequent uti-
lization of heavy gas trucks in cartage, construction, and other high-
use operations makes the annual total miles of operation comparable
to annual miles of travel by light-duty vehicles and simultaneously
contributes to more rapid emission deterioration.  Consequently, al-
though heavy gasoline trucks are believed to account for less than
5 percent of total vehicle miles of travel nationwide, they may con-
tribute up to 15 percent of total vehicular emissions of HC and CO.
     Emissions from diesel-powered vehicles (though occasionally
characterized by visible smoke, strong odor, and aesthetic unpleasant-
ness) are relatively low in HC and CO, and thus,  EPA estimates.account
for a minimal contribution (about one percent)  to mobile-source related
ozone and carbon monoxide air pollution.
                                  2-3

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     Some existing I/M programs do include the testing of heavy-duty
diesel trucks.  However, the test performed on these vehicles does
not monitor emissions of HC and CO, but checks only the density
(opacity) of smoke issuing from the exhaust stack.  If Michigan opted
to test these vehicles, equipment requirements for vehicle inspection
stations would include opacity meters and other specialty equipment
for diesel testing.  Also, because the test procedure is different,
throughput and hence station efficiency would be affected.

2.2  FUEL SAVINGS
     It is generally accepted that the fuel economy of any automobile
will be improved with proper maintenance, especially tune-up.  The I/M
program tends to isolate those vehicles which are gross emitters and
thus, by inference, badly out of tune.  Those vehicles that cannot
comply with stringency standards and have deficiencies corrected either
by getting a tune-up or by undergoing a minor adjustment to the car-
buretor will experience better fuel economy, thereby conserving energy
resources.
     Two studies that have been identified as establishing fairly
reliable estimates of fuel savings attributable to an I/M program are
those conducted during the mandatory State of California program at
the Riverside testing facility  and during the ongoing testing program
in Portland, Oregon.   The realiability of these studies is predicated
on  (1) the sample size and composition of vehicles followed through
the study, and (2) the inclusion of catalyst-equipped (post-1974)
vehicles.  The California study found that, for vehicles of known
pretest  fuel economy which had failed inspection, been repaired,
 State of California,  "Evaluation of Mandatory Vehicle Inspection and
 Maintenance Programs," Unpublished report, December 1976
 United States Environmental Protection Agency, "Portland Study
 Interim Analysis:  Observations on Six Months of Vehicle Operation,"
 Unpublished report, January 1979
                                  2-4

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passed a second inspection, and were monitored for mileage under
driving conditions similar to those before the first test, an average
improvement in fuel economy of 2.7 percent among catalyst vehicles
and 3.8 percent among noncatalyst vehicles was recorded.  By contrast,
the Portland results are proving to be much more conservative.  The
magnitude of mileage improvement appears to be more senstitive to the
availability of trained mechanics for performing necessary repairs
and to the type of driving undertaken than to present emissions con-
trol technology of individual vehicles.  Table 2-2 presents the observed
and hypothetical difference in fuel economy for repaired automobiles
in pre- and post-catalyst age groups under a variety of circumstances.

          Table 2-2.  FUEL ECONOMY RESULTS FOR REPAIRED AUTOS
Control
Technology
(Age Group)
Pre-Catalyst
(1972-74)
Catalyst
(1975-80)
3-Way Catalyst
(1981-
Post-Repair Percent Improvement in Fuel Economy for
City
Driving
+1.5
+1.0
	
Highway
Driving
-0.7
-1.5
	
Untrained
Repairs
1.0
0
	
Skilled
Mechanic Repairs
+3.0
+3.0
+10.0-20.0
Hypothetical value based on presumption of additional diagnostic
 information on-board 3-way catalyst cars and on preview of rich
 failure modes of prototype engines.
     These somewhat discouraging results for existing vehicles apply
only to that proportion of the vehicle fleet that fails an emission
test and is actually repaired.  Therefore, a +3.0 percent value in
Table 2-2 corresponds to a +0.6 percent value fleetwide if the I/M
program stringency (failure rate)  is 20 percent.  The optimistic pro-
jection for fuel economy improvements to future technology vehicles is
based on an assumption of improved test diagnosis (discussed below) and
would correspond to a +2.0 percent improvement fleetwide.
                                  2-5

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     The availability of skilled mechanics to repair failed vehicles
appears to be critical to the ability of an I/M program to improve
aggregate fuel economy.  Under present laws, or after an appropriate
training program, the State of Michigan would likely have an adequate
supply of such mechanics.  This will be especially important in future
years when the technology of vehicle emission control incorporates the
three-way catalyst system, which continually monitors and controls
combustion temperature as well as carbon monoxide and unburned hydro-
carbons in the engine exhaust.  If vehicles equipped with three-way
catalysts also include system feedback information readouts on the
control panel, it should be possible for a skilled mechanic to diagnose
the reason(s) for emission control failure at any engine operation
speed, and therefore, to make the correct repair almost without error
on the first attempt.  Moreover, inspection diagnosis itself should be
improved (i.e., test technicians' "truth charts" may be made more
precise.)  In summary, EPA has hypothesized that I/M programs will
result in a significantly greater proportion of post-1980 model vehicles
operating to manufacturers' specifications in regular travel than is the
case for the present vehicle stream.
     It should be pointed out that many other variables can influence
fuel economy.  These variables include the diagnostic capabilities of
the test mode, characteristics of the vehicle population tested, and
geographic coverage of the program, as well as the time the program
has been in effect.
     An estimate of fuel savings in 1978 dollars for failed light-duty
vehicles resulting from I/M implementation in the 37 nonattainment
counties in Michigan can be calculated for 1987.  Assumptions include:
20 percent stringency factor; repairs by trained mechanics; daily total
of 147,389,119 vehicle miles of travel; an average improvement of fuel
economy for failed vehicles of 3.0 percent for pre-1981 and 10.0 percent
for 1981 and later vehicles; an average fleet mileage figure of 25.0 mpg;
and a cost of  $0.73 per gallon of gasoline.  The total projected vehicle
miles of travel by county in Michigan was provided by the Michigan
                                  2-6

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Department of Transportation (see Table 2-3) .   Average fleet mileage
is computed from a weighted  mean of EPA mileage-per-gallon specifica-
tions for model-year light-duty fleets through 1987 (see Tables 2-4
and 2-5).
   Table 2-3.  ESTIMATED DAILY VEHICLE MILES OF TRAVEL (VMT) 1987
                 BY LIGHT-DUTY VEHICLES BY STUDY AREA*
Designated Study Area
Grand Rapids (Ottawa & Kent)
Lansing (Clinton, Eaton & Ingham)
Flint (Genessee)
Detroit (Macomb, Monroe, Oakland,
Washtenaw & Wayne)
Nonattainment 37 Counties
Statewide (83 Counties)
VMT
9,618,344
6,510,039
8,647,615
75,908,539
147,489,119
171,195,471
*Source:  Michigan Department of Transportation
         Table 2-4.  TRAVEL WEIGHTING  FACTOR CALCULATION FOR LDV

Year



1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
Pre-76

Vehicle
Age


1
2
3
4
5
6
7
8
9
10
11
12
13+
(a)
Fraction
Total Reg.
For Michigan
Vehicles
0.127
0.124
0.116
0.113
0.105
0.092
0.081
0.072
0.058
0.043
0.028
0.017
0.024
(b)
Average Annual
Miles Driven**


15,900
15,000
14,000
13,100
12,200
11,300
10,300
9,400
8,500
7,600
6,700
6,600
5,491

(a) x (b)



2,019.3
1,860.0
1,624.0
1,480.3
1,281.0
1,039.6
834.3
676.8
493.0
326.8
187.6
112.2
131.78

£(a) x (b)/sum] -
Travel Fraction


0.167
Q.154
0.135
0.123
0.106
0.086
O.O69
0.056
0.041
0.027
0.016
0.009
0.011
  "Source:  U.S. EPA Nationwide Estimates
                                  2-7

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Table 2-5.  U.S. EPA MPG SPECIFICATIONS FOR LDV'S AND AVERAGE FLEET MILEAGE
                    FOR LDV'S COVERED BY I/M BY 1988
Model Year
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1981-
1976-1980
TOTAL
EPA Mileage
Standard
27.5
27.5
27.5
27
26
24
22
20
19
18
17.5
16.8



Travel Fraction
0.057a
0.154
0.135
0.123
0.106
0.086
0.069
0.056
0.041
0.027
0.016
0.009



Column (1) x Column C3)
0.880b
1.781
4.813
4.219
3.774
3.132
2.345
1,725
1.273
0.885
0.552
0.318
0.172
26.266
18.899
24.989 Fleet Mileage
    Approximation based on estimated miles of travel accumulated by model
    year 1987 LDV's inspected by January 1, 1988.  It is assumed that 30
    percent of total registered 1987 model year cars will have been tested
    by that date.
    Normalization factor to reflect nonparticipation of pre-1976 vehicles
    and 70 percent of 1987 model year fleet.
        The fleet mileage average from Table 2-5 has been disaggregated
   into averages for pre-1981 and three-way catalyst technology vehicles,
   respectively, in order to compute total daily fuel savings in 1987.
   It is assumed that failed vehicles are operating at either 3 or 10 per-
   cent below their model-specific EPA mileage ratings, and that failures
   will occur uniformly across the spectrum of all models (test cutpoints).
   Repair is therefore assumed to restore each vehicle to its "new car"
   mileage, represented in the aggregate by the appropriate average fleet
   mileage.  Exceptions are in those cases where a vehicle fails a second
   emissions test and may or may not be exempted from further testing.  It
   is conservatively estimated that vehicles failing twice constitute 20
   percent of the original failures, and that no fuel savings can be
                                     2-8

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 credited to  them.   Travel  affected by I/M improvements under a 20 per-
 cent test stringency is  therefore; 0.2 -0.2(0.2)  = 0.2-0.04 = 0.160,
 16.0 percent of  total vehicle miles.
      Let  this 16 percent value be  called  IMT.  for  every geographic  area
of interest  i.  In each case  it is  equal  to 0.16 times the  daily  VMT
value in  Table 2-3.   The equation  applied for  fuel savings  is
_ /(l.l IMT.) (TF2)     IMT. (TF2)\         /(JL.03 IMT.) (TF1)    - IMT. (TF1)\
— I	1	   -    1	 I         I 	i	       1	  j
  \     MPG2              MPG2  /         \      MPG1              MPG1    J
                     = .0731  (IMT.)   +    .00447 (IMT.)
                           26.2718.90

where AG  = gallons of fuel  saved,
           TF1 = 0.149 = Travel fraction  by pre-1981 LDVs in 1987 )  See
           TF2 = 0.731   Travel fraction  by post-1980  LDVs  in  1987 J  Table 2-5
           MPG1=18.90>   _    _ , .   .  _
           MPG2=26.27/   See  TablS  2'5
           1.1, 1.03  represent  fuel savings multipliers.  (10 percent
                      and 3  percent improvement, respectively)

      Table 2-6 presents  the estimated daily  fuel  savings  in gallons
 and  1978  dollars for each  geographic  area of  interest  in  1987. The
 estimates do not account for  gasoline used to  drive to  the  inspection  station
 and  wait for an  inspection.  Obviously,  should the technological  innova-
 tions on board three-way catalyst-equipped vehicles fail  to conform to
 EPA  expectations, the results for  post-1980 vehicles may  or may not be
 accurately represented.
      From Table  2-6, total fuel savings in the nonattainment counties
 for  the year 1987 could  be as high as 26.0 million gallons, or $19.0
 million.   A  statewide program could produce  savings of 30.2 million
 gallons,  or  $22.0 million.
                                  2-9

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      Table 2-6.   FUEL SAVED DAILY BY AREA OF COVERAGE  IN 1987,
                       IN GALLONS AND DOLLARS,
            'ATTRIBUTABLE TO AN I/M PROGRAM IN MICHIGAN
 Area From Table 2-3
Gallons
             1978 Dollars
          (73$/gallon av. price)
 Detroit
   (5-County Metro)
 Flint (Genesee)
 Grand Rapids
   (Ottawa,  Kent)
 Lansing
   (Clinton, Eaton,
    Ingham)
 Nonattainment Counties
 (Less the above)
 Statewide
 (Less the above)
36,669
 4,178
 4,646
 3,145
71,300
82,700
22,662
11,400
            $26,768
            $ 3,050
            $ 3,392
            $ 2,296
            $52,049
$62,025
$16,543
$ 9,976
2.3  EFFECT ON VEHICLE PERFORMANCE AND LIFE
     Another possible benefit of an I/M program that accrues directly
to motorists could be improvement of vehicle performance and increase
of vehicle life.  The impact of I/M on these factors is difficult to
quantify, and studies to date have not been conclusive.  They have
centered on the way I/M affects vehicle deterioration rates.  A
deterioration curve (Figure 2-1) illustrates the rate at which a
vehicle deteriorates after it has been tuned.  This directly influences
vehicle performance.  To the extent that I/M slows the rate of change
in the shortcurve,  it should have a positive impact on vehicle per-
formance.  If an engine continues to operate within the manufacturer's
specification due to I/M, it should perform at a higher level.
     Improvement in performance and longevity resulting from I/M's
impact on long run deterioration is unknown.  It seems reasonable
that a properly maintained vehicle will experience less wear than if
it is not maintained to manufacturer's specifications.  Assuming this
relationship is true, I/M should have a positive effect on vehicle
life.
                                 2-10

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EMISSIONS
                                       7
                                    ~7
                            r
     RAPID
 DETERIORATION
   LINEAR
DETERIORATION
    SLOW
DETERIORATION
                                                           -*-TIME
 Figure 2-1.  Possible Post-Maintenance Deterioration Functions-Short Run
                              2-11

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2.4  VALUE OF WARRANTY REPAIRS PERFORMED
     Section 207 of the Clean Air Act mandates a new vehicle and engine
emissions warranty which includes a general defects warranty in Section
207(a), a performance warranty in 207(b), and an enforcement and recall
provision in 207 (c) .  EPA has proposed regulations under Section 207(b) that
will require every automobile manufacturer to bear the cost of repair
of any properly maintained and operated vehicle that it has produced
and which fails an EPA-certified emission test within 24 months or
24,000 miles, whichever comes first.  After this period, the warranty
applies only to catalytic converters, thermal reactors, or other com-
ponents installed on or in a vehicle for the sole or primary purpose
of reducing vehicle emissions.
     The State of California in 1977 completed a surveillance test
program on 1975 to 1976 model-year vehicles.  These vehicles were
tested using:
     • CVS-75 test used in new car certification
     • Federal highway fuel economy test
     • Loaded-mode test
     • Acceleration/deceleration driving sequence EPA model test
     • Sealed housing evaporative determination (SHED) test
     Only 9 percent of the venicles failed because of defective com-
ponents .  These defective components may not have been covered by
warranty because of:
     • Lack of maintenance
     • Abuse of vehicle
     • Other unspecified reasons
     It is evident that the subject of repair work to be performed under
Section 207(a) warranty requires further study and definition to form  a
basis for analysis.
     It was estimated that approximately 4 percent of the less than
24,000 miles of light-duty vehicles had defective parts prior to
                                   2-12

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testing and would require warranty parts replacement.  Based on existing
registration data, vehicles with 24,000 miles or less on the odometer and
subject to I/M account for approximately 11.3 percent of passenger cars.
     The average cost of a warranty parts replacement would be approxi-
mately $32 in 1978 dollars.  The light-duty vehicle population is pro-
jected to be 4,967,970 in 1983  for the nonattainment areas only.  If
4 percent of the under-24,000 mile subject LDVs represented in this
total  (about 0.45 percent of total registration) undergo repairs  to
emission control components covered by warranty at an average repair
cost of  $32, the net additional value of warranty  repair work performed
on  vehicles as  a direct  result  of  failures diagnosed during emissions
inspection could approach  $718,600 in 1983.

 2.5 EMPLOYMENT GENERATION AND  OTHER ECONOMIC GROWTH EFFECTS
     Although  the  public demand generated  by an  I/M program is  not
 truly  an expression of genuine  desire  for  a new  good  or service,  this
demand must in part  be met by growth and/or transition in the private
sector.  Chiefly, the supply of trained mechanics  and vehicle inpsection
technicians will increase to meet this demand.
     The total requirement for new positions in these  two employment
categories will be determined by the mode of test selected and the
geographic coverage of the testing program.   Staffing  needs at test
stations generally increase as a function of the  diagnostic capabilities
of the inspection test mode, which also governs the amount of time
required per test.   The requirement for repair mechanics is not sensitive
to test mode unless private garages perform both  inspection and repair.
In this case,  a lower proportion of each mechanic's labor time would
be devoted to repair and thus the total  mechanic  requirement would
increase as a direct function of the  duration of  an inspection.   However,
assuming a uniform level of capability,  the overall demand for trained
mechanic services  may actually decline  as test diagnostics  improve.
Obviously,  total needs in both categories will increase  as  more  counties
are subject to the I/M requirement.
                                   2-13

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      In practice, neither  technicians  nor trained mechanics  are  imported
•by  test operators from outside  a region  subject to testing.   It  is
 conceivable that all new demand in these categories could be met by
 Michigan  residents.  In the  case of a  program operated by a  contractor
 or  through Michigan's private garages, all new employment generated
 by  the demand for technicians and mechanics would be in the  private sector.
 Technicians could be full- or part-time  employees,  depending on  the
 testing load in a particular area or time of year.   Most administrative
 and quality control functions required of State government under such
 a program optimally could  be carried out by current state personnel.
 However,  it is assumed that  some augmentation of the State-employed
 work  force will be necessary.   New mechanics would be trained and
 present mechanics retrained  through state and/or private programs.   In
 the case  of a program operated  by the  State itself,  demand for mechanics
 would still be met in the  private sector,  but test technicians would pro-
 bably have to be full-time state employees,  with virtually all program
 operations employment generated in the public sector.

      Specific  estimates of the  personnel  requirements for each I/M
 program option are presented in Section  5 of this report. It is well
 to note that the  total  cost  of  this manpower would be met by a transfer
 payment within or between  sectors and  does not constitute true growth
 in gross  state product.  However, demand for hard goods in the clas-
 sifications  listed below is  likely to  increase after program implemen-
 tation, resulting in  revenue growth and  possible employment  expansion
 for Michigan manufacturers of these goods.
           •  Automotive repair  parts
           •  Mechanics'  hand tools
           •  Electronic analyzers (vehicle tuning)
           •  Garage  accessories (e.g., hydraulic lifts, dynamometers)
           •   "Do-it-yourself"  repair manuals
                                    2-14

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          •  Office equipment (testing and quality control stations)
          •  Industrial gases (used in test calibration)
          •  Building supplies and construction materials  (test facilities)
          •  Uniforms; coveralls
          •  Software and other data processing supplies
This list could be augmented (or diminished) as the technology of the
internal combustion engine and its emissions control systems evolves
during the life of an I/M program.

2.6  OFFSETS AND EMISSION "BANKING"
     Pursuant to Section 173 (I)(A)  of the Clean Air Act, EPA issued
its Emission Offset Interpretive Ruling, which requires that, until
such time as a state issues its own permit regulations for new stationary
emission sources consistent with the mandates of Section 172 of the
Act, any new source in a nonattainment area must meet the "....lowest
achievable emission rate for the problem pollutant(s) and ....obtain
more than equivalent offsetting emission reductions  (emission offsets)
from existing sources."

     The second clause of this Ruling has raised numerous questions
in presently-designated nonattainment areas regarding opportunities
for economic growth.  A producer contemplating development of an
industrial plant in a nonattainment area might be dissuaded from an
affirmative decision if it becomes his or her responsibility to
negotiate source emission reductions from manufacturers already
established in that area.
     Responding to this concern, many states are investigating the
implementation of emissions "banking" accounts for attainment and
nonattainment areas alike.  As emission reduction credits are deter-
mined for various emission control strategies promulgated under state
and local programs, these credits are assigned to an economic growth
 Federal Register,  Vol.  44,  No. 11 - January 16, 1979, p. 3274
                                   2-15

-------
 "bank" account,  This account, after deductions to meet necessary goals for
 "reasonable further progress" toward attainment of ambient air quality
 standards, shows the balance of permissible annual emission tonnage
 increments for industrial and commercial growth.
      Inspection/maintenance programs can make a significant contribu-
 tion to this "bank" account.  For the relatively minor inconvenience
 of an annual emissions check, motor vehicle owners can guarantee that
 the economic growth potential of their county, region, or state of
 residence will not be thwarted by an ambient air quality condition
 over which they have little direct control.

2.7  INTANGIBLE BENEFITS.
     Benefits over a wide spectrum of health, welfare and aesthetic
dimensions have been variously attributed to clean air.  Insofar as
an I/M program contributes to the attainment of clean air, it shares
the credit for these benefits.
     Individual perceptions of a "desirable environment" are highly
subjective, but several studies have indicated that land values respond
positively to improvements in air quality.  That is, people prefer to
live where clean air is a part of overall aesthetics.

     Moreover, clean air has been hypothesized to pay off in reduced
health costs and crop damage.  A few studies have related foliar damage
in trees and crop leaves to the suppression of normal photosynthesis
induced by plant exposure to ozone concentrations in excess of the
ambient standard for one hour or less.  Lack of on-site correlations
of monitored ozone concentrations with leaf and crop conditions in
Michigan render application of this finding invalid and thus no crop
damage hypotheses can presently be upheld.
                                     2-16

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     Evidence for the health benefit of clean air is more amenable
to generalization.  Among numerous studies commissioned for the pur-
pose of estimating the health costs imposed by various pollutants,
one in particular predicted the following damage costs attributable
                                                             4
to ozone pollution for four major metropolitan areas in 1975.
           REGION                       HEALTH COSTS (IQ6 Dollars)
           New York                         21.3
           Chicago                          16.6
           Washington                        1.7
           Los Angeles                     152.5
      Symptoms of ozone irritation include eye discomfort (dryness
 and/or burning), chest discomfort (impaired breathing),  coughing,
 headache,  and,  in susceptible cases,  aggravated asthma or heart and
 lung disease.  Costs are incurred both in the expense resulting from
 any medical treatment and in lost employee time and productivity owing
 to impaired function.   The magnitude  of such negative impacts tends
 to be greatest in urbanized areas,  with relatively larger work forces
 and generally more days in violation  of ambient standard than are the
 case in less densely developed regions.  For this reason, Detroit,
 Flint, Lansing, and Grand Rapids are likely to be the Michigan locations
 most vulnerable to the health cost dimension of ozone pollution damage,
 and it is  therefore in just these locations that any I/M program for
 the purpose of reducing the quantity  of airborne, ozone-forming hydro-
 carbons could produce the greatest net benefit.
       In the Detroit area, reduction of ambient carbon monoxide  (CO)
 levels through I/M may also contribute to an improvement in general
 health and efficiency.  Exposure of eight or more hours to CO concen-
 trations of 10 to 15 ppm  (.the eight-hour ambient standard is violated
 when  CO concentration exceeds 9 ppm).  is highly correlated with impaired
 time-interval discrimination, heart muscle strain owing to decreased
 oxygen availability in the bloodstream, and occasional severe chest
 pain  in angina-pectoris patients.  These conditions are exacerbated
 for moderate to heavy smokers experiencing elevated ambient CO levels.
 Studies presently available have not identified  any adverse effects
 on vegetation or materials arising from elevated CO exposure.
4Mathtech, inc., "A Computer Simulation Model for Analyzing Mobile
 Source Air Pollution Control Strategies," EPA, September 1976, pp. 29-32
                                    2-17

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                                   Section 3
               INSPECTION MAINTENANCE (I/M)  PROGRAM REQUIREMENTS
     In this section, each of the factors affecting the magnitude and distribu-
tion of program costs will be discussed.  Administrative approach and method
of test will be reviewed again, since they are the major elements influencing
the scale of the program.  In addition, information about the geographic
areas, vehicle population statistics, inspection lane throughput, and personnel
requirements will be evaluated.  Other requirements, such as mechanic's train-
ing, public information, and consumer protection, will be introduced.  The
costing categories for each program will be presented in Section 4.
3.1       ADMINISTRATIVE OPTIONS
     The administrative approaches characterized in the operational format of
the inspection phase of I/M* are as follows:

     •    State-owned/operated centralized facilities - A public authority
          manages and operates publicly-owned test facilities.

     •    Contractor-owned/operated centralized facilities - A private firm,
          or other entity selected through competitive bidding is delegated
          operational responsibility for inspection.  The contractor, not the
          State, assumes financial responsibility for constructing and operating
          test centers.  Administrative control is still the responsibility of
          a public authority.
 Service garages, dealerships, and independents comprising the repair industry
 will provide the requisite maintenance for failed vehicles identified by the
 inspection phase.
                                     3-1

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    •    Privately-owned/operated decentralized facilities  - A public authority
         certifies qualified establishments  (e.g.,  independent service  garages
         and dealerships)  to perform  inspections.   The State regulates  and
         oversees the program to ensure  that I/M requirements and provisions
         are met.  This  system provides  a network of decentralized  inspection
         and repair  facilities which  are certified  and controlled by the
         State.

    •    Statistical sampling of vehicle population - Statistical sampling
         relating to an  I/M program is the process  of collecting I/M data
          (such as emissions, costs, benefits,  and repair, information) to
         provide a basis for trend  characteristics.

         A program to test a statistical sample of  vehicles has been identified
         by the Michigan Department of Transportation  (MOOT) as a candidate
         option.  It could be operated by either  the State  or a contractor,
         but is not  acceptable  to the Environmental Protection Agency  (EPA)
         because•of  the  questionable  effectiveness  of the approach.

         The collection  of such data  on  a certain number of vehicles from a
         specific vehicle population  is  called a  sample  of  the population.
         However, the process  (whereby the  sample is selected)  is  termed
         sampling.   The  nature  of the sampling process  is  likely to determine
         the success or  failure of  the conclusions  arrived  at  from  the  data.

         The method  of  selecting  the  sample  must  ensure  the sample  will
         contain  the same proportion  of  age/type/size/make, etc.,  character-
         istics of vehicles  as  contained in  the  total population.   To  achieve
         these objectives, a stratified  random sampling technique  must be
         introduced. A  "roulette wheel" selection  of  the  area  population
         could be programmed to provide  for  such  a  random selection of a
          stratified  sample.

     No administrative approach geared to mandatory  I/M is  intrinsically more
effective than  another in reducing vehicle  emissions.   However,  the specific
                                   3-2

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administrative approach chosen will have a substantial effect on initial
implementation cost,  program capital  and operational expenditures.
3.2       TEST MODES

     The emission test modes  identified by  the  State of Michigan were analyzed
with the alternative program  scenarios previously outlined.   These test modes
are:

     •   Idle-mode test
     •   Loaded-mode test
     •   Engine parameter/device  inspection

     A typical inspection sequence is illustrated in Figure  3-1.

3.2.1      IDLE-MODE TEST

     The idle-mode test, which will be costed in Section 5,  consists of measur-
ing the exhaust emissions with the vehicle  in a neutral gear and the engine at
idle.  Hydrocarbon  (HC) and carbon monoxide (CO)  levels are  measured at both a
normal- and high-idle speed.  The  test at the normal-idle speed is conducted at
the manufacturer's recommended idle (600 to 1,000 revolutions per minute
 (rpm)) uniformly, while the high-idle speed test is  conducted at 2,500 rpm.

     The overall test procedure  includes the following steps: (1)  collection of
vehicle number,  (2) visual inspection of the exhaust system  and emission
control devices;  (3) the exhaust emission test;  and  (4)  recording of the test
data.

     Based on the exhaust emission test data,  the vehicle will pass or fail.
Passed vehicles will be certified  and, if indicated  by the emission data,
impending malfunctions will be discussed with the owner.   The vehicle is then
released.  Failed vehicles will  be diagnosed for probable cause of failure and
released to the owner for required repair(s).   After repair(s),  the vehicle
will be returned to the facility and retested.
                                     3-3

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     The general characteristics of idle-mode testing are:

     •    Simple test procedure that requires minimum training for inspectors
     •    Limited diagnosis of some engine maladjustments and malfunctions
     •    Duplication by either public or private test systems
     •    Requires minimal test time and equipment
     •    Malfunctions that occur under loaded conditions may not be detected
     •    Oxides of nitrogen (NO )  testing cannot be performed effectively
                                Ji
     •    Carburetor adjustment could be made during test

3.2.2     LOADED-MODE TEST

     The loaded-mode emission test requires the use of a chassis dynamometer
and EC/CO gas analyzers, and an NOX  analyzer  (if specified) .  The test is performed
on a simple chassis dynamometer at vehicle speed and load modes that are
calculated to expose engine faults.  The operational modes  are idle, low
cruise, and high cruise.  After vehicle pretest activities  are performed, the
vehicle is positioned on the dynamometer and emission test  equipment attached.
The initial test mode is at high cruise conditions.  The driver accelerates to
a speed and load range of 44 to 50 mph and 21 to 30 horsepower  (hp), depending
upon vehicle weight.  During this period, the engine temperature is stabilized.
High cruise emission measurements are performed and the vehicle speed and load
is reduced to 22 to 30 mph and 6 to 12 hp depending again upon vehicle weight.
After measurement, the vehicle is allowed to return to idle for final measure-
ments prior to post-test operation.  Exact test speeds and  loads used depend on
vehicle weight.

     Different failure limits are established for the HC and CO concentrations
for each operational mode.  By referring to a logic diagram termed a "truth
chart," probable engine malfunctions can be identified.  This provides an
important diagnostic aid to the repair technician.  In addition to the truth
tables, a manual containing usage examples may be provided to repair facilities.
                                     3-5

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3.2.3     ENGINE PARAMETER/DEVICE INSPECTION

     In this option, vehicles are subjected to a sequence of inspections to
determine the mechanical condition of various emission-related systems.
Components and/or operating parameters with measurements outside the accepted
tolerance range are considered to have failed, and are required to be replaced
or adjusted to manufacturer's specification.  Table 3-1 presents test param-
eters and their emission relationships.  This approach does not require measure-
ment of emission levels although,in some cases, emission measurements can  be
made to evaluate the state of certain vehicle systems  (e.g., measurement of
idle CO concentration to evaluate proper idle air/fuel ratio adjustment).

     Diagnosis of failed vehicles can be complicated.  The variations in logic
flow that stem from failure contingencies are so numerous that flow diagraming
techniques become overwhelming.  The diagnostic tasks are divided into emission
control system tests, fuel system tests, ignition system tests, and mechanical
system tests.  Testing for component failure within these system areas is
accomplished during various static engine operating modes.  The modes are
described as prestart, idle, off-idle, and  special.  Prestart tests generally
concern detailed visual inspection of system components.  Idle tests involve
specific emission control components, idle  speed and mixture tests and ignition
timing, and point dwell inspection.  Off-idle testing is concerned with addi-
tional fuel system tests involving air cleaners, power enrichment, and main
circuit carburetor condition.  Ignition coil, distributor, plugs, and wires are
further tested, including mechanical and vacuum advance mechanisms.  When
mechanical system components such as  exhaust or intake valves are suspected of
failure, special tests involving static  load (power drop) are performed.
     The elements of a parameter inspection  are flexible and not everyone
agrees on which elements should be included.  In order to minimize the time of
the inspection and still have a meaningful test, SCI has estimated a requirement
of 24.4 minutes for the inspection.   This allows for a 12.2 minute visual inspec-
tion at position one and a 12.2 minute  diagnostic hook-up and test a position two.
The parameters measured include:
                                       3-6

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     Table 3-1.  ENGINE PARAMETER/DEVICE TEST AND EMISSION RELATIONSHIPS
EMISSION CONTROL SYSTEM

 1. Carburetor System
    a. Choke
    b. Metering rod
    c. Power valve
    d. Idle adjustment
    e. Float and valve
 INDICATION OF MALFUNCTION
Adjustment
Adjustment
For ruptured diaphragm
Fuel mixture
Float level
    f. Vacuum break valve  Ruptured diaphragm or
                            loose vacuum hose
 2. Ignition System
    a. Spark plugs
    b. Wires
    c. Cap

    d. Rotor

    e. Vacuum advanced

    f. El Mag trigger
    g. Timing

 3. Thermal Air Inlet


 4. Heat Riser

 5. PCV Components

 6. EGR Components

 7. EVAP Components
Electrode deterioration
Cable deterioration
Terminal corrosion or
 erosion
Terminal corrosion or
 erosion
Ruptured diaphragm or
 loose vacuum
Deterioration
Adjustment

Ruptured diaphragm or
 loose vacuum hose

Stuck

Clogged

Stuck

Clogged
 8. Air Injection System   Broken hose or fault air
 9. Spark Delay Valves

10. Three-Way Catalyst

11. Reduction Catalyst

12. Oxidation Catalyst

a
 pump

Stuck

High ppin HC
0. emissions status

0  emissions status'
                                                        POLLUTANT EMISSION
                                                             RELATION
HC
x
X
CO
 X
 X
 X
 X
 X
                                             NO
X
X


X


X
 X
 X
         X
         X
        X


        X
X


X


X
 X


 X
                X


                X


                X
 In lieu of 0_ emissions status, a gas sample would have to be checked before and
 after the catalyst.  Visual inspection could be made for a general status;  dis-
 coloration of the stainless steel case is indicative of higher temperature
 effects and possible malfunction.
                                    3-7

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     •    Oscilloscope check of ignition system
     •    Distributor vacuum and mechanical advance check
     •    Dwell check (for vehicles with points)
     •    Basic timing check
     •    Idle enrichment check
     •    RPM check
     •    EGR vacuum check
     •    EGR valve stem movement check
     •    Vacuum check at PCV

3.3       OPTIONAL INSPECTION (SAFETY AND NOISE)

     There are several associated programs that can be efficiently integrated
with I/M.  These programs are categorized as follows:  Safety Inspection, Noise
Inspection, or Safety and Noise Integrated with I/M.

3.3.1     SAFETY INSPECTION

     The vehicle-in-use  (VIU) standards and periodic motor vehicle inspection
programs presently in operation in other states emphasize safety-related
components.  There is a general belief that vehicles in good operating condition
are less likely to be involved in accidents.

     During 1975 and 1976, random check lanes were used to estimate the condi-
tion of automobiles in two Michigan counties.  This program was called the
Michigan Trial Substitute Vehicle Inspection Program; it was a substitute for
a fully implemented and mandatory vehicle safety inspection program required by
the Federal Highway Administration  (FHA).  The Michigan program set-up check
lanes in two counties.  One county checked 5 percent of the cars, and the other
checked 15 percent.  Results of the program indicated that the effect of the
5 percent program was no different than the effect of the 15 percent.

     The following items were checked as part of the safety program:

     •    Vision Defects - Visual inspection for glass  (safety glass, cracked
          or chipped windows),operating windshield wipers and washers, and
          condition of mirrors.
                                     3-8

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     •    Lighting Defects - Headlight aiming and output, high-beam indicator
          lights, tail lights, stop lights, and license plate lights.

     •    Exhaust Defects - Noise and excessive smoke.

     •    Control Defects - Steering, the foot and parking brake by the wheel-
          pull method, and by the moving/stopping test method.  Tread depth,
          tire condition, and tire pressure.

     •    Miscellaneous Defects - Horns, licenses and registrations, and seat
          belts.

     The State of Michigan no longer has a safety inspection program for
automobiles.  The safety program Michigan is considering for implementation
with the I/M program is discussed in Volume 1.  The safety test discussed in
the Section 5 - Cost Analysis is summarized above.  Brake testing may be per-
formed by:

     •    Wheel removal
     •    Moving/stopping
     •    Skid plate or low or high speed dynamic brake analyzers

The cost estimates in Section 5 are for the skid plate test method. Most brake
testing systems used for safety inspections employ platform brake testers
commonly called skid plates.  This device consists of four metal pads spaced to
accommodate the wheels of an automobile.   The pads are connected by a hydraulic
linkage to a gauge or display, calibrated in pounds of braking force.  The
vehicle to be inspected is driven onto the metal pads at a speed of between 4
and 8 miles per hour, the brakes applied so that the vehicle stops on the pads.
The force applied to the pads by the vehicle during the braking action pushes
the fluid through the return lines.  The resultant pressure is indicated on the
display.  Four separate readings are obtained, one for each wheel.  The  indica-
tor on the display retains the reading until the vehicle has moved off of the
platform.  The readings show both left-to-right eg^ialization and front-to-rear
imbalance.
                                    3-9

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     The attractiveness of the platform brake tester is its ability to quickly
carry out a brake test which indicates both left-to-right  equalization and
front-to-rear imbalance.  This test can usually be accomplished in  less  than
one minute.   Because  of this, most state- and city-operated inspection programs
use this system.

3.3.2     NOISE INSPECTION

     Federal "pass-by" noise testing procedures specify a  measurement distance
of 15 meters (50 feet) between the vehicle and the microphone used  to monitor
noise.  This requires a large, hard surface similar  to a highway  as a testing
site.  Low ambient noise levels are also necessary.  For noise testing to be
included in  I/M, it  is desirable to test vehicle  noise at  a  shorter distance,
in a stationary mode, and to have the results correlate closely with the Federal
"pass-by" testing procedures.  Previous studies have shown weak correlation
with Federal procedures when the microphone distances are  varied  and the micro-
phone height remains constant.  If the microphone height is  also  adjustable,
the correlation improves and noise testing at shorter distances is  possible.

     It is not necessary to use a dynamometer to  simulate  driving conditions
for noise testing because the instantaneous vehicle  noise  which is  responsible
for most noise standard violations depends mostly on the engine power (throttle
setting) and the engine speed.  This means that a vehicle  can be  tested  in  a
stationary position, as long as ambient noise levels are acceptable.

     The State of Michigan has enacted the following law.   Rules  for the law's
implementation must  be promulgated by the MDOT.   This  includes  holding public
hearings.  The Department of Transportation has proposed  that  these standards
be  implemented and enforced partly on a local level  and partly  by MDOT enforce-
ment terms.  MDOT will be providing  testing equipment  and  training to 40
communities  throughout  the State.
                                    3-10

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    "(1) After April 1, 1978, a motor vehicle shall not be operated or driven
on a highway or street if the motor vehicle produces total noise exceeding one
of the following limits at a distance of 50 feet except as provided in subdivi-
sions (b)(iii) and (c)(iii):
     (a) A motor vehicle with a registered weight of 8,500 pounds or more,
singly or towing a semitrailer, pole trailer, or trailer or a combination of
those trailers:
     (i) Ninety DBA if the maximum lawful speed on the highway or street is
treater than 35 miles per hour.
     (ii) Eighty-six DBA if the maximum lawful speed on the highway or street
is not more than 35 miles per hour.
     (iii)  Eighty-eight DBA under stationary run-up test.
     (b) A motorcycle or a moped as defined by section 32b:
     (i) Eighty-six DBA if the maximum lawful speed on the highway or street is
greater than 35 miles per hour.
     (ii) Eighty-two DBA if the maximum lawful speed on the highway or street
is not more than 35 miles per hour.
     (iii)  Ninety-five DBA under stationary run-up test at 75 inches.
     (c) A motor vehicle or a combination of vehicles towed by a motor vehicle
not covered in subdivision (a) or  (b):
     (i) Eighty-two DBA if the maximum lawful speed on the highway or street is
greater than 35 miles per hour.
     (ii) Seventy-six DBA if the maximum lawful speed on the highway or street
is not more than 35 miles per hour.
     (iii)  Ninety-five DBA under stationary run-up test 20 inches from the end
of the tail pipe."
3.4       GEOGRAPHIC AREA OF COVERAGE


3.4.1     NONATTAINMENT AREAS


     The MDOT has provided background documentation identifying geographic areas

that presently violate air quality standards for CO, photochemical oxidants

(O ), and NO .
  O         X


     The nonattainment areas for 0  are presented  in Figure  3-2.  The areas  of

0  nonattainment are in the 37 counties in  the  southern area of Michigan, plus

one county in the northern area.  In contrast,  CO  nonattainment is found only

in the Detroit metropolitan area as presented in Figure 3-3.   The State of

Michigan is currently meeting air quality standards for nitrogen dioxide  (NO ).

Boundaries of the urban areas of Detroit, Lansing, Flint,  and Grand  Rapids are

shown in Figure 3-4.  By provisions of the  Clean Air Act,  I/M may be implemented
                                     3-11

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              NONATTAINMENT
              AREAS
            COCSTISS
 1.  AI£CHA
 J.  ALZ2GAN
 4.  ALP5HA
 5.  ANTRIM
 6.  ASENAC
 7.  3ARAGA
 8.  3ARBS
 9.  MX
10.  3E8Z2E
11.  3ESRZ2X
12.  BRANCH
13.  CAIHOON
14.  CASS
15.  =3A!tt£VOIX
16.  CHEBOXGAN
17.  CHI5PSWA
IS.  CLARE
19.  CLJNTOJJ
20.  C8AWFORD
21.  DELIA
22.  DICXINSOH
23.  SATON
24.  EMMET
25.  GESESES
26.  3LADWTH
27.  GOGEB1C
28.  SD. TSAVEBSc
29.  33ATIOT
30.  HILLSQALS
31.  BOOGHTOH
32.  HUSON
33.  1XG3AM
34.  ICTIZA
25.  IOSCO
36.  ISDN
37.  ISABEL1A
38.  JACJ3CN
39.  iCUAHAZOO
40.  XALKASKA
41.  SSBT
42.
43.  LAX2
44.
45.  LZZLANAO
46.  L5KAWSS
47.  iTTTNGSTON
48.  U7C2
49.  XACKIMAC
SO.  MACOHB— METSO
SI.  MAOTSTES
52.  «A«QorrrE
S3.  MASOM
S4.  MECOSTA
55.  MEMOMINES
56.  MlaLAHS
57.  MISSAtTKEE
53.  MONROE
59.  MONTCAW
SO.  MONTMORENCT
61.  MOSXSGON
63.  OAKLAND-MSTSO
64.  OCSAMA
65.  OG2MAW
66.  ONTOSAGON
67.  OCSOLA
63.  OSCOOA
69.  OTSSSD
70.  OTTAWA
71.  9RESQOE ISLE
72 .  BCSCOSMQN
73.  3AGIMAH
74.  SAHI1AC
75.  SCHCOLCSAFT
76.  SSIAWASSES
77.  ST. GAi
78.  ST. JOSEPH
79.  TUSCSiA
30.  VAN 3OBSS
31.  WA3HTSIAW
32.  WAXNE— METSO
33.  WOTOSO
/  51     83     57
72     65  ;   35
                             Figure  3-2.   Michigan Ozone Nonattainment Counties
                                                           3-12

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DISTRICT  AND   COUNTY  NUMBERS
    NONATTAINMENT
    AREAS
       COUNTIES
DISTRICT
2. ALSER 	 Z
1 ALLE8AN 	 7
j 11 PWA 4
1 ANTRIM 	 3
1 AREMAC - -5
7. IARACA 	 1
1 MRRY 	 - 	 7
1 IAY — 	 — --*
11 UNTIE-. 	 3
11. ICRRIEN. ._ 7
11 MUNCH 	 7
11 CALHOUN 	 7
1* CA&» 7
11 CHARLEVOIX 	 1
11 CHEMY6AN. -4
17. CXimWA 	 2
11 CURE 	 3
11 CUNTON 	 S
21 CRAWFORD 	 4
21 DELTA 	 2
22. DICKINSON 	 1
21 EATON 1
24 EMMET 	 4
21 4fHfffiE 1

27 80SEJIC 1
21 80. TRAVERSE .3
a. SRATIOT 	
a. HILLSOALE 	
31 HOUGHTQN
S. HURON 	
11 IMHAM 	 -
M, IONIA 	
31 IOSCO 	
31 IRON - 	 -1
37. HAIEILA 	 5
31 JACKSON- I
31 KAUMAZOO —7
41 KALXASXA. 	 3
41. KENT 	 S
tt. KEWEENAW 	 1
DISTRICT
41 LAKE . T^
44 LAKER 	 1
41 LEIUNAU. 	 3
41 LENAWCE 	 I
47. UVIN6STON 	 1
41 LUCE 	 2
41 MACXINAC 	 2
SI MACOMI..METRO
11. MANOTEE 	 3
a MAROUCTTE 	 i
SI MASON 	 3
S4 MECOSTA 	 S
SI MENOMINEE 	 1
SI MIDLAND 	 1
57. MBUOKEE 	 3
SI MONROE 	 I
SI MOHTCALM 	 S
H. MONTMORENCY__4
n. MUSKEGON 	 S
O. MEWAY60 	 S
(1 OAKLAND- METRO
14 OCCANA 	 S
d 06EMAW 	 4
H. ONTONA60N ...1
17. OCEOLA 	 3
a. OSCOOA.
H OTSEBD 	
71 OTTAWA 	 S

72 ROSCOMMON...
71 SA8INAW 	 .
74 SANIUC 	

71 SMAWASSEE ...S
n. ST. CUIR-.METRO
71 ST. JOSEPH. 	 7
71 TUSCOLA 	 1
ML VAN IUREN 	 7
11. WASXTENAW..-1
O. WAYNE 	 METRO
0. WCXFORO 	 3
   51  83^57
                                                      w«eo*iKO»4 'oa«>m»
                                                       72    65    35 J
                                                  34   19
                                               8
                                                             hl-TH  79  j  74
                                                             7£JBr-l
                       HAWM* ]
                       '«   I
                        76
                                                                ~aiN(n< i UAHIM
                                                                  25 i  44
                                                    (ATOM , INOHAM  UVIMOXTOM
      .—  b    23 i  33  ! 47
	.4tL_  	.
 VANaU«IM|KAlAWA200| CAU4OUN I jACXSON
  80   39     13  I   38 4Q81
  	!	L	J	a	
  CAB  i sr.joum i MAHOI IHILLSOAU|  UMAWII  | MOMMO*
                                  11   14   78    12 I 30  i  46    58
              Figure  3-3.  Carbon Monoxide Nonattainment Areas
                                  3-13

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URBAN AREA OPTIONS
1) Detroit fcW.-XxX:
                                    J **» \  U1U
                                      53 !  43
                                      64    62    54  i 37
          ••••I—- —ifc I - •• I !!• _ —. ••^H
          •"•mat*  I anATioT

            59   I 29
                                                                 73    !   J
VAM luiiiK IKAIAM*^

  80 !  39
   Monroe County - 58
   Washtenaw County - 81
   Wayne County - 82
   Macom County - 50
   Oakland County - 63

2)  Flint

   Genesee County - 25

3)  Grand Rapids

   Ottawa County - 7-0
   Kent County - 41

4)  Lansing
   Clinton County -  19
   Eaton County - 23
   Ingham County - 33
                  Figure 3-4.  Michigan Urban/I/M Option Areas
                                    3-14

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in any or all of these areas.  They are therefore referred to as the urban I/M
option areas.

3.5       VEHICLE POPULATION
     Vehicle registration data on light-duty vehicles  (LDVs) in 1977 for state-
wide, nonattainment counties, Grand Rapids,  Lansing, Flint, and Detroit were
analyzed and are presented in Table 3-2.  Based on 1977 registration data, LDV
projections in 1983 and 1987 are also presented.  A statewide 2.8 percent
annual average growth rate was assumed in each county.*

               Table 3-2.  LIGHT-DUTY VEHICLE POPULATION FIGURES
          Motor Vehicle Population  1977  (Base)    1983       1987
Statewide
Nonattainment areas
Grand Rapids
Lansing
Flint
4,647,450
4,220,800
303,330
194,060
226,910
5,470,040
4,967,970
357,020
228,400
267 , 08
6,264,760
5,689,760
408,880
261,600
305,880
          Detroit                   2,339,490    2,753,570   3,153,640

     Vehicle registration data for such vehicle categories  as light-duty trucks
 (LOT 1: less than 6,001 Ib), light-duty trucks  (LDT  2:  6,001-8,500  Ib), heavy-
duty vehicles  (greater than 8,500 Ib), and motorcycles  are presented in Table 3-3,
Detailed vehicle registration data are presented in  Appendix A.   These data  are
used to determine the number of test  lanes and  stations needed for  the different
programs.

               Table 3-3.  OTHER VEHICLE POPULATION FIGURES  (1977)
                          Light-Duty  Medium-Duty  Heavy-Duty
     Vehicle Population     Truck        Truck        Truck   _ Motorcycle
     Statewide
     Nonattainment areas
     Grand Rapids
     Lansing
     Flint
     Detroit
761,811
642,524
46,288
36,009
40,239
252,821
24,620
21,580
1,567
1,577
729
8,233
84,869
75,917
8,451
3,573
3,415
35,262
247,420
218,640
18,920
13,540
12,820
94,630
*
 Provided by  the State of Michigan  through  correspondence.
                                     3-15

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3.6       INSPECTION LANE REQUIREMENTS

3.6.1     LANE OPERATION

     Facilities will consist of one or more multi-position lanes.  Regardless
of test mode, drive-through facilities are assumed.  The first position is the
receiving station.  Functions typically performed at this position or work
station are:

     •    Vehicle documentation check
     •    Initial underhood inspection
     •    Computer data entry

     After the receiving station functions are completed, the vehicle will be
driven to the second position which is the test station.  Typical functions
performed at this station are:

     •    Emission test  (manual or automated)
     •    Engine parameter inspection  (if applicable)
     •    More detailed underhood inspection

     After the test station, the vehicle is driven to the certification station.
Functions performed at this station are:

     •    Provide the vehicle owner test results  (manual or automatic printout)
     •    Issue a certificate of compliance
     •    Issue a failure report with diagnostic information for repair station
     •    Issue a certificate of waiver

For multi-position test lanes, it is desirable to have the functions performed
at each position to take approximately the same time.  The longest position
time will dictate the output rate.
                                    3-16

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        3.6.2     LANE  OUTPUT ANALYSIS

             In order to determine the number of lanes required for a geographic  area
        of interest for each test mode alternative, the number of inspections per year
        per lane must be first determined.  The information in the following paragraphs
        documents the lane capacity for each test mode considered.
9
        3.6.2.1   Idle Mode

             It was determined from time and motion studies conducted at various  idle
9      I/M programs that each three position lane has an ideal output rate of  one
        vehicle per 2.4 minutes.  Therefore, a single idle-inspection lane has  an
        estimated theoretical annual average output rate of 50,000 inspections.   This
        assumes 250 working days per year-and an 8 hour work day.
•
             Based upon a 30 percent stringency factor and the assumption of a  60 per-
        cent overall efficiency, the effective annual output is 23,000 LDVs per year
        ,50,000   n ,.  .
        (—~r— x 0.6) .*
•         1'3
        3.6.2.2   Loaded Mode

             The loaded mode test consists of three operating modes  (0  (idle),  30, and
        50 mph).  The idle mode  consists of two operating modes (idle and 2,500 rpm).
        The time required per operating mode is approximately 30 seconds.  Test set-up
        and disconnect  procedures  require  about 55 seconds.  Therefore, the ideal output
        rate is one vehicle per  2.9 minutes or 41,400 inspections per year.  Using the
        30 percent stringency factor and an overall efficiency of 60 percent,  the
        effective output  rate is 19,200 LDVs per year.

        3.6.2.3  Engine Parameter/Device Inspection

             SCI mechanics have estimated  that the engine parameter/device inspection
        would require between 20 to 60 minutes depending upon the thoroughness of the
I   -    test.  As described in Section 3.2.3, a total inspection time of 24.4  minutes
        is assumed.
        *Current I/M programs are experiencing a 55 to 65 percent overall efficiency.
                                            3-17

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     Utilizing a three-position station the estimated ideal output rate is one
vehicle exiting every 12.2 minutes.   This will allow 12.2 minutes at each of the
positions, yielding an ideal throughput time of  36.6 minutes.  Again using the
30 percent stringency factor and an  efficiency of  60 percent, the effective output
rate is 4,500 LDVs per year.

3.6.2.4   Safety and Noise Inspection

     If safety and/or noise inspection is added  to any of the above emission
inspection test modes, the same throughput rate  is assumed.  This is
accomplished by adding inspection personnel, increasing the number of test
lane  positions, and adding appropriate equipment  per lane.
 3.7       PERSONNEL REQUIREMENTS

      Inspection personnel required for lane operation will be  one  inspector
 for each work position.  For a three position  lane, three inspectors will  be
 required.  In addition to lane personnel, one  facility  supervisor  and  one
 clerk will be required for each facility.  Therefore, for a one  lane facility,
 the personnel complement will be five.  For a  two  lane  facility, the personnel
 complement will be eight.  These are "in operation" staffing levels to be  used
 for option comparison purposes.
 3.8       RELATED ISSUES

 3.8.1     STATE LEGISLATION

      Individual states are responsible for obtaining the  legal  authority to
 implement vehicle I/M programs.  Michigan does not have enabling  legislation;
 it will seek legislation during the  fall of  1979.  Legislation  may  be  general,
 or may be specific and assign all responsibilities for the program,  determine
 testing procedures, and even set emission standards.  Appendix  B  presents a
 detailed discussion of the issues that should be considered  for inclusion in
 I/M legislation.
                                       3-18

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3.8.2     PUBLIC INFORMATION AND PARTICIPATION

     While I/M legislation is debated, and after its passage by the Legislature,
it is of paramount importance that the citizens of Michigan be kept abreast of
all aspects of the impending program which will have an impact on their
accustomed activities.  The importance of the program as a health benefit, a
potential fuel saver,  and an economic benefit should be stressed in any public
information campaign,  to  be  weighed against the relatively minor inconvenience
of an annual emissions check.  The Clean Air Act mandates extensive and direct
participation of representative public and private interest groups as an
element of information diffusion.  Groups such as the local Lung Assocation
can generally be counted  on  to communicate the pros and cons of program elements
to their respective  constituencies.

     The basic features of  a public information  effort and a suggested time
line for their implementation in Michigan are presented in Appendix C.

3.8.3     MECHANICS TRAINING

     An I/M program will  fully succeed with respect to its intended purpose
and to the satisfaction of  the public only if qualified mechanics perform the
repairs necessary to bring  polluting vehicles into  compliance with emission
standards established under this program.  Michigan is fortunate to have a
vehicle mechanic certification and registration  system in use.   This system
will greatly ease the problem of identifying qualified mechanics to perform
vehicle repairs.  Whether vehicle inspections are performed at centralized
state or contractor facilities or at private garages,  additional mechanics
must be trained and many  mechanics retrained to  perform the necessary repairs.

     A mechanic training  program may be  funded directly by the State through
class fees paid by individual trainees,  or through  a combination of these
sources—for example, a year of state funding  followed by self-supporting
courses at the local level.  Appendix D  discusses possible mechanic training
program approaches, procedures for efficient dissemination of required skills,
estimated program costs,  and an appropriate program timeline.  Additional
mechanics training cost analysis is included in  Section 5 and Appendix F.
                                     3-19

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3.8.4  CONSUMER PROTECTION AND QUALITY ASSURANCE ISSUES
     An effective consumer protection and quality assurance element is
important to the effectiveness and acceptance of the I/M program.  It is
essential that the consumer be protected from inequities in either the
inspection or the maintenance phase of the program.  In the inspection
phase, quality assurance as an aspect of consumer protection strives to
guarantee uniformity and a high degree of precision during emissions
inspection.  In the maintenance phase, consumer protection is designed to
protect a motorist from invalid repairs in the event of emissions
test failure through such mechanisms as consumer hot lines, repair cost
ceilings, waivers, exemptions, and licensing of mechanics and repair faci-
lities .  Some of the techniques of quality assurance are periodic cali-
bration, daily operational checks and adjustments, preventive maintenance
and major equipment maintenance.  Procedures designed to minimize the
circumvention of the inspection system should also be an element of con-
sumer protection, in order to preserve fairness in program enforcement.
These issues are discussed in greater depth in Appendix E.
                                  3-20

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                                   Section 4
                     PROGRAM COST ELEMENTS AND METHODOLOGY
     A vehicle emissions testing program requires appropriate emission  test
equipment, buildings in which to complete the tests, and qualified staff  to
perform the tests.  A program must be managed to assure accuracy and uniformity,
to keep records, to arbitrate and resolve disputes, and to handle various
administrative tasks inherent in any program.  Furthermore, an inspection
program must be planned in detail and resources organized in order to provide
and maintain the operation of the program as expected and desired.

     The costs associated with an I/M program have been organized into  three
broad categories:  initial implementation costs, capital costs, and annual
operating costs.  These categories were chosen to reflect their differing
natures and timing of expenditures, as well as to identify the various  types
of expenditures that will be required.  Not all of the categories are applicable
to all program options.  Their applicability to various test types and  adminis-
trative methods is discussed in Section 6.
4.1       METHODOLOGY

     The costing of program options utilizes the concept of Life Cycle  Costs
(LCC) which assures that cost elements are systematically  considered over the
duration of the program.  A LCC model was used to facilitate the option costing
process, and has the following format:
                                    4-1

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 where:
      LCC = total program cost for expected duration
        n = index of years in life-cycle duration
        y = expected number of years in life cycle
     Q
      INV = program research and development, facility acquisition, and
            investment expenditures (in dollars)
      C   = operation and maintenance expenditures  (in dollars)

      Each of the major categories is  further defined by identifying
the contributing cost elements applicable  to the  total program.  The
analysis in this report utilizes 1978  constant dollars.

      A discussion of major cost categories follows, with the detailed
costing of elements contained in Apprndix  F.  The discussion and costing
follow the organization of Table 4-1.
4.2       INITIAL IMPLEMENTATIONAND CAPITAL COSTS  (I)

4.2.1     INITIAL IMPLEMENTATION COSTS

     After the selection of an I/M option, plans and decisions must be  made
regarding individual program elements.  Test station locations,  facility
design, actual staffing needs, etc., must all be determined on an  operational
level before equipment is purchased, personnel hired, contracts  bid and let,
etc.

     Many of these activities would likely be performed by the central  office
or program administration staff.  The various activities performed before the
program is operational are discussed below and a brief example of the type of
expenses which would be required is  presented for each activity.
                                    4-2

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                  Table 4-1.   COMMON  SET  OF  COST ELEMENTS
                                     COST ELEMENT
        INITIAL IMPLEMENTATION AND CAPITAL COSTS  (NONRECURRING)

        A.   Initial Implementation Costs

             1.  Sice Selection
             2.  Bids Preparation and Evaluation
             3.  Facilities Design
             4.  Training Plan Development
             5.  Personnel Selection
             6.  Document Preparation
             7.  Administrative Support
             3.  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.   Capital 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 Operaring Costs

              1.   Personnel
              2.   Supply
              3.   Maintenance


III.      ANCILLARY PROGRAMS ANNUAL OPERATING COSTS

         A.    Ancillary Program Costs

              A.   Mechanic Training

              B.   Public Information Program

              C.   Consumer Complaint

              D.   Vehicle Test Scheduling Costs
                                       4-3

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1.   Site Selection - After the criteria for station sites have been
     determined, specific sites must be located before purchases can be
     made.  Examples of types of costs would be mileage and personnel
     costs for searches.

2.   Bids Preparation and Evaluation - The specifications of the program
     must be written into a "Request for Proposal"  (RFP)  if  a contractor
     or private garage is selected.  If a state run program is chosen,
     specifications must be developed for operating and test
     systems.  In either case, bidders' Qualifications would have to be
     certified, and contracts drawn for selected suppliers or operators.

3.   Facility Design - Test stations must be designed to meet the require-
     ments of the selected program, as well as local zoning  ordinances  and
     building codes.

4.   Training Plan Development - Testing personnel in the program will
     need instruction in the theory and operation of test equipment, I/M
     program operations, station and test lane procedures, and public
     relations.  This training regimen, curriculum, and specific class
     scheduling must be planned and organized to ensure proper training.

5.   Personnel Selection - Various types and levels of skills will be
     required in an inspection and maintenance program.  Personnel selec-
     tion costs include the costs of determining appropriate qualifica-
     tions, recruiting, interviewing, and hiring needed personnel.

6.   Document Preparation - The progress and development of the program
     will have to be documented and reported.  This cost element represents
     the clerical, editorial, and reproduction costs incurred for recording
     the plans and schedules, and decisions made during the implementation
     period.

7.   Administrative Support - This element covers the costs of administra-
     tive personnel during facility construction, personnel selection and
     system integration, checkout, and certification.
                                4-4

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     8.    System Integration,  Checkout,  and Certification - Prior to opening
          the inspection system for operation, equipment and testing procedures
          must be checked to ensure all components work as expected, and that
          the components work well as a system.  This activity would likely be
          done in two stages.   The first of these stages would involve the
          checkout of individual station equipment after each station has been
          otherwise made ready for operation.  Performance would be compared
          with purchase and contract specifications, problems would be removed,
          and the station subjected to test procedures.  This may be integrated
          with personnel training activities.

          The second stage would involve testing of all of the inspection stations
          as a system.  This would be done  to assure program-wide uniformity
          and to test system wide components (such  as centralized data collec-
          tion procedures and equipment).

     9.    Test Scheduling System Development - Vehicles must be scheduled for
          testing.  Vehicle owners must be notified prior to their scheduled
          test period and apprised of test station locations.  The primary
          cost in this element is for computer software development.

4.2.2     CAPITAL COSTS  (CONSTRUCTION)

     Capital costs include the purchase of items such as buildings, land, and
equipment as required by the option selected.  These expenditures will be made
prior to the official starting date of the program, with the capital goods
acquired being assumed to last for the 5-year program life.

     1.    Land and Site Improvement Costs - Station sites identified during
          the initial implementation period must be purchased.  After purchase,
          nonbuilding site improvements such as paving, landscaping, and
          special utility connections may be required during and after station
          construction.  This category includes the actual costs of land and
          nonbuilding improvements to the land itself.
                                     4-5

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     2.    Facility Construction - Test  stations will be  constructed to  meet
          program requirements.  This category covers  all  costs  related to the
          actual building construction,  including test lanes,  station office
          areas, and data collection/storage areas.

     3.    Instrumentation Cost - Test equipment required by the  type of test
          selected  for the program will have to be purchased and installed.
          Some initial equipment calibration is in this  cost element.  Instru-
          mentation costs include  all equipment required for a test lane to
          operate,  as well as tools required for  routine maintenance.

     4.    Office Equipment - Each  station will have an office area for  adminis-
          tration of the individual station.  Some office  equipment will be
          needed to process employee work records and schedules, collect and
          compile emission data, prepare inspection forms, and if required,
          collect inspection fees.   Office equipment and incidental office
          supplies  are included in this cost element.

     5.    Computer  Costs - Depending upon the amount of  automation desired for
          data collecting, various types of computer equipment may be required
          both at the station and  central office  level.   This element includes
          estimated equipment costs for both a manual  system and automated
          system, as well as software  for controlling station computer  equipment
          data collection.

4.2.3     CAPITAL COSTS (OTHER)

     1.    Administrative Office Equipment - Regardless of  program type, a
          state agency will be responsible for managing  and coordinating the
          program.   The program administration staff will  require office
          furniture  and equipment.

     2.    Quality Control Equipment - This cost category covers  the costs of
          mobile vans,  correlation  vehicles, and  the  referee stations that
          will be required to ensure ongoing test accuracy,  to provide  mechanisms

                                    4-6

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          for resolving disputes and granting repair waivers, and to provide
          back-up testing capabilities in the event of test lane failures.

     3.   Consumer Complaint - The consumer protection/complaint program is
          designed to protect consumers from unreasonable repair charges, to
          monitor repair practices, and to investigate complaints of these
          practices.  Vehicles will be needed for use by personnel to investi-
          gate the complaint.  The cost of the vehicles is the only item
          included in this cost element.
4.3       ANNUAL OPERATING COSTS (II)
     Operating costs represent expenditures that will be made throughout the
program life, and cover personnel costs, equipment and station maintenance,
utilities, debt service, and other charges incidental to the operation of an
inspection and maintenance program.

4.3.1     FACILITY OPERATING COSTS

     1.   Personnel - Employees salaries and benefits are the largest cost
          item in station operation.  Benefits include insurance, vacation,
          retirement, and sick leave.

     2.   Maintenance and Miscellaneous Item Costs - Inspection equipment will
          require routine and corrective maintenance for operation to design
          specifications and program requirements.  The costs of operating and
          maintaining test stations consist of utilities, property taxes,
          testing and administrative supplies, landscaping, cleaning, or other
          similar expenses.

4.3.2     SUPPORT COSTS

     1.   Administrative - A central office  staff  will be required to administrate
          and coordinate the activities  performed  under the I/M program.  Depending
                                      4-7

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          on the type of management scheme to be utilized for the program, there
          may be a number of administrative levels with responsibilities delegated
          to regional or lower levels.  An example of the type of cost involved is:

               Personnel and Office Supplies - These costs  cover the salaries
               and benefits of program administration staff and management.
               Office space will be obtained for the program administrative
               staff, and that office stocked with necessary office supplies.
               Office rent, supply costs, and utilities are costed in  this
               element.

     2.   Data Analysis - Emission data collected will be analyzed and summa-
          rized for use in determining failure rates, vehicle data, repair
          costs,  etc.  This information could be utilized for both ongoing
          operations and for quarterly reports.  This cost  item includes the
          cost of collecting and analyzing data, writing, typing, and  printing
          reports.

     3'   Training - Ongoing personnel training expenditures will be required
          to keep program employees abreast of changes in automotive emissions
          technology and to train new employees.

4.3.3     QUALITY CONTROL OPERATING COSTS

     The quality control activities utilize mobile vans, correlation vehicles,
and referee stations to ensure test accuracy and uniformity throughout the
inspection operation.  Costs for these activities include personnel who will
perform the various quality control  tasks, procure associated supplies,  and take
responsibility for maintenance of the capital equipment utilized in quality
control.
                                       4-8

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4.4       ANCILLARY PROGRAM ANNUAL OPERATING COSTS  (III)

4.4.1     MECHANICS TRAINING

     The annual costs of a mechanics training program will consist of instruc-
tors' salaries, the costs of course materials, classroom space, and certifica-
tion costs.  This program may be self-supporting.

4.4.2     PUBLIC INFORMATION PROGRAM

     This category includes the media expenses to inform the public of the
program's goals, station locations, consumer protection provisions,  and
general program operation.  Media coverage includes radio, TV, and newspaper
advertising, pamphlets, bumper stickers, and presentations.

4.4.3     CONSUMER COMPLAINT

     The consumer complaint activities consists of complaint follow up and
service industry field checks.  Operating costs entailed in the course of
these activities are for personnel expenses, vehicle operating and maintenance,
and computer time-sharing.

4.4.4     VEHICLE TEST SCHEDULING COSTS

     After the method of vehicle owner scheduling has been programmed and
integrated with vehicle registration, the cost of the scheduling inspections
should consist only of computer processing and core time, inspection notifica-
tion cards, and postage.
4.5       COST-RELATED ASSUMPTIONS
     The cost methodology was based upon the following assumptions:
                                     4-9

-------
The program options are costed and compared over a 5-year period.

Initial implementation and capital costs are amortized using 6 percent
annual interest.  Depreciation schedules for different cost elements
are as follows:

     Land     = forever (note:  value is assumed  to remain constant)
     Facility = 20 years
     Other    = 5 years

Only single- and double-lane facilities will be built.

The personnel fringe benefits for all state and contractor employees
including sick leave, vacation, retirement, insurance, holidays,
etc., are estimated at 25 percent of base rate.

Contractor burden costs include overhead and general administration
(G/A) and are determined as follows:

     Overhead costs such as certain indirect costs related to corpo-
     rate and management personnel salaries, travel, and expenses
     are assumed to be 5 percent of annual operating costs  (SCI
     estimate).

     G/A costs such as certain indirect costs related to administra-
     tive, accounting, purchasing, financing, etc., activities are
     assumed to be 10 percent of contractor annual operating costs
     plus overhead (SCI estimate).

     Contractor's fee or profit is assumed at 10  percent of total
     cost (SCI estimate).
                           4-10

-------
     •    State burden cost to cover G/A is estimated at 15 percent of state
          annual operating cost (MDOT estimate).

               Burdened labor cost = 1.15x(state  annual operating costs).

     •    All costs are presented in 1978 dollars.

     •    Facility Construction cost = $20/sq.  ft.  (MDOT estimate).

     •    Land Cost (provided by MDOT).

               Major metropolitan (over 1,000,000 population)
                 Urban                            $5.97/sq. ft.
                 Suburban                         $4.02/sq. ft.
                 Rural                            $0.50/sq. ft.
               Submetropolitan (200,000-1,000,000 population)
                 Urban                            $4.02/sq. ft.
                 Suburban                         $1.00.sq. ft.
                 Rural                            $0.11/sq. ft.
               Minor metropolitan (under 200,000 population)
                 Urban                            $2.00/sq. ft.
                 Suburban                         $0.70/sq. ft.


4.6       OPERATIONAL RELATED ASSUMPTIONS
     The following operational related assumptions were used in the analyses:

     •    Effective annual LDV output rate for test modes with and without
          safety inspection at 30 percent stringency factor per lane are:

               Idle mode test                     = 23,000/yr.
               Loaded mode test                   = 19,200/yr.
               Engine parameter/device inspection = 4,500/yr.

     •    All retested vehicles are assumed to pass.
                                    4-11

-------
                                   Section 5
                         OPTION DEFINITION AND COSTING
     The Michigan I/M study includes the evaluation of possible I/M program
alternatives and comparison of their potential benefits and costs.  The pro-
gram variables are identified as:  administrative approach; method of test,
with and without safety and noise inspection;  geographic areas; vehicle cate-
gories; and stringency factor.  There are also other factors subject to pro-
gram analysis.  For example, the test facilities can have up to six test lanes,
with each lane having from one to three positions.  However, if all possible
combinations of these elements were to be considered, more than one million
program alternatives would require analysis.  It is therefore impractical to
analyze all these factors.

     In this study, 24 major alternatives are evaluated.  They are listed in
Table 5-1.  However, of the 24 major alternatives, only seven base options are
analyzed in detail.  They are:  base options 1, 2, 3, 5, 7, 9, and 17 shown
in Table 5-2.  They include all the common primary characteristics of I/M
program costs.  The remaining 17 options are analyzed in Section 6.
5.1      BASE OPTIONS DEFINTION

     The base options have all the following common characteristics:

     •    Thirty-eight ozone nonattainment counties covered
     •    Inspection of light-duty passenger vehicles only
     •    Thirty percent stringency factor
                                       5-1

-------
     Table 5-1.  ADMINISTRATIVE APPROACH VERSUS METHOD OF TEST
Administrative Approach

S tate-operated

 Without safety and
  noise
 With safety and noise
                                       Method of Test
  Idle
Loaded
Engine Parameter/
Device Inspection
Option 1*  Option  9*
Option 2*  Option 10
               Option 17*
               Option 18
Contractor-operated

 Without safety and
  noise
 With safety and noise
Option 3*  Option 11
Option 4   Option 12
               Option 19
               Option 20
Private garage

 Without safety and
  noise
 With safety and noise
Option 5*  Option 13
Option 6   Option 14
               Option 21
               Option 22
Statistical sampling

 Without safety and
  noise
 With safety and noise
Option 7*  Option 15
Option 8   Option 16
               Option 23
               Option 24
 *Base options
                              5-2

-------
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     The basic options consider a network of test stations in the nonattain-
ment counties.  The nonattainment counties and the associated motor vehicle
population are presented in Section 3.  The basic options consider only passen-
ger vehicles.  Light trucks under 6,001 pounds are included in the discussion
of Section 5.9.

     The test station is designed for three-position lanes.  The single-lane
arrangement is necessary to provide convenience for the public in areas having
a low vehicle population.  It was assumed that the maximum travel  (one way)
for the worst-case condition  (in Marquette County) for a vehicle owner is
approximately 30 miles.  The average travel is less than 5 miles, and in the
Detroit metropolitan area, would vary from 1 to 3 miles.

     The assumed stringency factor throughout this analysis is 30 percent,
which means the program is designed to fail 30 percent of the vehicles tested.
Assuming that all failed vehicles would require retesting before registration,
the actual number of inspections to be performed  is 30 percent higher than  the
vehicle population required to participate in the program.  For the purpose of
this study, no retests are assumed.

     The common assumptions are:

     •    The inspection station work schedule is 8 hours per day,  250 days
          per year, for a total of 2,000 hours.

     •    An efficiency factor of 0.60 was used  (see Section 3).

     •    The base option configuration is two lanes.

5.1.1     OPTION COSTS

     The costs associated with an I/M program implementation and operation
 are:
           Initial  implementation  and capital  costs
                                      5-4

-------
              •    Annual operating costs
              •    Ancillary program costs

0             Refer to  the discussion (see Appendix F)  concerning base data and analyti-
         cal  techniques relating to the development of these costs.

              To determine the costs, additional ass-.imptions were made.  These are:
9
              •    Funds for construction costs should be made available in 1982 to
                   assure implementation of program in 1983.

^             •    Vehicle population growth from 1983 to 1987 will be accommodated by
                   additional hours of operation,  rather  than construction of new-
                   inspection facilities.

*        5.1.2     OPTION-SPECIFIC BENEFITS

              Inspection/maintenance is designed to reduce automobile emissions as a.
         means of improving ambient air quality.  The magnitude of potential emission
         reduction is dependent on the type and size of the vehicle population covered
         by the mandatory program.   The failure  rate and  the nature of mechanics training
         also influence the magnitude of emission  reductions.  Although a loaded mode
         emissions test may be capable of identifying more reasons for emission failure
         than the idle  test,  it has not been  established  that greater emission reductions
         result when a  loaded mode  test is used  in a program.  The U.S. EPA has determined
         only that a difference in  test effectiveness is  not recognizable unless repair
         mechanics are  extensively  trained in the  proper  use of loaded test diagnostic
         information.

              Because the remainder of emission reduction variables are held constant
 ^        over all options, given the proposed stringency factor and establishment of a
         mechanic training program in Michigan, the emission credits attributable to
         I/M are essentially the same for all options.  The exception is statistical
         sampling, which captures only a small fraction of total vehicle population,
 )        and parameter inspection,  for which credits have not yet been established by
                                            5-5

-------
The U.S.  EPA.   Emissions benefits,  therefore, are not evaluated in this section
for each option,  but were  discussed for the I/M program as a whole in Section 2.

     The variables  that differentiate one option from another are administra-
tive framework, test type  and scope, and what each option is intended to
accomplish.  The advantages  and disadvantages of these variables as applied to
each program type are discussed for each option.  The discussions focus on each
option's ease of implementation,  consumer convenience, consumer protection,
flexibility for future modification and financial feasibility.  A summary of
these criteria is provided below:

     •    Ease of Implementation - It is generally acknowledged that the
          procedures involved in government purchases of land, equipment and
          buildings, or of hiring personnel very often slow the effective
          implementation of any governmental program.  These procedural problems
          should not be as pronounced with a private contractor or an estab-
          lished repair garage.   In this respect, the contractor and the
         - certified garage approaches offer an advantage which may include
          avoidance of the costs  associated with implementation delays.

     •    Consumer Convenience - The decentralized administrative approach
           (private garage) has the advantage of offering inspection facilities
          at numerous convenient locations, while the location of the fewer
          state- or contractor-operated testing centers may require some
          motorists to drive  farther for an emissions check.  The private
          garage option also  offers the opportunity for one-stop inspection
          and repair.  This does not hold true in the state or contractor
          option.

     •    Consumer Protection - Consumer protection issues include the  consis-
          tency of test procedures, proper calibration of test equipment,  and
          a check on  the  effectiveness of maintenance performed in response  to
          vehicle failure.  Consumer protection in respect of the above criteria
           is easiest  to manage in  a centralized program where testing and
          repair are  separated.  In a private garage program, testing and
                                     5-6

-------
calibration procedures  and quality  control may vary from one garage to
the next,  thereby jeopardizing the  validity of test results.

Flexibility for Future Modification - Flexibility is measured in
terms of the ability of the State to expand or diminish the program's
scope as changes are warranted, and the ability of the program to
accommodate these modifications.  The state and contractor options
have a greater opportunity for modification than the decentralized
garage program.  The decentralized program has more facilities and
inspectors than a centralized program, and procedural changes must
be communicated to a larger and more dispersed group.

Financial Flexibility - Centralized programs typically require high
initial capital outlay for land, buildings, and equipment.  This may
present a problem for a state-operated program in that the government
must raise the necessary  funds.  One advantage of the contractor
centralized approach is that it eliminates the necessity  for a State
to make such large capital outlays.  The private garage  (decentral-
ized) approach also holds this advantage over a state-run program,
because most of the program capital outlay is for purchase by garages
of emission testing equipment which complies with State specifica-
tions.  Thus, restrictions on a State's ability to raise  funds would
support the argument for private sector operated programs.
                           5-7

-------
5.2       OPTION_1


     The configuration for Option 1 is:


     •    State-operated
     •    Idle-mode (automated testing and data processing)

     •    Without safety and noise inspection


5.2.1     OPTION 1 - DEFINITIONS AND REQUIREMENTS


     This option is a state-administered and operated network of  idle  test

stations.  The station requirements.based upon the  1983 LDV vehicle population

and the 23,000 LDV effective annual output rate  (see Section 3), are shown  in

Table 5-3.  Area types were defined in Section 4.5.   Detailed lane analysis for

each county is presented in Appendix G.   Dividing  the vehicle population of

LDVs for each county in 1983 by the annual effective LDV capacity of an
inspection lane determines how many lanes are needed in each county.
                        Table  5-3.   STATION REQUIREMENTS
                      OPTION 1:   STATE-OPERATED,  IDLE TEST

                   Area Type             Single Lane   Double Lane
                  Metropolitan
                   Urban                      0            16
                   Suburban                  0            12
                   Rural                      6             0

                  Submetropolitan
                   Urban                      0            18
                   Suburban                 40             0
                   Rural                     16             0

                  Minor metropolitan
                   Urban                     65             0
                   Suburban                  0             0
                  TOTAL                     12?            46"
      The basic personnel requirements of an I/M program involve both operations
 and administration.   Operating personnel are those directly involved in

 performing inspections or providing managerial functions at the inspection
 site.  Administrative personnel are involved in operating support programs
 such  as public information,  consumer complaint, mechanics training, and quality
                                    5-8

-------
control, or in providing overall program management and administration.  The
personnel requirements for Option 1 are shown in Table 5-4.

     Referee stations are necessary when any of the following functions are to
be performed:

     •    Investigate consumer complaint cases that require detailed  study to
          establish the validity of the complaint.   (The referee  station can
          perform a detailed or gross diagnostic evaluation.  The complaint
          can be resolved from the resulting data.)

     •    Developed improved testing practices, improved quality  control
          practices, and correlation studies with  relation to the Federal Test
          Procedures  (FTP).

     •    Provide additional testing capacity for  short-term overflow of
          demand.

     •    Develop diagnostic  routines to establish  repair effectiveness during
          during retesting.

     The regional office requirements and referee  stations for Option 1 are
shown in Table 5-5.  Regional offices are located  in designated test  facilities
in which the regional manager and secretary are located.

5.2.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS  (ONE-TIME COSTS)

     The implementation costs, construction costs, and the other  capital costs
for Option 1 are presented in Tables 5-6, 5-7, and 5-8, respectively.

5.2.3     OPERATIONS COST (ON-GOING COSTS)

     The operating costs for both the inspection facilities and ancillary
programs are presented in Tables 5-9 and 5-10 for  the years 1983  through and
including 1987.
                                     5-9

-------
                    Table 5-4.   PERSONNEL REQUIREMENTS
                   OPTION 1:   STATE-OPERATED,  IDLE TEST
                        	Personnel	
                         State       Inspection  Quality  Ancillary
Classification	  Administrative   Facility   Control   Program   Total
Program manager 1
Quality control manager 1
Manager 1
Environmental engineer 3
Statistical analyst 2
Regional manager
Facility manager
Technician
Secretary/clerk 7
Field investigator 	
TOTAL 15
1
1

6 9
1 3
13 13
173 173
657 22 679
186 6 3 202
	 	 3_ 	 3
1,029 34 7 1,085
                                 5-10

-------
            Table 5-5.   REFEREE OFFICE AND REGIONAL REQUIREMENTS
                     OPTION 1:   STATE-OPERATED,  IDLE TEST
                                a
              Referee   Regional
  Location    Stations   Offices
Kalamazoo
Grand Rapids    1
Lansing
Ann Arbor
Saginaw
Flint

Pontiac
Mt. Clemens

Detroit

  TOTAL
1


1
 2

 1

 4

13
                               Other  Counties  Served
Branch
Allegan
Barry
Van Buren
Kalamazoo
St. Joseph
Cass
Berrien

Kent
Ottawa
Muskegon

Montcalm
Gratiot
Ionia
Clinton
Eaton
Ingham
Calhoun
Hillsdale
Lenawee
Jackson
Washtenaw
Monroe
Livingston

Midland
Bay
Saginaw
Tuscola
Huron
Sanilac
Shiawassee
St. Clair
Genessee
Lapeer

Oakland
Macomb
Wayne
 Regional stations utilize office space in designated inspection facilities for
 management runctions only.
                                    5-11

-------
  Table 5-6.  INITIAL IMPLEMENTATION COSTSa
     OPTION 1:  STATE-OPERATED, IDLE TEST
                  YEAR - 1982
                 (1978 Dollars)

	Cost Elements	     Dollars

1.  Site selection                      74,200

2.  Bid preparation and evaluation      14,800

3.  Facilities design                  249,100

4.  Training plan development            3,500

5.  Personnel selection                 43,000

6.  Document preparation                10,000

7.  Administrative support             156,000

8.  System integration, check-out
     and certification                 352,500

9.  Test scheduling system
     development                        67,000

    TOTAL                              970,100

a
 All costs were rounded off to hundreds of dollars.
                     5-12

-------
 Table 5-7.  CAPITAL COSTS (Construction)
   OPTION 1:  STATE-OPERATED, IDLE TEST
                YEAR - 1982
               (1978 Dollars)

       Cost Elements              Dollars
1.  Land and Site Improvement
    Land                          6,010,800
    Site improvement              3,337,400

2.  Facility construction         6,903,600

3.  Instrumentation               2,091,500

4.  Office equipment                259,500

5.  Computer costs
    Hardware                      8,869,500
    Software                        108,000

    TOTAL                        27,580,300
                  5-13

-------
        Table 5-8.  CAPITAL COSTS (Other)
      OPTION 1:  STATE-OPERATED, IDLE TEST
                   YEAR - 1982
                  (1978 Dollars)

           Cost Elements                Dollars
1.  Administrative office equipment       12,000

2.  Quality control equipment

    Mobile units (five)                   100,400
    Referee stations (six)             1,272,000
    Correlation car (one)                  9,700

3.  Consumer complaint
    (3 complaint inspection cars)         15,000

    TOTAL                              1,409,100


 Including land cost of $512,400 and building
 cost of $524,400.
                      5-14

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-------
5.2.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown in Table 5-11 include capital recovery
of the cost of implementation, construction, and other capital using an interest
figure of 6 percent per annum.*  The total annualized cost in 1978 dollars is
$28,282,618.

5.2.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 1 for an
average yearly passenger vehicle population of 5,320,000 over 5 years of
program operation is $5.32.

5.2.6     BENEFITS

     In this type of program, all administrative and operational responsibil-
ities are vested in governmental agencies of the State of Michigan.

     With respect to its ease of implementation, a  state usually imposes
limitations on hiring of employees, requires that buildings and equipment meet
certain specifications, and imposes certain regulations regarding capital
expenditures.  The time required to obtain approval usually has a significant
effect on the implementation of a state-operated program.  State agencies
wishing to employ personnel for such a program have to request these personnel
through the State Civil Service.  Since appropriations are based on specific
personnel ceilings, requests for personnel to staff an emissions I/M program
have to be approved by the State Legislature in advance of the date they are
actually required for operations of the program.  In addition, it is usually
difficult to hire part-time personnel to accommodate the peak demand period.
Similarly, agency requests for estimated capital expenditures for land, build-
ings, and equipment to be used in state-operated centralized facilities must
be appropriated by the legislature.  However, land  and buildings for such a
*The State  of Michigan has  identified the  program funding would be provided
 under  the  State  of  Michigan's  Motor Vehicle  Highway Fund at a 6 percent
 interest rate.
                                     5-17

-------
                                   Table  5-11.
                  ANNUALIZED PROGRAM COSTS  AND CONSUMER FEE
                    OPTION 1:   STATE-OPERATED,  IDLE TEST
                               (1978 DOLLARS)
             Category
             Capital      Annualized
Cost     Recovery Factor     Cost
1.
2.
3.
4.
5.
6.
7.
8.
9.
Initial implementation costs
Capital costs (construction)
Land
Facility and site improvement
Equipment
Capital costs (other)
Land
Facility and site improvement
Equipment
Subtotal (Items 1, 2, and 3)
Annual operating costs
Ancillary program costs
Subtotal (Items 5 and 6)
G/A (@ 15% on Items 5 and 6)
Total (Items 4, 7, and 8)
970,100 0.2374
6,010,800 0.06
10,241,000 0.0872
11,328,500 0.2374
512,400 0.06
524,400 0.0872
372,300 0.2374
17,337,020 1
3,484,300 1

230,300
360,600
893,000
2,639,400
30,700
45,700
88,400
4,338,100
17,337,020
3,484,300
20,821,320
3,123,198
28,282,618
   Consumer Fee  = $28,282,618/5,320,000 = $5.32
Referee stations impose land and building construction costs
Average over 5 years
                                    5-18

-------
program might be leased, rather than purchased, thus alleviating the requirement
for large capital outlay by the State.

     Consumer convenience is essentially the same for state- and contractor-
centralized programs .  The number of stations in a centralized program is
limited and, even if they are located with maximum accessibility in mind, most
motorists are required to travel out of their neighborhoods to undergo the
emission test itself and, if required, repair and retest.  Nevertheless,
consumers are better protected under a centralized program.  A centralized
program assures consumers accurate and consistent test results.  Each vehicle
is tested by an organization having no special interest in auto repairs.
Testing is conducted in high-volume facilities designed for the purpose and
utilizing standardized procedures and specially trained personnel.  Furthermore,
a centralized program facilitates automated data collection and analysis  to
eliminate errors in the recording of test results.

     Flexibility for future modification is possibly the greatest  in the
State-operated program, but depends upon the enacted legislation.  Develop-
ments that would require program modification include  (1) change in emission
standards,  (2) change in program scope, and  (3) change in equipment or program
operations.  For each of these contingencies, the State-operated program  has
maximum flexibility for modification because no contractual changes would be
required.

     Because the program is expected to be self-sustaining, the major item
concerned with financial feasibility is implementation costs.  Initial financing
could be provided by the State Treasury from general revenues or obtained
through a bond issue (which may not be possible under current Michigan law).
In either case, the costs impose significant financial responsibilities on the
State.

     This option involves idle mode testing.  This type of testing entails the
least cost for equipment.  The basic idle mode test requires the use of an
emission analyzer which costs from $1,500 to $4,000 per unit.  The cost for
training test technicians/inspectors is also lower for idle mode equipment.
                                     5-19

-------
As discussed earlier, the idle mode is capable of achieving substantial emis-
sion reductions when used in conjunction with a reasonable stringency factor.
It should be noted that, if the mode of testing is projected to change during
the course of the program, this option offers the opportunity for constructing
test facilities that can later be adapted to loaded mode, parameter/device, or
other FTP-correlatable short test procedures.
                                     5-20

-------
5.3       OPTION 2

     The configuration for Option 2 is:

     •    State-operated
     •    Idle-mode (automated testing and data processing)
     •    With safety and noise inspection

5.3.1     OPTION 2 - DEFINITIONS AND REQUIREMENTS

     This option is a state-administered and operated network of idle  test
stations.  The station requirements,.based upon the 1983 LDV vehicle population
and the 23,000 LDV effective annual output rate  (see  Section  3), are shown in
Table 5-12.  Area types were defined in Section  4.5.   Detailed  lane analysis for
each county is presented in Appendix G.  Dividing the vehicle population of LDVs
for each county in 1983 by the annual effective  LDV capacity  of  an inspection  lane
determines how many lanes are needed in each county.
                      Table 5-12.  STATION REQUIREMENTS
                   OPTION 2:  STATE-OPERATED,  IDLE  TEST WITH
                          SAFETY AND NOISE INSPECTION
                     Area Type          Single Lane   Double  Lane
                 Metropolitan
                   Urban                      0            16
                   Suburban                   0            12
                   Rural                      6             0
                 Submetropolitan
                   Urban                      0            18
                   Suburban                 40             0
                   Rural                    16             0
                 Minor metropolitan
                   Urban                    65             0
                   Suburban                	0_             0_
                 TOTAL                     127            46
     Additional equipment cost associated with the safety  inspection  is pre-
sented in Table 5-13.  There are three options for brake test under safety
inspection (Table 5-14).  In the cost analysis, skid-plate  testing was used
for the brake test.  Noise testing would require an additional  $582 per lane
                                     5-21

-------
              Table 5-13.   NOISE AND SAFETY EQUIPMENT'
     Equipment
 Per Unit
   Per 2-Lane Facility
Sound-level meter
Tire depth gauge
Headlamp aimer
Brake tester (plate)
Total
$ 582.00
5.00
175.00
13,000.00
$13,762.00
(2)
(2)
(2)
(2)

$ 1,164.00
10.00
350.00
26,000.00
$27,524.00
 Additional equipment for converting an idle mode station to one
 with safety and noise capabilities.
     Table 5-14.  COMPARATIVE MATRIX ANALYSIS FOR BRAKE TESTING
                                          Strategy
Item   Cost Consideration  Wheel  Pull

 1    Land cost increase   20 percent
      from base unit
      Operating time to
      accomplish test
                      c
      Lane requirement
      (increase)
      Equipment cost
      (increase)

      Maintenance cost
      (increase)

      Personnel
      (increase)
15 minutes
need 4-5
bays added
for wheel
pulling
               Moving/
               Stopping

              114 percent
3 minutes
              Skid Plate
   0.0 min.
$300.00
5 persons
$300.00
1 person
$13,000.00


$ 1,300.00/yr


1 person
 Wheel pulling does not provide for complete inspection of the brake
 system, as only one wheel is pulled.

 The brake test is performed while moving the vehicle from position
 one to position two.

"The side bays for wheel pulling are necessary to provide for the
 vehicle throughput rate as noted under Item 3.
                              5-22

-------
for noise testing equipment.  Two additional inspectors per lane over Option 1
will be required to maintain the same output rate and perform the safety and
noise inspections.

     The basic personnel requirements of an I/M program involve both operations
and administration.   Operating personnel are those directly involved in
performing inspections or providing managerial functions at the inspection
site.  Administrative personnel are involved in operating support programs
such as ancillary programs and quality control, or in providing overall program
management and administration.  The personnel requirements for Option 2 are
shown in Table 5-15.

     Referee stations are necessary when any of the following functions are to
be performed:

     •    Investigate consumer complaint cases that require detailed study to
          establish the validity of the complaint.   (The referee station can
          perform either a detailed or gross diagnostic evaluation.  The
          complaint can be resolved from the resulting data.)

     •    Develop improved testing practices, improved quality control prac-
          tices, and correlation studies with relation to the Federal Test
          Procedures (FTP).

     •    Provide additional testing capacity for short-term overflow of
          demand.

     •    Develop diagnostic routines to establish repair effectiveness
          during retesting.

     The regional office requirements and referee stations for Option 2 are
shown in Table 5-16.  Regional offices are located in designated test facilities
in which the regional manager and secretary are located.
                                    5-23

-------
                      Table 5-15.  PERSONNEL REQUIREMENTS
             OPTION 2:  STATE-OPERATED, IDLE TEST WITH SAFETY AND
                               NOISE INSPECTION

                         	PERSONNEL	
                             State       Inspection  Quality  Ancillary
    CLASSIFICATION	  Adminis trative   Facility   Control   Program   TOTAL


Program manager                1                                             1

Quality control manager        1                                             1

Manager                        1                                             1

Environmental engineer         3                        69

Statistical analyst            2                                  13

Regional manager                             13                             13

Facility manager                            173                            173

Technician                                1,095        22                1,117

Secretary/clerk                7            186         6         3        202

Field investigator            	         	        	         _3_      	3_

TOTAL                         15          1,467        34         7      1,523
                                    5-24

-------
          Table 5-16.  REFEREE AND REGIONAL STATION REQUIREMENTS
     OPTION 2:  STATE-OPERATED, IDLE TEST WITH SAFETY AND NOISE INSPECTION
             Referee   Regional
 Location    Stations  Offices
Other Counties Served



Kalamazoo 0





Grand Rapids 1




Lansing 1





Ann Arbor 1






Saginaw




Flint 1

Pontiac 1
Mt. Clemens
Detroit 1
TOTAL 6



1





1




1





1






1




1

2
1
4
13
Branch
Allegan
Barry
Van Buren
Kalamazoo
St. Joseph
Cass
Berrien
Kent
Ottawa
Muskegon
Montcalm
Gratiot
Ionia
Clinton
Eaton
Ingham
Calhoun
Hillsdale
Lenawee
Jackson
Washtenaw
Monroe
Livingston
Midland
Bay
Saginaw
Tuscola
Huron
Sanilac
Shiawassee
St. Clair
Genes see
Lapeer
Oakland
Macomb
Wayne

Regional stations utilize office space in designated inspection facilities for
management functions only.
                                   5-25

-------
5.3.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS (ONE-TIME COSTS)

     The implementation costs, construction costs, and the other capital costs
for Option 2 are presented in Tables 5-17, 5-13, and 5-19, respectively.

5.3.3     OPERATIONS COST (ON-GOING COSTS)

     The operating costs for both the inspection facilities and ancillary
programs are presented in Tables 5-20 and 5-21 for the years 1983 through and
including 1987.

5.3.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown in Table 5-22 include capital recovery
of the cost of implementation, construction, and other capital using an interest
figure of 6 percent per annum.*  The total annualized cost in 1978 dollars is
$37,419,700.

5.3.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 2  for an
average yearly vehicle population of 5,320,000 over S years of program operation
is $7.04.

5.3.6     BENEFITS

     The State of Michigan has performed  extensive analysis on the benefits of
a safety testing program, the results of  which are not discussed in this
report.

     Michigan also regulates vehicle noise levels, the context of  which is
discussed in Section 3.3.2.  This regulation is not presently in operation but
is expected to be implemented in the near future.  Enforcement will be  simpli-
fied if the noise standard compliance test is coupled with the emissions
inspection at a  "one-stop" facility.
 *The State of Michigan has  identified  the program  funding would  be  provided
  under the State of Michigan's Motor Vehicle Highway  Fund at  a 6 percent
  interest rate.
                                     5-26

-------
     Table 5-17.  INITIAL IMPLEMENTATION COSTSa
OPTION 2:  STATE-OPERATED, IDLE TEST WITH SAFETY AND
            NOISE INSPECTION, YEAR - 1982
                   (1978 Dollars)

              Cost Elements               Dollars
   1.  Site selection                      74,200

   2.  Bid preparation and evaluation      14,800

   3.  Facilities design                  249,100

   4.  Training plan development            3,500

   5.  Personnel selection                 43,000

   6.  Document preparation                10,000

   7.  Administrative support             156,000

   8.  System integration, check-out
        and certification                 352,500

   9.  Test scheduling system
        development                        67,000

       TOTAL                            1,294,000
    All costs were rounded off to hundreds of dollars.
                         5-27

-------
              Table 5-18.  CAPITAL COSTS  (Construction)
OPTION 2:  STATE-OPERATED, IDLE TEST WITH SAFETY AND NOISE INSPECTION
                             YEAR - 1982
                           (1978 Dollars)

                      Cost Elements             Dollars
             1.  Land and site improvement
                 Land                          6,010,800
                 Site improvement              3,337,400

             2.  Facility construction        11,460,000

                                b
             3.  Instrumentation               5,105,400

             4.  Office equipment                259,500

             5.  Computer costs
                 Hardware                       8,869,500
                 Software                         108 , OOP

                 TOTAL                        35,150,600
          66 percent increase on Option  1 for allowing  two
          more test stations at each facility.
         b
          Including additional $13,762 per lane  for  safety
          and noise equipment.
                                 5-28

-------
                 Table 5-19.  CAPITAL COSTS  (Other)
OPTION 2:  STATE-OPERATED, IDLE TEST WITH SAFETY AND NOISE INSPECTION
                             YEAR - 1982
                             (1978 Dollars)

                     Cost Elements                Dollars
          1.  Administrative office equipment       12,000

          2.  Quality control equipment

              Mobile units  (five)                  100,400
              Referee stations   (six)            1,272,000
              Correlation car (one)                  9,700

          3.  Consumer complaint
              (3 complaint inspection cars)         15,OOP

              TOTAL                              1,409,100
           Including land cost of $512,400 and building
           cost of $524,400.
                              5-29

-------
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5.4       OPTION  3
     The configuration  for Option  3  is:


     •    Contractor-operated

     •    Idle-mode  (automated  testing and data processing)

     •    Without  safety  and noise inspection


5.4.1     OPTION 3 - DEFINITIONS AND REQUIREMENTS


     This option is a contractor-operated network  of idle test stations with

the State administering all other  functions performed in Option 1.   The station
requirements, based upon the 1983 LDV vehicle population and  the 23,QQQ. LDV

effective annual output rate (see Section 3), are shown in Table 5-23.   Area
types were defined in Section 4.5.   Detailed lane analysis for each, county is

presented in Appendix G.  Dividing the vehicle population of  LDVs for each.

county in 1983 by the annual effective LDV capacity of an inspection lane deter-

mines how many lanes are needed in each county.

                      Table 5-23.   STATION REQUIREMENTS •
                   OPTION  3:  CONTRACTOR-OPERATED,  IDLE TEST

                   Area Type             Single Lane   Double Lane
                 Metropolitan
                   Urban                      0            16
                   Suburban                   0            12
                   Rural                      6            0

                 S ubme tropo1i tan
                   Urban                      0            18
                   Suburban                  40            0
                   Rural                     16            0

                 Minor  metropolitan
                   Urban                     65            0
                   Suburban                 	p_            0

                 TOTAL                      127            46


     The basic personnel  requirements  of an I/M program involve both operation

and administration.  Operating personnel are  those  directly  involved in

performing inspections or providing  managerial functions  at  the inspection
                                     5-33

-------
site.  Administrative personnel are involved in operating support programs
such as ancillary programs and quality control, or in providing overall program
management and administration.  The personnel requirements for Option 3 are
shown in Table 5-24.

     Referee stations are necessary when any of the following functions are to
be performed:

     •    Investigate certain consumer complaint cases that require detailed
          study to establish the validity of the complaint.   (The referee
          station can perform either a detailed or gross diagnostic evaluation.
          The complaint can be resolved from the resulting data.)

     •    Develop improved testing practices, improved quality control prac-
          tices, and correlation studies with relation to the Federal Test
          Procedures  (FTP).

     •    Develop diagnostic routines to establish repair effectiveness
          during retesting.

     The regional office  requirements and referee stations for Option  3 are
shown in Table 5-25.  Regional offices are  located in designated  test  facilities
in which the regional manager and secretary are located.

5.4.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS  (ONE-TIME  COSTS)

     The implementation costs, construction costs, and the other  capital  costs
for  Option  3 are presented in Tables 5-26,  5-27, and 5-28, respectively.

5.4.3     OPERATIONS COST (ON-GOING COSTS)

     The operating  costs  for both the inspection facilities  and  ancillary
programs are presented  in Tables 5-29 and  5-30  for the years  1983 through and
including 1987.
                                     5-34

-------
                                  Table 5-24.

                            PERSONNEL REQUIREMENTS

                   OPTION 3:  CONTRACTOR-OPERATED, IDLE TEST
                                           PERSONNEL
    CLASSIFICATION
Program manager



Quality control manager



Manager



Environmental engineer



Statistical analyst



Regional manager



Facility manager



Technician



Secretary/clerk



Field investigator



TOTAL



a
 State personnel

b
 Contractor personnel
State Inspection Quality Ancillary
Administrative Facility Control Program
1
1
1
3 6
2 1
13
173
657 22
7 185 6 3
	 	 	 3_
15 1,029 34 7
TOTAL
1
1
1
9
3
13
173
679
202
	 3_
1,085
                                     5-35

-------
             Table  5-25.   REFEREE  AND REGIONAL STATION REQUIREMENTS
                 OPTION  3:   CONTRACTOR-OPERATED,  IDLE TEST
Referee Regional
Location Stations Offices



Kalamazoo 1 1





Grand Rapids 1 1




Lansing 1 1





Ann Arbor 1 1






Saginaw - 1




Flint 1 1

Pontiac 1 2
Mt. Clemens - 1
Detroit !_ _4_
TOTAL 6 13
Other Counties Served
Branch
Allegan
Barry
Van Bur en
Kalamazoo
St. Joseph
Cass
Berrien
Kent
Ottawa
Muskegon
Montcalm
Gratiot
Ionia
Clinton
Eaton
Ingham
Calhoun
Hillsdale
Lenawee
Jackson
Washtenaw
Monroe
Livingston
Midland
Bay
Saginaw
Tuscola
Huron
Sanilac
Shiawassee
St. Clair
Genes see
Lapeer
Oakland
Macomb
Wayne

Regional stations utilize office space in designated inspection facilities  for
management functions only
                                      5-36

-------
   Table 5-26.  INITIAL IMPLEMENTATION COSTS
   OPTION 3:  CONTRACTOR-OPERATED, IDLE TEST
                  YEAR - 1982
                 (1978 Dollars)

          Cost Elements                Dollars
1.  Site selection3                     74,200
                                  a
2 .  Bid preparation and evaluation      14 , 800

3.  Facilities design                  249,100

4.  Training plan development            3,500

5.  Personnel selection                 43,000

6.  Document Preparation                10,000
                          a
7.  Administrative support             156,000

8.  System integration, check-out
     and certification                 352,500

9 .  Test scheduling system
     development                        67,000

    TOTAL                              970,100

a

 Contractor cost
 State cost
b
°State cost is $2,200(= $43,000 x T||F)
                                  10 SD
 Contractor cost is $40,800
                    5-37

-------
 Table 5-27.   CAPITAL COSTS (Construction)
 OPTION 3:   CONTRACTOR-OPERATED, IDLE TEST
                YEAR - 1982
               (1978 Dollars)
       Cost Elements
1.  Land and site improvement

    Land
    Site improvement

2.  Facility construction

3.  Instrumentation

4.  Office equipment

5.  Computer costs

    Hardware
    Software

    TOTAL
 Dollars



  6,010,800
  3,337,400

 6,903,600

 2,091,500

   259,500
  8,869,500
    108,000

27,580,300
 Contractor cost
 State cost
                   5-38

-------
         Table 5-28.  CAPITAL COSTS (Other)
     OPTION 3:  CONTRACTOR-OPERATED, IDLE TEST
                    YEAR - 1982
                    (1978 Dollars)

           Cost Elements                 Dollars
 1.  Administrative office equipment       12,000

 2.  Quality control equipment

     Mobile units  (fiye)                  100,400
     Referee stations   (six)            1,272,000
     Correlation car (one)                  9,700

 3.  Consumer complaint
     (3 complaint inspection cars)         15,000

     TOTAL                              1,409,100

a
 Cost to the State
b
 Including land cost of $512,400 and building cost
 of $524,400
                       5-39

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-------
5.4.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown in Tables 5-31 and 5-32 for both the
State and contractor include capital recovery of the cost of implementation,
construction, and other capital using an interest figure of 6 percent per
annum.*  The total annualized costs in 1978 dollars are:

                     Contractor      State       Total
                     $25,541,670  $5,371,100  $30,912,770

5.4.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 3 for an
average yearly vehicle population of 5,320,000 over 5 years of program operation
is:

                          Contractor   State   Total
                             $4.80     $1.01   $5.81

5.4.6     BENEFITS

     The majority of the benefits associated with this option are similar  to
those of Option 1 but with a difference with, respect to implementation and  finan-
cial flexibility.  In a contractor-operated program, the contractor is expected to
provide the capital outlay  for construction and operation of the inspection
facilities.  The actual implementation time requirement is not expected to be
any greater for the contractor than it is  for the State.  The minor difference
is the amount of time required for the State to prepare a Request for Proposal,
solicit responses, review bids, and let the contract.  However, this time  is
offset by the time saved by the State because it is not responsible for the
acquisition of land and the construction of the facilities.  A contractor  has
the flexibility to add or reduce staff loading according to demand without
being encumbered by State Civil Service personnel procedures.  Additionally, a
*The State of Michigan has identified the program funding would be provided
 under the State of Michigan's Motor Vehicle Highway Fund at a 6 percent
 interest rate.
                                     5-42

-------
                                  Table 5-31.
            ANNUALIZED PROGRAM COSTS AND CONSUMER FEE - CONTRACTOR
                   OPTION 3:  CONTRACTOR-OPERATED, IDLE TEST
                                (1978 DOLLARS)
              Category
                                      Cost
1.

2.
Initial implementation costs

Capital costs (construction)
Land
Facility and site improvement
Equipment

Capital costs (other)
Land
Facility and site improvement
Equipment
634,200
                                        6,010,800
                                       10,241,000
                                       11,228,500
                                                0
                                                0
                                                0
    Capital
Recovery Factor

    0.2374
             0.06
             0.0872
             0.2374
4.

5.

6.

7.

8.

9.
Subtotal  (Items 1, 2, and 3)

Annual operating costs             16,580,000            1

Consumer protection costs                   0

Subtotal  (Items 5 and 6)

Overhead & G/A (@ 15.5% on Item 5)

Contractor's fee  (@ 10% on Items 1, 2, 7, and 8)

TOTAL (Items 4, 7, 8, and 9)

Contractor's share - Consumer Fee = $25,541,670/5,320,000 =  $4.
Annualized
   Cost

   150,600
                    360,600
                    893,000
                  2,665,600
                                   0
                                   0
                          	0_

                           4,069,800

                          16,580,000

                          	0_

                          16,580,000

                           2,569,900

                           2,321,970

                          25,541,670

                         80
                                    5-43

-------
                                  Table 5-32.
                ANNUALIZED PROGRAM COSTS AND CONSUMER FEE - STATE
                   OPTION 3:  CONTRACTOR-OPERATED, IDLE TEST
                                (1978 DOLLARS)
              Category
  Cost
1.  Initial implementation costs

2.  Capital costs (construction)
    Land
    Facility and site improvement
    Equipment

3.  Capital costs (other)
    Land
    Facility and site improvement'
    Equipment

4.  Subtotal (Items 1, 2,  and 3)

5.  Annual operating costs
  335,900
        0
        0
  100,000
  512,400
  524,400
  372,300
  953,000

3,484,300
    Capital
Recovery Factor

    0.2374
    0.2374
    0.06
    0.0872
    0.2374
6.  Consumer protection costs"

7.  Subtotal (Items 5 and 6)

8.  G/A (@ 15% on Items 5 and 6)

9.  Total (Items 4, 7, and 3)

    State's share consumer fee = $5,371,100/5,320,000 = $1.01

a
 Referee stations impose land and building construction costs
b
 Average over 5 years
Annualized
   Cost

    79,700
         0
         0
    23,700
    30,700
    45,700
    88,400

   268,200

   953,000

 3,484,300

 4,437,300

   665,600
                             5,371,100
                                    5-44

-------
contractor may be able to raise capital more quickly, thereby expediting
program implementation.

     Most of the consumer convenience characteristics of a State-operated
program are also applicable to a contractor-operated program because both
utilize centralized facilities.  Waiting time, however, is more controllable
in a contractor-operated program because of the contractor's ability to hire
temporary or part-time inspectors to increase vehicle throughput during peak
volume periods.

     With regard to consumer protection, the state must take a more active
role in assuring the accurate operational performance of the contractor's
facilities.  These assurance measures are discussed in Appendix E.

     The flexibility for modification of a contractor program could or could
not be equivalent to that of the State program dependent upon the substance of
the agreement between the contractor and the State.  If the contract is very
specifically defined, modifications could be very difficult without financial
penalties to the State.
                                     5-45

-------
5.5       OPTION 5

     The configuration for Option 5 is:

     •    Private garage-operated
     •    Idle-mode (manual operation and data collection)
     •    Without safety and noise inspection

5.5.1     OPTION 5 - DEFINITIONS AND REQUIREMENTS

     This option is a private garage-operated network of idle test stations.
This option adds the following assumptions:

     •    All private garages will participate
     •    Only manual inspection equipment will be installed

     This option does not include costs of constructing new facilities.
Existing private garages that participate in the I/M program will purchase the
necessary testing equipment and the State would assume capital costs of adminis-
tration, office equipment, quality control equipment, mechanic training,
consumer complaint, and vehicle test scheduling.

     The basic personnel requirements of an I/M program involve both operations
and administration.   Operating personnel are those directly involved in
performing inspections or providing managerial functions at the inspection
site.  Administrative personnel are involved in operating support programs
such as ancillary programs and quality control, or in providing overall program
management and administration.  The personnel requirements for Option  5 are
shown in Table 5-33.

     Referee stations are necessary when the following functions are to be
performed:

     •    Investigate consumer complaint cases that require detailed study  to
          establish the validity of the complaint.  The referee station can
                                      5-46

-------
                              Table 5-33.
                        PERSONNEL REQUIREMENTS
             OPTION 5:  PRIVATE GARAGE-OPERATED, IDLE TEST

                    State       Inspection   Quality   Ancillary
                Administrative   Facility    Control    Program
Classification    Personnel     Personnel   Personnel  Personnel  Total

Program manager       1                                             1

Quality control       1                                             1

Manager               1                                             1

Environmental
 engineer             3                        12                  15

Statistical
 analyst              2                        .13

Regional
 manager

Facility
 manager

Technician                                     44                  44

Secretary/clerk       7                        12          3       16

Field
 investigator        	                                    3        3

  TOTAL              15                        68          7       90

a
 Personnel associated with service centers may vary according to
 work assignment and business nature
                                5-47

-------
          perform a detailed or gross diagnostic evaluation.  The complaint
          can be resolved from the resulting data.

     •    Develop improved testing practices, improved quality control prac-
          tices, and correlation studies with relation to the Federal Test
          Procedures (FTP).

     •    Develop diagnostic routines to establish repair effectiveness
          during retesting.

     The referee station requirements for Option 5 are shown in Table 5-34.
The number of stations have been increased because of more consumer complaints
and less sophisticated test equipment being utilized.

5.5.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS (ONE-TIME COSTS)

     The implementation costs, construction costs, and the other capital costs
for Option 5 are presented in Tables 5-35, 5-36, and 5-37, respectively.

5.5.3     OPERATIONS COST (ON-GOING COSTS)

     The operating costs for both the inspection facilities and ancillary
programs are presented in Tables 5-38 and 5-39 for the years 1983 through and
including 1987.

5.5.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown in Tables 5-40 and 5-41 include
capital recovery of the cost of implementation, construction, and other
*The State of Michigan has identified the program funding would be provided
 under the State of Michigan's Motor Vehicle Highway Fund at a 6 percent
 interest rate.
                                     5-48

-------
                                   Table 5-34
                          REFEREE STATION REQUIREMENTS
                 OPTION 5:  PRIVATE GARAGE-OPERATED, IDLE TEST
  LOCATION    NUMBER OF STATIONS
Kalamazoo
Grand Rapids
Lansing
Ann Arbor
Saginaw
Flint


Pontiac

Mt.  Clemans

Detroit

  TOTAL
 2

 1

_3_

12
                        COUNTY SERVED
Branch
Allegan
Barry
Van Buren
Kalamazoo
St. Joseph
Cass
Berrien

Kent
Ottawa
Muskegon

Montcalm
Gratiot
Ionia
Clinton
Eaton
Ingham
Calhoun

Hillsdale
Lenawee
Jackson
Washtenaw
Monroe
Livingston

Midland
Bay
Saginaw
Tuscola
Huron
Sanilac
Shiawassee

St. Clair
Genessee
Lapeer

Oakland

Macomb

Wayne
                                    5-49

-------
                             Table 5-35
                   INITIAL IMPLEMENTATION COSTS*
            OPTION 5:   PRIVATE GARAGE-OPERATED,  IDLE TEST
                            YEAR - 1982
                           (1978 DOLLARS)
                  Cost Elements                        Dollars
1.  Site selection                                           0

2.  Bid preparation and evaluation                           0

3.  Facilities design                                        0

4.  Training plan development                            3,500

5.  Personnel selection                                  2,200

6.  Document preparation                                10,000

7.  Administrative support                             156,000

8.  System integration, checkout and certification       7,500

9.  Test scheduling development                         67,000

    TOTAL                                              246,000
a
 State cost
                               5-50

-------
                             Table 5-36
                   CAPITAL COSTS (CONSTRUCTION)
            OPTION 5:  PRIVATE GARAGE-OPERATED, IDLE TEST
                            YEAR - 1982
                           (1978 DOLLARS)
                  Cost Elements                            Dollars
1.  Land and site improvement

    Land                                                            0
    Site improvement                                                0

2.  Facility construction                                           0

3.  Instrumentation*                                       51,856,000

4.  Office equipment                                                0

5.  Computer costs

    Hardware                   •                                     0
    Software                                                  100,000

    TOTAL                                                  51,956,000

 Private Garage Cost - Cost is based on $3,656 per service center.  There
 would be 13,965 service centers in 1987
b
 State cost
                              5-51

-------
                                  Table 5-37.
                             OTHER CAPITAL COSTS3
                 OPTION 5:  PRIVATE GARAGE-OPERATED, IDLE TEST
                                  YEAR - 1982
                                (1978 DOLLARS)
                  Cost Elements                               Dollars
1.  Administrative office equipment                            12,000


2.  Quality control equipment

    Mobile units  (ten)                                        200,800
    Referee stations (twelve)                               2,544,000
    Ccorrelation cars (two)                                     19,400


3.  Consumer complaint (3 complaint inspection cars)           15,000

    TOTAL                                                   2,791,200

a
 Cost to the State
 Assuming 10 percent of private garages will be randomly selected for
 quality control inspection per 90 days
£»
 Including land cost of $1,024,800 and building cost of $1,048,800
                                    5-52

-------








































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-------
capital 6 per cent per annum.*  The total annualized cost in 1978 dollars are:

     •    For state -              $ 6,097,800
     •    For private garage -     $23,850,800
     •    Total -                  $29,948,600

5.5.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 5 for an
average yearly vehicle population of 5,320,000 over 5 years of program operation
is:
     •    For state -
     •    For private garage -
     •    Total -

5.5.6     BENEFITS
     The use of private garage-operated decentralized facilities offers many
of the same advantages as the contractor-operated approach.  In the decentral-
ized approach, however, the State would have the responsibility for the certifi-
cation of garages, training of inspectors, and quality  control.  Both  the
certification of garages and the training of inspectors could be carried out
under the existing Michigan Motor Vehicle Repair Act.   For quality control,
the State would be required to provide one or more  "challenge" garages to
enable a motorist to obtain an independent inspection to  compare results with
the private-garage inspections.  This would involve acquisition of land,
building, equipment, and staff by the State.  Even  though Michigan's capital
investment and staff requirements would be much lower than for a state-
operated program, they would be greater than for a  contractor-operated option
 (Option 3).

     A decentralized private-garage program offers  the  greatest convenience to
the motorist.  Due to the number of garages already in  existence, the  aggregate
traveling time and distance required to take the test would be lowest  for  all
                                     5-57

-------
options considered.  The most convenient aspect of this option is that the
motorist may undergo the initial test, maintenance, repairs, and retest in a
single visit to the emissions testing stations.   The reduced queueing
(waiting) time resulting from the larger total of available testing lanes may
be offset by the fact that private garages are not specialized facilities and
thus efficiency could be lower.

     Consumer protection is an issue of great concern for this option.  In
contrast to a centralized program, the chances of a consumer receiving one or
more inaccurate tests are greater due to the difficulty in achieving uniform
testing and calibration enforcement procedures.  This problem could be offset
in part by the State's deploying a greater number of facility inspectors to
perform more frequent quality checks.

     A decentralized program is less amenable to modification than a state
program.  A change in the scope and method of testing could be implemented
rather easily by requiring the garages to follow the prescribed procedure, but
substitution of equipment could engender major problems due to the reluctance
by garage entrepreneurs to invest additional capital if debt on the original
equipment is not fully paid.
                                     5-58

-------
5.6       OPTION 7

     The configuration for Option 7 is:

     •    State-operated, statistical sample
     •    Idle-mode (manual testing and data collection)
     •    Without safety and noise inspection

5.6.1     OPTION 7 - DEFINITIONS AND REQUIREMENTS

     This option is a state-administered and operated network of idle test
stations.  It was assumed that a 5 percent test rate would provide a statisti-
cally adequate sample of the in-use vehicle population.  This implies that
approximately 250,000 vehicles would be sampled every year.

     In order to calculate the number of test stations required to test 5 per-
cent of the vehicle population, it was estimated that an inspection team
(three technicians) could test 23,000 vehicles per year.  This requires that
test stations be located in all areas with a vehicle population of 460,000 or
greater, and therefore requires three one-lane stations, four two-lane stations,
one referee station (located  in Detroit), and one mobile unit for quality control
checks and backup for  the referee  station.  Driving distance was not considered.
This may limit participation  from  a practical standpoint.

    The basic personnel requirements of an I/M program include both operations
and administration. Operating  personnel are those directly involved in perform-
ing inspections or providing managerial functions at the inspection site.
Administrative personnel are involved  in  operating support programs such as
ancillary programs and quality control, or  in providing overall program manage-
ment and administration.  The  personnel requirements for Option 7 are shown in
Table 5-42.
                                       5-59

-------
                              Table 5-42.
                        PERSONNEL REQUIREMENTS
        OPTION 7:  STATE-OPERATED,  IDLE TEST, 5 PERCENT SAMPLE
                                       PERSONNEL
CLASSIFICATION
    State       Inspection  Quality  Ancillary
Administrative   Facility   Control   Program   TOTAL
Program manager 1
Quality control manager 1
Manager 1
Environmental engineer 3
Statistical analyst 2
Regional manager
Facility manager
Technician
Secretary/clerk 7
Field investigator 	
TOTAL 15
1
1
1
1 4
1 3
0
7 7
33 4 37
7 1 1 16
	 	 _1 _1
47 6 3 71
                                 5-60

-------
5.6.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS (ONE-TIME COSTS)


     The implementation costs, construction costs, and the other capital costs

for Option 7 are presented in Tables 5-43, 5-44, and 5-45, respectively.


                  Table 5-43.  INITIAL IMPLEMENTATION COSTSd
            OPTION 7:  STATE-OPERATED, IDLE TEST, 5 PERCENT SAMPLE
                                   YEAR - 1982
                                 (1978 DOLLARS)

                         Cost Elements               Dollars
1.
2.
3.
4.
5.
6.
7.
8.

9.

Site selection
Bid preparation and evaluation
Facilities design
Training plan development
Personnel selection
Document preparation
Administrative support
System integration, checkout
and certification
Test scheduling system
development
7,800
9,300
16,000
3,500
43,000
10,000
156,000

9,500

67,000
                   TOTAL                             322,100
               a.
                All costs were rounded-off to hundreds of dollars.
                    Table 5-44.  CAPITAL COSTS  (CONSTRUCTION)
            OPTION 7:  STATE-OPERATED, IDLE TEST, 5 PERCENT SAMPLE
                                  YEAR - 1982
                                  (1978 DOLLARS)
                            Cost Elements               Dollars
                    1.  Land and site improvement
                        Landa                            433,700
                        Site improvement                 140,600
                    2.  Facility construction            320,400
                    3.  Instrumentation                  105,100
                    4.  Office equipment                  16,500
                    5.  Computer cost
                        Hardware                               o
                        Software                         100,000

                        TOTAL                          1,116,300
                    a
                     Assuming all facilities located in submetropolitan
                     urban area.

                                     5-61

-------
                     Table 5-45.   CAPITAL COSTS (OTHER)
           OPTION 7:   STATE-OPERATED,  IDLE TEST,  5 PERCENT SAMPLE
                                  YEAR - 1982
                                 (1978 DOLLARS)
          	Cost Elements	    Dollars
          1.  Administrative office equipment                12,000
          2.  Quality control equipment
                a. Mobile unit (one)                          20,100
                b. Referee station3 (one)                   212,000
                c. Correlation car (one)                      9,700
          3.  Consumer Complaint (1 complaint inspection)      5,000
              TOTAL                                         258,800
           Including land cost of $85,400 and building cost of $68,800.

5.6.3     OPERATIONS COST  (ON-GOING COSTS)

     The operating costs for both the inspection facilities and ancillary
programs are presented in Tables 5-46 and 5-47 for the years 1983 through and
including 1987.

5.6.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown  in Table 5-48 include capital recovery
of the cost of implementation, construction, and other capital using an interest
figure of 6 percent per annum.*  The  total annualized cost in 1978 dollars  is
$1,808,800.

5.6.5 .    CONSUMER FEES

     The average vehicle owner fee (in 1978 dollars) for Option 7 for an
average yearly vehicle population of  250,000 over 5 years of program operation
is $7.23.  If the consumer fee were to be distributed over the 5,320,000
vehicles owners, the fee would be $0.34 per owner.
*The State of Michigan has identified the program funding would be provided
 under the State of Michigan's Motor Vehicle Highway Fund at a 6 percent
 interest rate.
                                     5-62

-------
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                5-65

-------
5.6.6     BENEFITS

     The purpose of this option is to make use of a statistically sampled
cross section of the vehicle population to demonstrate to the U.S. EPA that
(1) the majority of vehicles on Michigan roads is currently performing to
manufacturers specifications, and (2) Michigan motorists tune their cars
regularly, especially prior to winter months, thereby achieving the same
purpose as a regular I/M program.  The qualitative advantages and disadvant-
ages for this option are similar to those for Option 1 with the exception  that
the U.S. EPA does not recognize this as a viable method of emissions control
and will not allow an emission reduction credit for the stated purpose.
However, this relatively low-cost random selection approach could, if scientif-
ically structured, provide a data base ample to support the contention that a
more expensive mandatory and all-inclusive program is unwarranted and that the
projected emission reduction credits for  a  full-scale program may be fallacious.
                                     5-66

-------
5.7       OPTION 9


     The configuration for Option 9 is:


     •    State-operated
     •    Loaded-mode (automated testing and data processing)

     •    Without safety and noise inspection


5.7.1     OPTION 9 - DEFINITIONS AND REQUIREMENTS


     This option is a state-administered and operated network of loaded-mode

test stations.  The station requirements,based upon the 1983 LDV vehicle popu-

lation and the 19,200  LDV effective annual output rate  (see Section 3}, are

shown in Table 5-49.   Area types were defined in Section 4.5.  Detailed lane

analysis by county is  presented in Appendix G.  Dividing the vehicle population
of LDVs for each county  in 1983 by the  annual effective LDV capacity of an

inspection lane determines how  many lanes are needed in each county.
                      Table 5-49.  STATION REQUIREMENTS
                    OPTION 9:  STATE-OPERATED, LOADED TEST

                   Area  Type             Single Lane  Double  Lane

                Metropolitan
                  Urban                      0            18
                  Suburban                   0            14
                  Rural                     10            0

                Submetropolitan
                  Urban                      0            27
                  Suburban                  34            0
                  Rural                     19            0

                Minor metropolitan
                  Urban                     78            0
                  Suburban                   0            _0_

                    TOTAL                  141            59
     The basic personnel requirements of an I/M program involve both operations
and administration.   Operating personnel are those directly  involved  in  per-
forming inspections or providing managerial functions at the  inspection  site.
                                     5-67

-------
Administrative personnel are involved in operating support programs such as
ancillary programs and quality control, or in providing overall program manage-
ment and administration.  The personnel requirements for Option 9 are shown in
Table 5-50.

     Referee stations are necessary when any of the following  functions are to
be performed:

     •    Investigate consumer complaint cases that require detailed study to
          establish the validity of the complaint.   (The referee station can
          perform either a detailed or gross diagnostic evaluation.  The
          complaint can be resolved from the resulting data.)

     •    Develop improved testing practices, improved quality control prac-
          tices , and correlation studies with relation to  the  Federal Test
          Procedures  (FTP).

     •    Provide additional testing capacity for short-term overflow of demand.

     •    Develop diagnostic  routines  to  establish repair  effectiveness  during
          retesting.

     The  regional office  requirements  and referee stations for Option  9  are
 shown in  Table  5-51.  Regional offices are located in designated test  facilities
 in which  the regional manager and  secretary ara  located.

 5.7.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS (ONE-TIME  COSTS)

     The  implementation costs, construction costs, and the other capital costs
 for  Option  9 are presented  in Tables 5-52, 5-53,  and 5-54, respectively.

 5.7.3     OPERATIONS  COST (ON-GOING COSTS)

     The  operating  costs  for  both  the  inspection facilities  and ancillary
 programs  are presented  in Tables 5-55  and 5-56  for the years  1983  through and
 including 1987.
                                     5-68

-------
                               Table 5-50.
                         PERSONNEL REQUIREMENTS
                 OPTION 9:  STATE-OPERATED, LOADED TEST

                     State       Inspection   Quality   Ancillary
                 Administrative   Facility    Control    Program
 Classification    Personnel     Personnel   Personnel  Personnel  Total
Program manager        1                                             1

Quality control        1                                             1

Manager                1                                             1

Environmental
 engineer              3                         69

Statistical
 analyst               2                                    13

Regional
 manager                            14                              14

Facility
 manager                           200                             200

Technician                         777          22                 799

Secretary/clerk        7           214           6          3      230

Field
 investigator         	         	          	         _3_    	3_

   TOTAL              15         1,205          34          7    1,261
                                 5-69

-------
                                  Table 5-51
                   REFEREE AND REGIONAL STATION REQUIREMENTS
                    OPTION 9:   STATE-OPERATED,  LOADED TEST
   Location
Referee   Referee
Stations  Offices
Kalamazoo
Grand Rapids
Grand Rapids
Lansing
Ann Arbor
Saginaw
Flint


Pontiac

Mt. Clemens

Detroit
            2

            1

           _4_
           14
           County Served
Kalamazoo
Berrien
Van Buren
Cass
St. Joseph
Allegan
Branch

Kent
Muskegon

Ottawa
Barry
Montcalm
Gratiot
Ionia
Clinton
Shiawassee

Ingham
Eaton
Calhoun
Jackson

Washtenaw
Monroe
Livingston
Hillsdale
Lenawee

Saginaw
Midland
Bay
Tuscola
Huron
Sanilac

St. Clair
Genessee
Lapeer

Oakland  (two-lane)

Macomb  (part of one-lane)

Wayne
 Regional stations utilize office space in designated inspection facilities
 for management functions only.
                                     5-70

-------
                   Table 5-52
          INITIAL IMPLEMENTATION COSTS
     OPTION 9:  STATE-OPERATED, LOADED TEST
                   YEAR - 1982
                 (1978 DOLLARS)

            Cost Elements                   Dollars
1.  Site selection                            85,000

2.  Bid preparation and evaluation            19,400

3.  Facilities design                        466,800

4.  Training plan development                  5,000

5.  Personnel selection                       43,000

6.  Document preparation                      10,000

7.  Administrative support                   156,000

8.  System integration, check-out and
    certification                            596,900

9.  Test scheduling system development        67,000

    TOTAL                                  1,449,100
                      5-71

-------
   Table 5-53.   CAPITAL COSTS (CONSTRUCTION)
     OPTION 9:   STATE-OPERATED,  LOADED TEST
                   YEAR - 1982
                 (1978 DOLLARS)

       Cost Elements                Dollars
1.  Land snd Site Improvement

    Land                            7,242,700
    Site improvement                3,720,000

2.  Facility construction           9,336,000

3.  Instrumentation                 6,747,000

4.  Office equipment                  300,000

5.  Computer costs

    Hardware                       10,489,500
    Software                          108,000

    TOTAL                          37,943,200
                     5-72

-------
                        Table 5-54.
                   CAPITAL COSTS (OTHER)
          OPTION 9:  STATE-OPERATED, LOADED TEST
                        YEAR - 1982
                      (1978 DOLLARS)

                Cost Elements                 Dollars
     1.  Administrative office equipment        12,000

     2.  Quality control equipment
         Mobile units (five)                   100,400
         Referee stations*                   1,272,000
         Correlation car (one)                   9,700

     3.  Consumer complaint (3 complaint
           inspection cars)                     15,OOP

         TOTAL                               1,409,100

aincluding land cost of $512,400 and building cost of $524,400
                          5-73

-------

































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5.7.4     ANNDALIZED PROGRAM COSTS

     The annualized program costs shown in Table 5-57 include capital recovery
of the cost of implementation, construction, and other capital using an interest
figure of 6 percent per annum.*  The total annualized cost in 1978 dollars is
$33,493,600.

5.7.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 9 for an
average yearly vehicle population of 5,320,000 over 5 years of program operation
is $6.30.

5.7.6     BENEFITS

     A loaded mode test requires additional equipment, mainly a dynamometer,
for complete testing.  It takes longer to perform a test, reducing throughput
accordingly.  The cost of training  inspectors is increased three-fold over
that for an idle emission test.  The major benefit of a loaded mode test is
that it is able to provide superior diagnostic information to that of the idle
test.  The diagnostic test procedure, if accomplished effectively, indicates
probable adjustments or repairs that should be performed.  This assumes that
properly trained mechanics are available.  This technique may result in reduced
repair costs to the vehicle owner.  Additionally, the longevity of engine
emissions control performance may be enhanced.

     The test procedure includes engine-load modes that tend to stress certain
emission-critical components.  Components that fail during the stress conditions
may be marginal under normal operating conditions.  Replacement of these
marginal components may preclude subsequent failure and resultant high exhaust
emissions.  A loaded mode test can  measure tailpipe emissions of oxides of
nitrogen  (NO } and could be a valuable tool where there is a NO  problem.
            X                                                  X
 *The State of Michigan has identified the program  funding would  be  placed under
  the State of Michigan's Motor Vehicle Highway Fund  at  a 6  percent  interest rate.
                                     5-76

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-------
5.8       OPTION 17

     The configuration for Option 17 is:

     •    State-operated
     •    Engine Parameter/Device Inspection  (EPDI)  (manual testing and  data
          collection)
     •    Without safety and noise inspection

5.8.1     OPTION 17 - DEFINITIONS AND REQUIREMENTS

     This option is a state-administered and operated network of  engine
parameter/device inspection test stations.  The station requirements, based
upon the 1983 LDV population and the 4,500 LDV effective annual output rate
(see Section 3),  are  shown  in Table 5-58.  Area types were defined in Section
4.5.  Detailed lane analysis by county is presented in Appendix G.  Dividing
the vehicle population of LDVs for each  county in 1983 by the annual effective
LDV capacity of an  inspection lane determines how many lanes are needed in
each county.
                      Table 5-58.   STATION REQUIREMENTS
         OPTION 17:  STATE-OPERATED, ENGINE PARAMETER/DEVICE INSPECTION
                   Area Type             Single Lane  Double Lane
                Metropolitan
                  Urban                      0           80
                  Suburban                   0           73
                  Rural                     12             0
                Submetropolitan
                  Urban                      0           92
                  Suburban                   0           95
                  Rural                     82             0
                Minor metropolitan
                  Urban                    120           38
                  Suburban                 134          	0_
                    TOTAL                  348          378

     The basic personnel requirements of  an I/M program involve both operations
and administration.  Operating personnel  are  those directly involved  in
                                     5-78

-------
         performing inspections or providing managerial functions at the  inspection
         site.  Administrative personnel are involved in operating  support programs
         such as ancillary programs and quality control, or in providing  overall  program
         management and administration.  The personnel requirements for Option  17 are
         shown in Table 5-59.

              Referee stations are necessary when any of the following functions  are to
         be performed:

              •    Investigate consumer complaint cases that require detailed study to
^                  establish the validity of the complaint.   (The referee station can
                   perform either a detailed or gross diagnostic evaluation.  The
                   complaint can be resolved from the resulting data.)

f             •    Develop improved testing practices, improved quality control prac-
                   tices, and correlation studies with relation to  the Federal  Test
                   Procedures  (FTP).

9             •    Provide additional testing capacity for  short-term overflow of  demand.

              •    Develop diagnostic  routines to establish repair  effectiveness
                   during retesting.
•
              The regional office requirements and  referee stations for Option  17 are
         shown in Table 5-60.  Regional offices are located in designated test  facilities
         in which the regional manager and secretary are located.

         5.8.2     INITIAL IMPLEMENTATION AND CAPITAL COSTS  (ONE-TIME COSTS)

              The implementation costs, construction costs, and the other capital costs
         for Option 17 are presented in Tables 5-61, 5-62, and 5-63, respectively.

         5.8.3     OPERATIONS COST  (ON-GOING COSTS)
 »
              The operating costs for  both the inspection  facilities and  ancillary
         programs are presented in Tables 5-64 and  5-65 for the years 1983 through and
         including 1987.
 ¥
                                               5-79

-------
                                Table 5-59.
                          PERSONNEL REQUIREMENTS
                  OPTION 17:  STATE-OPERATED, EPDI TEST
                     State       Inspection   Quality   Ancillary
                 Administrative   Facility    Control    Program
 Classification    Personnel     personnel   Personnel  Personnel  Total
Program manager        1                                             1

Quality control        1                                             1

Manager                1                                             1

Environmental
 engineer              3                         69

Statistical
 analyst               2                                    13

Regional
 manager                              60                            60

Facility
 manager                             726                           726

Technician                         3,312        32               3,344

Secretary/clerk        7             786         6          3      802

Field
 investigator         	           	        	          _3_    	-L

   TOTAL              15           4,884        44          7    4,950
                                   5-80

-------
                 Table  5-60.   REGIONAL  STATION REQUIREMENTS
                   OPTION  17:   STATE-OPERATED,  EPDI  TEST
             Referee   Regional
 LOCATION    Stations    Offices
COUNTY SERVED
Kalanvazoo -
Benton Harbor
Marshall
Grand Rapids 1
Muskegon
Lansing 1
Ann Arbor 1
Jackson
Saginaw
Bay City
Flint 1
Mt. Clemens
Monroe
Detroit 1
Pontiac 1
Total 6
2
2
2
4
2
4
2
2
2
2
4
6
2
16
8
60
Kalamazoo
Allegan
Barry
Berrien
Cass
Van Buren
Calhoun
St. Joseph
Branch
Hillsdale
Kent
Montcalm
Ionia
Muskegon
Ottawa
Ingham
Clinton
Eaton
Shiawassee
Livingston
Washtenaw
Jackson
Lenawee
Saginaw
Gratiot
Bay
Tuscola
Huron
Sanilac
Midland
Genessee
Lapeer
Macomb
St. Clair
Monroe
Wayne
Oakland

Regional stations utilize office space in designated inspection facilities
for management functions only.
                                   5-81

-------
                    Table 5-61.
           INITIAL IMPLEMENTATION COSTS
OPTION 17:  STATE-OPERATED, ENGINE PARAMETER/DEVICE
           INSPECTION TEST, YEAR - 1982
                  (1978 DOLLARS)
              Cost Elements               Dollars
 1.  Site selection                        295,400

 2.  Bid preparation and evaluation         14,800

 3.  Facilities design

 4.  Training plan development               7,500

 5.  Personnel selection                    43,000

 6.  Document preparation                   10,000

 7.  Administrative support                156,000

 8.  System integration, check-out and
     certification                       1,486,100

 9.  Test scheduling system development     67,000

     TOTAL                               2,079,800
                        5-82

-------
                    Table 5-62.
            CAPITAL COSTS (CONSTRUCTION)
OPTION 17:  STATE-OPERATED,  ENGINE PARAMETER/DEVICE
           INSPECTION TEST,  YEAR - 1982
                  (1978 DOLLARS)
        Cost Elements                Dollars
 1.  Land and site improvement

     Land                           26,307,600
     Site improvement               14,486,400

 2.  Facility construction          26,352,000

 3.  Instrumentation                17,167,200

 4.  Office equipment                1,089,000

 5.  Computer costs

     Hardware                       44,712,000
     Software                          108,OOP

     TOTAL                         130,222,200
                       5-83

-------
                        Table 5-63.
                   CAPITAL COSTS (OTHER)
    OPTION 17:   STATE-OPERATED,  ENGINE PARAMETER/DEVICE
               INSPECTION TEST,  YEAR - 1982
                      (1978 DOLLARS)
               Cost Elements                  Dollars
     1.  Administrative office equipment        12,000

     2.  Quality control equipment
         Mobile units (ten)                     200,700
         Referee stations  (six)              1,272,000
         Correlation cars (two)                 19,400

     3.  Consumer complaint (3 complaint
           inspection cars)                      15,000

         TOTAL                               1,519,100

alncluding land cost of $512,400 and building cost of $524,400
                           5-84

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5.8.4     ANNUALIZED PROGRAM COSTS

     The annualized program costs shown in Table 5-66 include capital recovery
of the cost of implementation, construction, and other capital using an interest
figure of 6 percent per annum.*  The total annualized cost in 1978 dollars is
$116,238,500.

5.8.5     CONSUMER FEES

     The average vehicle owner fee  (in 1978 dollars) for Option 17 for an
average yearly vehicle population of 5,320,000 over 5 years of program opera-
tion is $21.85.

5.8.6     BENEFITS

     The parameter test requires over 12 minutes' time, as opposed to 2 minutes
for an idle test, and therefore vehicle throughput rate is decreased dramat-
ically.  Because more stations would be needed to accommodate the vehicle
population, significantly higher capital and operating costs and inspection
fees characterize this option.  The major benefit of this method of testing is
that it is the test most likely to pinpoint the reason for emissions failure
of a vehicle.  This capability will be enhanced for vehicles with on-board
diagnostic components that will actually be able to "tell" a knowledgeable
mechanic what is wrong with the vehicle's operation  or performance.  This
technology is expected to be standard equipment by 1983.
                                    5-87

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-------
5.9       LIGHT-DUTY TRUCKS
     The previous option analyses did not consider inpsection of light-duty
trucks (LDT )  less than 6,001 pounds gross vehicle weight.  In 1983 there would
be 756,264 LDT's and 4,967,970 passenger vehicles for a total of 5,724,234
light-duty vehicles.  This would increase the number of vehicles to be tested
in the nonattainment areas by over 15 percent.
    Extrapolating the average passenger vehicle population from 1983 to 1987,
assuming a 2.8 percent per year vehicle growth, yields 5,320,000 vehicles.
With the inclusion of similarly extrapolated LDT ,  the average number of
vehicles inspected would increase to 6,129,852.

    Table 5-67 presents comparisons for each of the seven base options for
light-duty vehicles with and without LDT 's.  As shown, consumer fees decrease
by 2 cents maximum and in two cases remain the same.   The analysis was based
upon recalculating the capital and annual operating costs.  Where cost elements
are affected by increasing the number of inspections, a 15.223 percent factor
was applied.  If a cost element was insensitive to additional vehicles in the
program, cost by program option remained the same as  for the original computation.
The cost element sensitivity is similar to that of geographic area of coverage,
presented in Section 6.
                                      5-89

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-------
                                          Section 6
                              COMPARATIVE ANALYSES OF I/M OPTIONS
             •This section presents a comparison of the 24 major I/M program options
*       and identifies the interrelated sensitivities of options.  Sensitivity analysis
        was performed on all major cost related variables.  The sensitivity analysis pro-
        vides information with respect  to  the  effect of including or excluding various
        program considerations.  The  major variables used in the sensitivity analysis are:
•
              •    Three test modes:   idle, loaded, and engine parameter/device inspec-
                   tion (EPDI)
ft
              •    Six geographic areas:   nonattainment area, Statewide, Detroit,  Grand
                   Rapids,  Flint, and Lansing.

£             •    Number of lanes:  one  to six

              •    Stringency factor - 10 to 50 percent.

^             •    Administrative methods:  centralized (State or  contractor),  decen-
                   tralized (private garages) , and statistical sample.

              •    Statistical sample size variation:  5 to 25 percent.
»
              •    Vehicle  type:   LDV,  LDT , HDG, HDD, motorcycles

              In addition,  there  are  numerous  minor variations which may affect  the
        cost  and operation of an I/M program.  These relate to equipment selection,
        personnel efficiency, land cost variation, etc.  Such variations were not
        analyzed as they are beyond the scope of this study.
                                             6-1

-------
6-1       COST COMPARISON OF 24 MAJOR I/M PROGRAM OPTIONS

     In Section 5, seven of the 24 options were analyzed in detail.  The
remaining 17 options are analyzed in this section in  terms of  their  initial
implementation and capital costs, average annual operating costs,  and  ancillary
program operating costs.  Furthermore, 5-year total program costs  and  consumer
fees are estimated.

     By using the given seven options as bases, the cost methodology of
estimating the remaining 17 options is defined as follows.  First, the appro-
priate cost ratio is found among base options, defined by administrative
option, method of test, and the associated program  (safety and noise inspec-
tion) .  Second, the cost ratio is applied to the candidate option  by multiplying
it by the cost of the given base within the same option group.   For  example,
in order to estimate cost of Option 11, determine the cost ratio between
Options 9 and 1.  Then, this factor will be multiplied by the  cost of  Option 3.
(See Table 5-1.)

     In addition to three direct cost categories, the 5-year total program
costs of the 17 options include appropriate G/A, overhead, and profit  as
assumed in Section 3.  However, interest incurred by  initial implementation
and capital costs is neglected for ease of  computation and lack of  detailed
information on land value,  building costs,  etc.  Consumer fee,  as usual, is the
average fee per vehicle based on the annualized program costs.   Results are pie-
sented in Table 6-1.

     Among the 24 options,  those which are  either  state-operated or contractor-
operated have automated inspection systems.   Options with either private garage
operation or statistical sampling have manual inspection systems.  They are
considered as normal configurations.  Consumer fee ranges from  approximately
$5 to $44 among options.  Options with engine parameter/device  inspection  are
considered to be "expensive," since the inspection time  is approximately 10
times that of the other two test methods.
                                       6-2

-------
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     The State's share of program cost when the State does not perform the
inspections, $1.01 to $1.16 per vehicle per year, exhibits- little change among
options.  Major State costs in this case are for program planning, administration,
and quality control.  These cost items do not vary significantly from one program
option to another.

6.2      TEST MODE SENSITIVITY

     The test mode sensitivity is obtained by comparing Options 1, 9, and 17,
which vary only with respect to the test mode.  The major cost variations are
those which are sensitive to output rate Csuch as numbers of stations, operating
personnel, quality control personnel, and equipment).  No ratio table is pre-
sented here because a detailed cost analysis of these three options was per-
formed in Section 5.  Refer to tables under each of the option discussions to
determine which cost parameters are most sensitive to test mode.

6.3      AREA COVERAGE SENSITIVITY

     The area coverage sensitivity is presented in Table 6-2.   The variations
are caused by the number of vehicles tested.  In addition, the construction
requirements would be impacted because of the need to provide  facilities con-
venient to the user.  This may require the construction of single-lane facilities
in lieu of double-lane or larger facilities.  In most cases, the sensitivity
factors are obtained by:

                          Number of vehicles in area of coverage
                         Number of vehicles in nonattainment area

     The variations in Table 6-2 are referenced to the 38-county nonattainment
area of the State as a base.  Where a cost does not vary from  one area to
another area the corresponding cost sensitivity factor would be one.
                                      6-9

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6.4       FACILITY COST SENSTIVITY

     Facility cost multipliers, as they relate to the number of lanes per
facility, are presented in Table 6-3. The major variations are those costs
that are sensitive to station size.  Increasing the number of lanes in a
station will result in increased parking space demand, queueing hold area, and
testing area.

     The relative cost factors shown in Table 6-3 are compared to a double-
lane facility.  For those cases where the factors are not proportional to the
double-lane configuration, a first order estimation was made based upon SCI's
engineering judgement and data related to I/M program experiences.

     Ancillary program operating costs are related to vehicle population.
These costs remain unchanged with respect to the number of lanes per inspection
facility.
6.5       STRINGENCY FACTOR SENSITIVITY - 10 TO 50 PERCENT

     The stringency factor sensitivity is presented in Table  6-4.  The major
costs are for construction and operation.  The  construction and operating
costs would be affected in accordance with the increase or decrease  in testing
vehicles.  The sensitivity factors are normalized around a 30 percent stringency
factor, and the stringency factor selected is usually less than  50 percent.   A
1972 EPA study showed that the aggregate emission reduction benefit  is reduced
above that level, as shown in Figure 6-1.  Data from existing I/M studies
indicate that repairs made to marginal failures result in improper adjustment
and increased emissions.
                                    6-12

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Source:  U.S. EPA  "Control  Strategies for In-Ose Vehicle,"November  1972.
                                     6-17

-------
6.6       ADMINISTRATIVE OPTION SENSITIVITY

     The administrative option sensitivities can be  developed by comparing
Options 1, 3, 5, and 7 in Section 5.  The major  cost variations in the admini-
strative options are those that relate  to the  test station,  overhead,  general
and administrative costs, and profit.   No table  has  been developed because
detailed cost summaries for these options were  presented in Section 5.
     The contractor-operated test station would result in reduced State opera-
ting, construction, and implementation costs.   The  consumer protection  and
quality control costs would not change.   Another item to consider is property
tax.  The contractor would pay an annual property tax varying from approximately
$1,500 per 2-lane facility.
     The private garage option operating costs  are  less because of the  higher
State salary rate and benefits as compared to the lower rates of private
garage personnel and the lower overhead costs.   However, the private garage has
longer throughput times.  The major cost reduction  is the elimination of con-
struction cost because existing stations are utilized.  Offsetting this reduction
is the increase in total equipment costs to outfit  the larger number of partici-
pating stations.

6.7       STATISTICAL SAMPLE SIZE VARIATION SENSITIVITY

     The statistical sample size sensitivity is directly related to the size of
the sample, except in the State administrative  activity.  For this activity,
fixed cost consists of 75 percent of the base.    All  other costs increase in
direct proportion to an increase in the size of the sample.

6.8       VEHICLE TYPE SENSITIVITY

     Light-duty passenger vehicle was chosen as the vehicle type in the base
analysis.  To include other vehicle types, cost sensitivity can be determined by
examining per-vehicle inspection time and the population of each vehicle type.
                                      6-18

-------
     Table 6-5 presents normalized factors  for other vehicle  types with respect
to passenger LDV.   The factors are on a vehicle unit basis.   Thus, to  obtain
total cost for each cost category, multiply the normalized  factor by the cost
of passenger LDV and the ratio of vehicle population.   This relationship is
expressed as:

Where
          i
          b
          j
          C. .
          NF. =
            1
          VP. =
            1
          VP,  =
vehicle type
base type  (=LDV)
cost item
cost item j of vehicle type i
cost item j of base vehicle type
normalized factor of cost item  j
population of vehicle type i
population of base vehicle type.
                                    6-19

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                                                                          6-21

-------
                              Section 7

             ISSUE IDENTIFICATION AND OPTION ELIMINATION
     The purpose of this section is to describe the factors that were
considered in arriving at a preferred option.  Costs, benefits, and
disbenefits of the base options were evaluated and discussed in
Section S.  Only overriding considerations are presented in subsequent
paragraphs in order to eliminate programs and narrow the field down
to a preferred option.  Table 7-1 lists the options that have been
evaluated.  In addition to the evaluation; input from the following
sources were considered:
     • The Air Quality Review Committee and its Technical Subcommittee
     • The Vehicle I/M Advisory Committee
     • The Legislative Liaison Committee
     • The Inter-Agency Vehicle I/M Technical Committee
     • A Public Opinion Poll conducted by the Highway Safety
       Research Institute in Ann Arbor, Michigan
     • The United States EPA
     • Comments at the Michigan State Implementation Plan public
       hearings

7.1  SAFETY AND NOISE INSPECTIONS
     Safety and noise inspection costs and benefits were presented in
Section 5.  The following overriding considerations have eliminated this
combined air quality/safety/noise testing approach:
     • Mandatory safety and/or noise inspection programs are not
       currently operating in Michigan (Volume II,  Section 5.3
       p. 5-21) .  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 (Volume
       II, Table 5-20, p.  5-30).  The Michigan Legislature must de-
       cide 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.
                                 7-1

-------
     Table 7-1.  ADMINISTRATIVE APPROACH VERSUS METHOD OF TEST
Administrative Approach

S tate-operated

 Without safety and
  noise
 With safety and noise
                                       Method of Test
  Idle
Loaded
Engine Parameter/
Device Inspection
Option 1*  Option  9*
Option 2*  Option 10
               Option 17*
               Option 18
Contractor-operated

 Without safety and
  noise
 With safety and noise
Option 3*  Option 11
Option 4   Option 12
               Option 19
               Option 20
Private garage

 Without safety and
  noise
 With safety and noise
Option 5*  Option 13
Option 6   Option 14
               Option 21
               Option 22
Statistical sampling

 Without safety and
  noise
 With safety and noise
Option 7*  Option 15
Option 8   Option 16
               Option 23
               Option 24
 *Base options
                                 7-2

-------
     • 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 (Volume II, Table
       6-1, p. 6-3)
     • Experience from other safety and emissions testing programs
       indicates that a high percentage of the tested vehicles
       fail the combined test.  Costs for retesting failed vehicles
       will increase accordingly (Volume I, Section 2, p. 5)
     • 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
     • 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
7.2  STATISTICAL SAMPLE

     The statistical sample administrative approach requires the

inspection of a small portion of the vehicle population.  The costs,

benefits and disbenefits of this option were described in Section 5.

The following overriding considerations have eliminated this testing

approach:

     • 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 (Volume II, Section 1, p. 1-2)

     • Other control strategies either from stationary sources or
       from other transportation control strategies will be re-
       quired to offset the shortfall in emission reductions
       obtained through this program
                                  7-3

-------
     • This approach is not acceptable to the federal EPA, since
       it does not fulfill the Clean Air Act Amendment requirement
       for I/M to be "mandatory and periodic." (Volume I, Appendix A)

7.3  STATE OPERATED SYSTEM

     The State operated administrative approach's costs, benefits,
and disbenefits were discussed in Section 5.  The following overriding
considerations have eliminated this administrative approach:

     • The initial costs to the State to implement the program are
       high (Volume II, Table 6-1, p. 6-3)
     • There is uncertainty in obtaining required funds to imple-
       ment the program
     • Governmental employment will be greatly expanded as com-
       pared to other private sector administrative approaches
       (Volume II, Table 5-4, p. 5-10)
     • 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
7.4  PRIVATE GARAGE SYSTEM

     The costs, benefits and disbenefits of this option were discussed

in Section 5.  The following overriding considerations have eliminated

this administrative approach:

     • There is reluctance by the private sector and consumers to
       have private garages perform bath the inspection and repair
       due to a potential and/or perceived conflict of interest

     • A high turnover rate  (10%/yr) 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
                                  7-4

-------
     • 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 (Volume II,
       Table 5-37, p. 5-52)

     • More resources must be devoted to private garage licensing,
       quality control and complaint investigation than for the
       other administrative approaches (Volume II, Section 5.5.6,
       p. 5-58)

     • So far, all of the states with private garage run I/M
       programs 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
       (Volume I, Section 2.2, p. 7)

     • 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 work-
       load and its effect on program costs and consumer costs are
       not possible to predict at this time
7.5  LOADED-MODE TEST

     The loaded-mode test costs, benefits, and disbenefits were dis-

cussed in Section 5.  Based on information to date, the loaded-mode

test has been eliminated.  If additional monitoring data indicates

an NO  problem, or if other pertinent technical information suggests
     X
that a loaded test is needed, this decision will be reconsidered.

The following statements indicate the reasons for eliminating a

loaded-mode test:

     • The loaded-mode test provides substantial diagnostic infor-
       mation.  The benefit of the additional information is de-
       pendent 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
       (Volume II, Section 5.7.6, p. 5-76)
                                 7-5

-------
     • A loaded-mode test does not increase the amount of emission
       reductions obtained by the program (Volume I,  Appendix A)
     • The repair industry may find it expensive and  impractical
       to buy a dynamometer to duplicate loaded-mode  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  dissatis-
       faction
     • A loaded-mode test costs 18% more than an idle-mode test
       (Volume II, Table 6-1, p. 6-3)

     • If heavy duty vehicles are included in a loaded-mode test I/M
       program, special  double axle dynamometers will be necessary.
       This substantially increases program costs (Volume II,
       Section 2.1, p. 2-1)
7.6  ENGINE PARAMETER/DEVICE INSPECTION

     The parameter inspections identified in this study are time inten-

sive and costly, but other device inspections may prove to be more cost

effective.  Although this is not a preferred option;  this option has

not been eliminated completely.

     The following issues must be considered:

     • The parameter inspection defined in this report is approxi-
       mately four times as expensive as an idle test (Volume II,
       Table 6-1, p. 6-3)

     • Very little information is available pertaining to the test
       time (and subsequently output rate at inspection stations)
       involved in parameter testing (Volume II, Section 3.2.3,
       p. 3-6)
     • I/M facilities for another test mode may be designed to
       include 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 (Volume I, Appendix A)
                                 7-6

-------
7.7  SELECTION OF CANDIDATE OPTIONS
     With the elimination of safety and noise inspections as dis-
cussed in Section 7.1, Options 1, 3, 5, 7,  9, 11,  13, 15, 17, 19,
21, and 23 remain as shown in Table 7-1.  The reasons to eliminate
these options are still valid regardless of the test mode.
     Options 7, 15, and 23 are eliminated by removing the statistical
sampling as an administrative approach.  Again, the overriding con-
siderations are independent of the test mode.
     Options 3, 5, 11, 13, 19, and 21 remain candidates after elimina-
tion of the State-operated administrative approach.  Again,  the over-
riding considerations are not a function of the test mode considered.
     Options 3, 11, and 19 remain after elimination of the private
sector as a vaiable administrative approach.  Although the overriding
considerations are applicable to all test modes, the loaded-mode test
is not amenable to the private sector due primarily to the cost of
the test equipment.  After the loaded-mode test is eliminated, Options
3 and 19 remain under the contractor administrative approach.
     As stated in Section 7.6, the engine parameter inspection is not
an immediate candidate.  Option 3, the contractor-operated idle test,
is the selected viable candidate.

7.8  CONCLUSIONS
     The contractor operated-idle mode test (Option 3)  is the pre-
ferred option.  Although the state run program option has been elimina-
ted, it will be necessary to continue a dual costing of state and con-
tractor run programs for comparative purposes.  This will provide the
state with the ability to evaluate contractor bids against the cost
for the state to run the program.  If the state is unable ot obtain
reasonable bids, it would then be possible for the state to  pick up
the program.
                                  7-7

-------
     While parameter testing is not a preferred approach, this option
will remain under consideration.  Other states have undertaken vehicle
testing programs to learn more about parameter testing.  It is possi-
ble that the results of these programs will define a cost effective
parameter test suitable for application in Michigan.
     The Michigan Department of Transportation may also wish to con-
sider combinations of options.  For example, a centralized idle test
with reinspection and repair in private garages may be a viable
approach.  Phase II will provide the opportunity to look into this
and other combinations.  In addition, further analysis is necessary
to provide answers to the following questions:
     • Should heavy duty gas and diesel vehicles be included
       in the program?
     • What emission cut point should be used to obtain a given
       failure rate?
     • How many lanes should there be at each facility?  How
       should facility locations be chosen?
     • Should a maximum repair cost be set, and if-"yes", how
       should it be set?
     • Should centralized and decentralized facilities be used
       in a combination of urban and rural areas?
     • How can mobile inspection stations be used in rural areas?
     • Can simple energy saving checks be made at an I/M station?
     • Can energy benefits of I/M be more accurately quantified?
       If "yes", can I/M be used as a cost effective energy saving
       strategy?
These and other questions will be answered in Phase II.
                                 7-8

-------
                                   Section 8
                              GENERAL DEFINITIONS
     These definitions are commonly used in inspection and emissions testing
procedures and I/M programs.

accuracy:  The degree by which an instrument is able to determine the true
     concentration of a pollutant in the exhaust gas sampled.

air contaminants:  Any fumes, smoke, particulate matter, vapor gas, or any
     combination, but excluding water vapor or steam condensate.

air-fuel ratio:  The expression of the proportional mixture by weight of air
     to gasoline created by the carburetor.  Usually expressed as a numerical
     relationship such as 14:1, 13:1, etc.

ambient air:  The surrounding or outside air.

analyzer:  An instrument which samples and determines the concentration of a
     particular gas of interest.

calibration gases:  A blend of hydrocarbon and carbon monoxide gases at known
     concentrations using nitrogen as the inert carrier gas.

carbon monoxide:  A nonirritating, colorless, odorless, but nonetheless toxic
     gas which has the molecular form of CO.

catalytic converter:  Device to reduce automobile emissions by converting CO
     and HC emissions to harmless carbon dioxide and water.
                                    8-1

-------
certificate of compliance:  A document which is issued upon completion of
     inspection which records the results and serves as proof for vehicle
     owner.

certified mechanic:  An individual certified by the State or I/M program
     office, to install, repair and adjust motor vehicle engine emissions-
     related components and pollution control devices so that the motor vehicle
     meets emissions standards.

certified station:  A private facility certified by the State or I/M program
     office, to install, repair and adjust motor vehicle engine emissions-
     related components and pollution control devices so that the vehicle meets
     applicable emissions standards.

chassis dynamometer:  A test instrument equipped with two parallel rollers that
     support the rear wheels of a motor vehicle.  When positioned on the
     dynamometer the vehicle may be "driven" to simulate the road operation.
     A power absorption unit is connected to the rollers to simulate the
     loading from the various sources of fluid and mechanical friction present
     during road operation.  Weights can also be coupled to the rollers to
     simulate the inertial effects of vehicle mass during acceleration and
     deceleration.

crankcase emissions:  The products of combustion emitted into the ambient air
     from the engine crankcase ventilation system.

cut point:  A threshold value of measured tail pipe pollutant emission concen-
     tration above which a vehicle will fail an emissions inspection.

degradation:  An increase in emissions due to normal wear of engine system.

deterioration:  A synonym for degradation indicating an increase in emission
     levels due to wear.
                                      8-2

-------
drift:  The amount of analyzer meter reading change over a period of time.
     Zero drift refers to change of zero reading when a zero gas is flowing
     through the analyzer.  Span drift refers to a change in reading of an
     analyzer meter when a calibration gas of known concentration is flowing
     through the analyzer.

emission inspection program:  An inspection and maintenance program in which
     each vehicle is subjected to a test of its emissions under specified
     conditions.  The emission levels are compared with a standard established
     for the vehicle class.  If the emissions are higher than the standard, the
     vehicle fails and must be adjusted or repaired to bring its emissions to
     within the standards.

engine family:  The basic classification unit of a manufacturer's product line
     used for the purpose of test-fleet selection.

engine-system combination:  Both an engine family-exhaust emission control
     system and a fuel evaporative emission control system.

exhaust emissions:  The gases emitted into the ambient air from any opening
     downstream of the exhaust ports of an engine.

exhaust gas analyzers:  Instruments that can determine the amounts of one or
     more gas(es) in the exhaust of a motor vehicle.

failure rate:  The percentage of vehicles tested that fails inspection.

fleet operator:  The owner of a fleet of a designated number of vehicles.

fleet owner authorized stations:  Stations operated by a fleet owner under
     certified authority to perform vehicle emissions inspection and limited to
     his fleet only.

fuel system:  Combination of fuel tank, feeder lines, fuel pump, and evaporative
     emissions control system.
                                      8-3

-------
gross vehicle weight:  The manufacturer's gross weight rating for the individual
     vehicle.

hang-up:  HC which clings to the surface of the sampling and analyzer system in
     contract with the gas sample stream which causes an erroneous indication
     of HC in the measured value.

heavy-duty vehicle:  Any motor vehicle designed for highway use having a gross
     vehicle weight of more than 8,500 pounds.

hydrocarbons:  An organic compound whose molecular composition consists of
     atoms of hydrogen and carbon only.  Gasoline is composed of various
     hydrocarbons.

idle test:  An emission inspection program which measures the exhaust emission
     from a motor vehicle operating at idle.   (No motion of the rear wheels.)
     A vehicle with an automatic transmission may be in "drive" with brakes
     applied or in neutral gear.

independent contractor:  Any person, business  firm, partnership, or corporation
     with whom the State may enter into an agreement providing for the con-
     struction, equipment, maintenance, personnel, management and/or operation
     of official inspection stations.

inspection and maintenance program:  A program to reduce emissions from in-use
     vehicles through identifying vehicles that need emissions control-related
     maintenance and requiring that maintenance be performed.  Abbreviated as
     I/M program.

inspection station:  A facility used for inspecting or testing motor vehicles
     and pollution control devices for compliance with applicable regulations.

inspector:  An individual who inspects motor vehicles and pollution control
     devices for compliance with applicable regulations.
                                     8-4

-------
light-duty vehicle:  A motor vehicle designed for highway use and less than
     6,001 pounds gross vehicle weight.  Further distinctions are sometimes
     made between light-duty automobiles and light-duty trucks such as pickup
     trucks.

loaded mode test:  An emission inspection program which measures the exhaust
     emissions from a motor vehicle operating under simulated road load on a
     chassis dynamometer.

medium-duty vehicle:  A motor vehicle designed for highway use with a gross
     vehicle weight between 6,000 and 8,500 pounds.

model-year of vehicle:  The production period of new vehicle designated by the
     calendar year in which such period ends.

motor vehicle:  Any self-propelled vehicle which is designed primarily for
     travel on public right-of-way streets and is used to transport persons
     and/or property.

output rate:  The number of vehicles that can be processed at a test lane per
     unit time.  The longest work station test time defines the output rate.

oxides of nitrogen:  Any molecule containing nitrogen and oxygen only.  For air
     pollution purposes, only nitric oxide (NO) and nitrogen dioxide  (NO.).

pollution control device:  Equipment designed for installation on a motor
     vehicle to reduce pollutants emitted from the vehicle, or an engine
     modification resulting in pollutant reduction.

positive crankcase ventilation:  A system designed to return blowby gases  from
     the crankcase of the engine to the intake manifold to burn them in the
     engine.  Blowby gas is unburned fuel/air mixture that leaks past the
     piston rings into the crankcase during the compression and ignition cycles
     of the engine.  Without positive crankcase ventilation, these gases which
     are rich in hydrocarbons escape to the atmosphere.
                                    8-5

-------
prescribed inspection procedure:  Approved procedure for identifying vehicles
     that need emissions control-related maintenance.

quality:  The results of engineering and manufacturing that determine the
     degree to which the product meets design specifications.

registered owner:  An individual, firm, corporation, or association whose name
     appears in the files of the Department of State as the owner of the vehicle.

repeatability:  The instrument's capability to provide the same value for
     successive measures of the same sample.

response time:  The period of time required by an instrument to provide a read-
     out after a step-change in gas concentration level initiated at the tail
     pipe sample probe.

smoke:  Small gasborne and airborne particles, exclusive of water vapor,
     resulting from insufficient combustion and in sufficient number to be visible.

stringency factor:  A design or theoretical failure  rate.

tampering:  The alteration, modification, or disconnection of emission  control
     devices.

vehicle dealer:  An individual, firm,  corporation or association who is licensed
     to sell motor vehicles.

vehicle emissions standard:  A  specific emission limit allowed  for  a class  of
     vehicles.  The standard is normally expressed in terms of  maximum  allow-
     able concentrations of pollutants (e.g., parts  per million).   However,  a
     standard could also be expressed  in terms of mass emissions per unit of
     time or distance traveled  (e.g.,  grams per mile).
                                     8-6

-------
                Appendix A
VEHICLE POPULATION DATA BY AREA OF COVERAGE

-------
LIGHT-DOTY VEHICLE POPULATION
         YEAR - 1977

          MOTOR V5HICLS POPULATION
Statewide
COUNTY
Alcana
Algar
Allagan
Alpena
Antrim
Arenac
aaraga
Barry
3ay
3en.zis
aerrien
Branch
Calhoun
Cass
Charievoix
Cheboygan
Chippewa
Clare
Clinton
Crawford
Delta
Dickinson
Eaton
Samet
Genesae
Gladwin
Gogeaic
Gd. Traverse
Gratiot
Hillsdala
Houghton
Huron
Ingham
Ionia
losco
Iron
Isabella
Jackson
Kalamazoo
KalXaska
Kant
Keweenaw
Lake
x 10
4
4
34
15
7
6
3
19
59
5
37
13
72
22
9
9
14
10
24
4
13
12
37
11
226
7
3
23
13
19
14
17
131
21
13
5
13
72
105
4
229
1
3
3
.73
.08
.71
.54
.39
.01
.64
.21
.53
.35
.38
.94
.33
.34
.79
.75
.53
.12
.33
.41
.01
.92
.39
.37
.91
.98
.76
.14
.50
.17
.63
.90
.79
.13
.62
.31
.32
.64
.31
.72
.56
.03
.30
%
0
0
0
0
0
0
0
0
1
0
1
0
1
0
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
2
0
0
0
0
1
2
0
4
0
0

.1
.1
.7
.3
.2
.1
.1
.4
.3
.1
.9
.4
.6
.5
.2
.2
.3
.2
.5
.1
.4
.3
.3
f 2
.9
.2
.2
. 6
.4
.4
.3
.4
.3
, 5
.3
.1
.4
. 6
.3
.1
.9
.3
.1
Nonattain- Grand
inent Countiss Rapids Lansing Flint Detroit
x 103


34.




19.
59.

37.
13.
72.
22.




24.



37.

226.




19.

17.
131.
21.



72.
105.

229.





71




21
53

33
94
33
34




38



39

91




17

90
79
13



64
31

66


%


0




0
T_

2
0
1
0




0



0

5




0

0
3
0



1
2

5


x 10 3 % x 103 % x 103 % x 103 %


.3




.5
.4

.1
.4
. 7
.5




.6 24.38 12.3



.9 37.39 19.3

.4 226.91 100




.5

.4
.1 131.79 67.9
. 5



w 7
. 5

.4 229.56 75.7


                                         (continued)
              A-l

-------
                         LIGHT-DOTY VEHICLE POPULATION
                                        YEAR -  1977
                                                         (Continued)
                                         MOTOR VEHICLE POPULATION
Statewide

COUNT?
Lapeer
Laelanau
Lanawee
Livingston
Luce
Mackinae
Macomb
Manistes
Marque «a
Mason
Mecosta
Menociinae
Midland
Missaukee
Monroe
Montcalai
Montaorsncy
Muskegon
Newaygo
Oakland
Cceana
Ogenaw
Cntonagon
Osceola
Os coda
Otsego
Ottawa
Preseque Isle
Roscoomon
Sagmaw
3t. Clair
St. Joseph
Sanilac
Sciioolcraft
Shiawassee
Tuscola
Van Suren
Wasntenaw
Wayne
Wexford
Foreign

x 10
27
6
42
40
2
4
334
10
31
12
12
12
36
4
62
20
3
77
14
560
9
7
4
3
3
6
73
6
3
114
64
26
13
4
32
24
29
125
1206
3

.77
.43
.63
.16
.35
.42
.50
.96
.39.
.17
.16
.30
.43
.12
.25
.32
.S3
.35
.75
.93
.15
.39
.35
.02
.12
.37
.67
.63
.24
.13
.73
.55
.21
.28
.38
.47
.70
.26
.50
11.69
15
.62
Honattain- Grand
oent Counties Raoids Lansing
3
% X 10 %
0
0
0
0
0
0
a
0
0
0
0
0
0
0
1
0
0
1
0
12
0
0
0
0
0
0
1
0
0
2
1
0
0
0
0
0
0
2
26
0
0
.6
.1
.9
.9
.1
.1
.3
.2
.7
.3
.3
.3
.3
.1
.3
.4
.1
.7
.3
.1
.2
2
.1
.2
.1
.1
.6
.1
.2
.5
.4
.6
.4
.1
.7
.5
.6
.7
.0
.3
.3
27

42
40


334

31



36

62
20

77

560






73


114
64
26
13

32
24
29
125
1206


.77

.63
.16


.50

.39



.43

.25
.32

.95

.98






.67


.13
.73
.55
.21

.33
.47
.70
.26
.50


0

1
1


9

0



0

1
0

1

13






1


2
1
0
0

0
0
0
3
23


3 1
x 10 % x 10 %
.7

.0
.0


.1

.7



.9

.5
.5

.3

.3






.7 73.67 24.3


.7
.5
.6
.4

.3
.6
.7
.0
.6


Flint Detroit
3 3
x 10 % x 10 %






334.50 16.4







62.25 2.7




560.98 24.0

















125.26 5.4
1206.50 51.6


Total
              4647.45  100  4220.30  100  303.33  100  194.06  100  226.91   100   2339.49   100
                                               A-2

-------
PROJECTED UGHT-OaTY VEHICLES POPULATION
               YEAR - 1983

                MOTOR VEHICLE POPULATION
Statewide
COUNTY
Alcana
Algar
Al lagan
Alpena
Antria
Aranac
Baraga
Barry
Bay
Benzie
Barrian
Branch
Calhoun
Cass
Charlavoix
Cheooygan
Chippawa
Clara
Clinton
Crawford
Delta
Dickinson
Eaton
Sauna t
Genesea
Gladwin
Gogabic
Gd. Traversa
Gratiot
Hillsdala
Hough ton
Huron
Ingnam
Ionia
losco
Iron
Isabella
Jackson
Kalamazoo
Kalkaska
Kent
: 1
29
5
21
15
44
13
267
9
10
33
21
22
17
21
155
24
16
3
22
35
123
5
270
i.
3
3
.53
.31
.35
.29
.23
.07
.23
.61
.07
.30
.35
.29
.13
.33
.32
.47
.10
.91
.23
.19
.20
.21
.00
.33
.03
.39
.31
.12
.77
. 56
.22
.07
.12
.93
.03
.01
.15
.50
.95
.56
.31
.27
.33
%
0
0
0
0
0
0
0
0
1
0
1
0
1
0
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
2
0
0
0
0
1
2
0
4
0
0

.1
.1
.7
.3
.2
. J.
.1
.4
.3
.1
.9
.4
.6
.3
.2
.2
.3
.2
.5
.1
.4
.3
.3
.2
.9
.2
.2
. 6
.4
.4
.3
.4
.3
.5
.3
.1
.4
.6
.3
.1
.9
.0
.1
Nonattain- Grand
nent Counties Ranids Lansing flint Detroit
x 10


40




22
70

102
22
35
26




29



44

267



21
22

21
155
24



35
123

270


3


.35




.61
.07

.35
.29
.13
.33




.23



.00

.33



.77
.56

.07
.12
.93



.50
.95

.31


%


0.




0.
1.

2.
0.
1.
0.




0.



0.

3.



0.
0.

0.
3.
0.



1.
2.

5 .


x 103 % x 103 % x 103 % x 103 %


3




5
4

1
4
7
4




5 29.23 12.3



9 44.00 19.3

4 257.03 100



4
3

4
1 155.12 57.9
5



7
5

4 270.31 75.7


                                                (continued)
                    A-3

-------
                   PBOJ5CTED LIGHT-DUTY VEHICLES  POPULATION
                                        TSAR -  1983
(Continued)
                                         MOTOR VEHICLE POPULATION
Statewide

COUNTY
Lapaar
Laalanau
Lenawea
Livingston
Luce
Mackinac
Macomb
Manistee
Marquetta
Mason
Mecosta
Menominea
Midland
Missaukae
Monroe
Montcala
Montaorency
Muskegon
Newaygo
Oakland
Oceana
Ogemaw
Ontonagon
Osceola
Oscoda
Otaego
Ottawa
Preseque Isle
Soscommon
Saginaw
St. Clair
St. Joseph
Sanilac
Schoolcraft
Shiawassee
Tuscola
Van Buren
Washtanaw
Wayne
Wexford
Foreign
3
x 10
32.
7.
30.
47.
3.
5.
452.
12.
36.
14.
14.
14.
42.
4.
73.
24.
4.
91.
17.
660.
10.
a.
5.
9.
3.
3.
36.
7.
9.
134.


63
63
17
26
35
20
55
90
95
33
31
43
93
34
27
51
27
75
36
27
77
S9
71
44
63
09
71
36
70
39
76.25
31.
21.
5 .
38.
25
43
03
11
28.30
34.96
147.43
1420.05
13.76
13.39

%
0
0
0
0
0
0
3
0
0
0
0
0
0
0
1
0
0
1
0
12
0
0
0
0
0
0
1
0
0
2
1
0
0
0
0
0
0
2
26
0
0


.6
.1
.9
.9
.1
.1
.3
.2
.1
.3
.3
.3
.3
.1
.3
.4
.1
.7
.3
.1
.2
.2
.1
.2
.1
.1
.6
.1
.2
.5
.4
.6
.4
.1
.7
.5
.6
.7
.0
.3
.3
Honattain- Grand
ment Counties Rapids Lansing
.
x 10'
3

32.63

50
47


452

36



42

73
24

91

660






36


134
76
31
21

38
23
34
147
1420



.17
.26


.55

.95



.93

.27
.51

.75

.27






.71


.39
.25
.25
.43

.11
.30
.96
.43
.05



%
0

1
1


9

0



0

1
0

1

13






1


2
1
0
0

0
0
0
3
23


3 1
x 10 * x 10 %
.7

.0
.0


.1

.7



.9

.5
.5

.3

.3






.7 36.71 24.3


.7
.5
.6
.4

.3
. 5
.7
.0
.6


Flint Detroit
3 3
x 10 % x 10 %






452. 5S 16.4







73.27 2.7




660.27 24.0

















147.43 5.4
1420.05 51.6


Total
              5470.04  100  4967.97  100  357.02  100  228.40  100  267.08  100  2753.57   100
                                              A-4

-------
PROJECTS) uIGHT-OCTf VEHICLES POPULATION
               YEAR - 1987

                MOTOR VEHICIZ POPUIATION
Statewide
CCCOTY
Alcona
Alger
Allegan
Alp ana
Antrin
Arsnac
Saraga
Barry
Bay
Benzie
Sarrien
Branch
Calhoun
Cass
Charievoix
Cheboygan
Chippewa
Clare
Clinton
Crawford
Delta
Dickinson
Eaton
Emmet
Genasee
Gladwzn
Sogebic
3d. Traverse
Graciot
Hillsdale
Hougnton
Huron
Ingnam
Ionia
losco
Iron
Isabella
Jackson
Kalamazoo
KaJJcaska
Kent
Keweenaw
LaKe
x 10
5
5
46
20
10
a
4
25
30
7
117
25
97
30
13
13
19
13
33
5
24
17
50
15
305
10
11
37
24
25
19
24
177
28
13
9
25
97
141
5
309
1
4
3
.39
.51
.78
.95
.63
.09
.90
.39
.25
.22
.79
.52
.50
.78
.19
.14
.53
.64
.54
.94
.23
.42
.40
.32
.33
.76
.30
.93
.93
.33
.72
.13
. 56
.55
.35
.13
.37
.92
.96
.36
.53
.46
.45
%
0
0
0
0
0
0
0
0
1
0
1
0
1
0
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
2
0
0
0
0
1
2
0
4
0
0

.1
.1
.7
.3
.2
.1
.1
.4
.3
.1
.9
.4
.6
.5
.2
.2
.3
.2
.5
.1
.4
.3
.3
.2
.9
.2
.2
.5
.4
.4
.3
.4
.3
. 5
.3
.1
.4
. 6
.3
.1
.9
.0
.1
Konattain- Grand
merit Counties Raoids Lansina Flint Detroit
x 10


46




25
30

117
25
97
30




33



50

305



24
25

24
177
23



97
141

309


3


.78




.39
.25

.79
.52
.50
.73




.54



.40

.33



.93
.33

.17
. 56
.55



.92
.96

.53


%


0.




0.
1.

2.
0.
1.
0.




0.



0.

5.



0.
0.

0.
3.
0.



1.
2.

5.


x 103 % x 103 * x 103 * x 103 %


3




5
4

1
4
7
5

t


6 33.54 12.3



9 50.40 19.3

4 305.33 100



4
5

4
1 177.66 67.9
5



7
5

4 309.53 75.7


                                                 i continued)
                     A-5

-------
                   PROJECTED LIGHT-DOTY VEHICLES POPULATION
                                        YEAR -  1987
(Continued)
                                         MOTOR VEHICLE  POPULATION
Statewide
COUNTY
Lapeer
Leelanau
Lenawee
Livingston
Lues
Mackinac
Maconb
Manistee
Marque tte
Mason
Mecosta
Manominaa
Midland
Misaaukee
Monroe
Montcalm
Montaiorancy
Huskegon
tfewaygo
Oakland
Oceana
Ogeoaw
Ontonagon
Osceola
Oscoda
Otsego
Ottawa
Preseque Isle
Roseoramon
Saginaw
St. Clair
St. Joseph
Sanilac
Schooler aft
Shiawassee
Tuscola
Van Suren
Waahtenaw
Wayne
Wexford
Foreign
x 103
37.
3.
57.
54.
3.
5.
518.
14.
42.
15.
16.
16.
49.
5.
83.
23.
4.
105.
19.
756.
12.
9.
6.
10.
4.
9.
99.
9.
11.
153.
37.

43
74
46
13
34
95
30
77
31
41
39
53
17
55
92
07
39
08
39
20
34
96
54
31
21
26
30
00
11
91
33
35.79
24.
54
5.76
43.
64
32.99
40.04
168.85
1626.37
15.76
21.06
%
0
0
0
0
0
0
3
0
0
0
0
0
0
0
1
0
0
1
0
12
0
0
0
0
0
0
1
0
0
2
1
0
0
0
0
0
0
2
26
0
0

.6
.1
.9
.9
.1
.1
.3
.2
.7
.3
.3
.3
.3
.1
.3
.4
.1
.7
.3
.1
.2
.2
.1
.2
.1
.1
.6
.1
.2
.5
.4
. 6
.4
.1
.7
.5
.6
.7
.0
.3
.3
Nonattain- Grand
ment Countiea Rapids Lansing Flint Detroit
xlO3
37.

57.
54.


513.

42.



49.

33.
28.

105.

756.






99.


153.
37.
35.
24.

43.
32.

43

46
13


30

31



17

92
07

08

20






30


91
33
79
54

64
99
40.04
163.
1626.


35
37


%
0

1
1


9

0



0

1
0

1

13






1


2
1
0
0

0
0
0
3
23


x 103 * x 103 % x 103
.7

.0
.0


.1

.7



.9

.5
.5

.3

.3






.7 99.30 24.3


.7
.5
.6
.4

.3
.6
.7
.0
.6


% x 10 3 %






518.30 16.4







33.92 2.7




755.20 24.0

















168.35 5.4
1626.37 51.6


Total
              6264.76  100  3639.76  100  408.38  100  261.60  100  305.38  100  3153.64  100
                                              A-6

-------
LIGHT-OUT: TRUCX POPULATION
         TEAR - 1977

          MOTOR VEHICLE POPULATION
COUNTY
Alcona
Alger
Allegan
Alpena
Antrim
Aranac
Baraga
Barry
Bay
3enzie
Semen
Branch
Calhoun
Cass
Charlavoix
Cheboygan
Chippewa
Clare
Clinton
Crawford
Delta
Dickinson
Eaton
Sonet
Genes ee
Gladwm
Gogebic
Gd . Traverse
Gratiot
Hilisdale
Hougnton
Huron
Ingham
Ionia
losco
Iron
Isabella
Jackson
•Calamazoo
Kalkaska
Kent
Keweenaw
Lake
Statewide
1,
1,
10,
4,
2,
1,
1,
6,
11,
1,
19,
5,
14,
7,
2,
2,
4,
3,
7,
1,
5,
3,
9,
3,
40,
2,
2,
6,
5,
5,
3,
S,
19,
6,
3,
2,
5,
15,
18,
1,
32,

1,
501
S13
360
607
177
976
396
08 S
097
553
099
731
335
061
764
971
240
293
433
296
343
322
160
065
239
757
756
833
467
973
774
192
361
142
462
433
003
300
295
340
495
301
073
%
.20
.20
1.36
.60
.29
.26
.13
.30
1.46
.20
2.51
.76
1.39
.93
.36
.39
.56
.43
.98
.17
.70
.44
1.20
.40
5.23
.36
.36
.37
.72
.7a
.50
.63
2.54
.31
.45
.32
.66
2.01
2.40
.24
4.27
.04
.14
Sonattain- Grand
sent Counties Hanids Lansing Plint Detroit


10




6
11

19
5
14
7




7



9

40



5
<•>

S
19
6



15
13

32




,360




,085
,097

,099
,731
,385
,061




,433



,150

,239



,467
,973

,192
,361
,142



,300
,295

,495




1.




.
^ .

2.
.
2.
1.




1.



1.

6 .



.



3.




2.
2.

5.


% % % % %

61




95
73

97
90
24
10




17 7,488 20-79



45 9,160 25.44

26 40,239 100



35
93

31
01 19,361 53.77
96



33
35

06 32,495 70.20


                                          (continued)
               A-7

-------
                          LIGHT-DOTY TRUCK POPULATION
                                       YEAR -  1977
                                        (Continued)
                                         MOTOR VEHICLE ?Qg'JIATION
COUNTY

Lapeer
Laelanau
Lanawee
Livingston
Lues
Mackinac
Macomb
Mania tee
Marquetta
Mason
Macosta
Menominee
Midland
Missaukee
Monroe
Monte als
Montnorency
Muskegon
Newaygo
Oakland
Oceana
Ogemaw
Ontonagon
Oscsola
Oscoda
Otsego
Ottawa
Preseque Isle
?j3Scocnmon
Saginaw
St. Glair
St. Joseph
Sanilac
Schoolcraft
Shiawassee
Tuscola
Van 3uren
Washtenaw
Wayne
Wexford
Foreign
Statewide

3
1
11
9
1
1
41
2
a
3
3
3
6
1
13
6
1
14
4
67
3
2
1
2
1
2
13
2
2
19
12
7
5
1
3
7
3
IS
112
3


,176
,809
,012
,721
,114
,517
,654
,790
,346
,388
,704
,412
,977
,374
,455
,564
,341
,794
,752
,077
,193
,491
,719
,330
,145
,116
,793
,320
,414
,051
,370
,529
,631
,403
,967
,772
,965
,421
,214
,101


1

1
1


5

1





1


1

3






1


2
1



1
1
1
2
14


ttonattam- Grand
Bent Counties Rapids Lansing Flint Detroit
%
.1
.24
.45
.23
.15
.20
.47
.37
.16
.44
.49
.45
.92
.22
.77
.36
.13
.94
.62
.30
.42
.33
.23
.33
.15
.23
.31
.30
.32
.50
.69
.99
.75
.13
.13
.02
.13
.42
.73
.41
—

3

11
9


41

3



6

13
6

14

67






13


19
12
7
5

3
7
3
13
112



,176

,012
,721


,654

,346



,977

,455
,564

,794

,077






,793


,051
,370
,529
,681

,967
,772
,965
,421
,214



1.

1.
1.


6.

1.



1.

2.
1.

2.

10.






2.


2.
2.
1.


1.
1.
% % * t »
27

71
51


43 41,654 16. 4(

33



09

09 13,455 5.3:
02

30 '

44 67,077 26.5






14 13,793 29.30


97
00
17
38

40
21
1.40
2.37 13,421 7.2
17.


46 112,214 44.3


Total
761,311  100  642,524  100  46,233  100  36,009  100  40,239  100  252,321  100
                                           A-8

-------
.MEDIDM-OOTY TRUCK POPULATION
          YEAR - 1977

           MOTOR VEHICLE POPOIATION
Nonattain- Grand
COUNTY
Alcona.
Alger
Allegan
Alpena
Antrim
Aranac
Saraga
Barry
Bay
Benzie
Bar nan
Branch
Calhoun
Cass
Charlevoix
Chaboygan
Chippewa
Clare
Clinton
Crawford
delta
Dickinson
Eaton
Emmet
Ganesee
Gladvui
Gogebic
Gd. Traversa
Gratiot
Hillsdala
Houghton
Huron
Ingham
Ionia
IOSCO
iron
Isabella
Jackson
Xalamazoo
Kalkaska
Kant
Keweenaw
I«ika
Statewide ment Counties Raoids Lansing Flint Detroit
29
27
344
90
63
104
17
172
391
49
734
200
422
247
43
79
109
67
223
17
94
91
236
99
729
52
45
201
230
259
71
547
1,063
205
66
35
176
415
447
60
1,139
3
25
.12
.11
1.40
.37
.26
.42
.07
.70
1.59
.20
2.98
.31
1.71
1.00
.19
.32
.44
.27
.93
.07
.38
.37
1.16
.40
2.96
.21
.13
.32
.93
1.05
.29
2.22
4.32
.33
.27
.14
.71
1.S9
1.32
.24
4.63
.01
.10


344




172
391

734
200
422
247




223



236

729



230
259

547
1,063
205



415
447

1,139


% % % % %

1.6




.3
1.3

3.4
9.3
1.96
1.14




1.06 223 14.46



1.33 236 13.14

3.38 729 100



1.07
1.20

2.53
4.93 1,063 67.41
.95



1.92
2.07

5.23 1,139 72.69


                                         (continued)
               A-9

-------
                         MEDICM-OUTY TRUCK POPULATION
                                       YEAR -  1977
                                                        (Continued
                                        MOTOR VEHICLE  POPULATION
COUNTY

Lapeer
Laelanau
Leaawe«
Livingston
Luce
Macfcinac
Macomb
Manistaa
Marquette
Mason
Macosta
Menominaa
Midland
Missaukee
Monroe
Montcalm
Monenorsncy
MusJcegon
Newaygo
Oakland
Ocaana
Ogemaw
Onconagon
Osceola
Oscoda
otsego
Ottawa
Preseque Isle
Roscommon
Saginaw
St. Clair
St. Joseph
Sanilac
Schoolcraft
Shiawassee
Tuscola
Van Buren
Washtsnaw
Wayne
Hexford
Foreign
Monattain- Grand
Statewide nent Counties Raoids Lansing Flint Detroit

223
91
614
234
ia
35
1,173
93
167
92
101
137
170
SO
696
170
23
399
123
1,719
124
57
20
73
25
51
423
99
27
794
361
217
283
17
343
499
377
553
4,092
73
—
%
.93
.37
2.49
.95
.07
.14
4.76
.34
.63
.37
.41
.56
.69
.24
2.33
.69
.09
1.52
.32
6.93
.50
.23
.08
.30
.10
.21
1.74
.40
.11
3.23
1.47
.38
1.15
.07
1.41
2.03
1.51
2.25
16.62
.30
—

223

614
234


1,173

167



170

696
170

399

1,719






428


794
361
217
283

343
499
377
553
4,092


% % % % *
1.06

2.35
1.09


5.44 1,173 14.2;

.77



.79

3.23 696 3.4!
.79

1.35

7.97 1,719 20.3!






1.93 428 27.31


3.63
1.67
1.00
1.31

1.61
2.31
1.75
2.56 553 6.7
13.96 4,092 49.7


Total
               24,620   100   21,530  100   1,567  100   1,577  100
                                                                       729  100    3,233  100
                                                A-10

-------
HEAVY-OUTY TRUCK POPULATION
        YEAR - 1977

         MOTOR VEHICLE POPULATION
Nonattain- Grand
COCNTY
Alcana
Alg«c
Allagan
Alpena
Antrim
Arenac
Baraga
3arry
Bay
Benzie
Bernan
Branch
Calhoun
Cass
Ciarlevoix
Cheboygan
Chippewa
Clare
Clinton
Crawford
Delta
Dickinson
2aton
2mnet
Genesae
Giadwin
Gog able
Gd. Traverse
Gratiot
Hillsdale
Hougnton
Huron
tngnam
Tania
losco
Iron
Isabella
Jackson
Xaiamazoo
KaJJcaska
Kent
Kewesnaw
WXe
Statewide sent Counties Rapids Lansing ?lmt Detroit
62
63
1,025
339
149
137
69
272
1,532
37
1,661
613
1,109
S23
136
203
317
134
634
66
811
4S6
333
267
3,415
120
146
536
626
666
262
917
2,301
455
223
119
504
1,310
1,707
163
6,793
17
40
.07
.07
1.21
.40
.13
.22
.08
.32
1.36
.10
1.96
.72
1.31
.62
.16
.25
.37
.22
.75
.08
.72
.54
.75
.31
4.02
.14
.17
.75
.74
.78
.31
1.08
2.71
.54
.27
.14
.59
1.54
2.01
.20
3.00
.02
.05


1,025




272
1,582

1,561
513
1,109
523




634



633

3,415



626
566

917
2,301
455



1,310
1,707

6,793




1.35




.36
2.03

2.19
.3
1.45
.70




.34 S34 17.74



.34 633 17.36

4.50 3,415 100



.32
.38

1.2
3.03 2,301 84.40
.60



1.73
2.24

3.95 5,793 30.38


                                              (continued)
                A-ll

-------
                          HEAVY-DOTY TRUCK POPULATION
                                       YEAR - 1977
(Continued)
                                        MOTOR VEHICLE POPULATION
Nonattain- Grand
COUNTY
Lapear
Laalanau
Lanawee
Livingston
Luce
Mackinac
Maconb
Manistee
Marquetta
Mason
Mecosta
Menominaa
Midland
Missaukae
Monroe
Montcala
Montaorency
Muskegon
Newaygo
Oakland
Oceana
Ogemaw
Ontonagon
Osceola
Oscoda
Otsego
Ottawa
Presequa Isla
Soscommon
Sagvnaw
St. Claxr
St. Joseph
Sanilac
Schoolcraft
Shiawassae
Tuscola
Van 3uren
washtanaw
Wayna
Wexford
Foreign
Statewide ment Counties Raoida Lansing Flint Detroit
639
160
1,129
593
73
30
4,506
173
503
231
212
429
464
135
1,386
435
78
1,431
352
7,627
197
165
32
212
47
219
1,658
152
94
2,512
1,248
750
677
98
650
1,070
574
1,407
20,336
259
—
.78
.19
1.33
.70
.09
.09
5.31
.20
.59
.27
.25
.51
.55
.16
1.63
.57
.09
1.69
.41
3.99
.23
.19
.10
.25
.36
.26
1.95
.13
.11
2.96
1.47
.38
.30
.12
.77
1.26
.63
1.66
23.36
.31
—
659

1,129
593


4,506

503



464

1,336
435

1,431

7,627






1,658


2,512
1,248
750
677

650
1,070
574
1,407
20,336


.37

1.49
.73


5.94 4,506 12.7:

.66



.61

1.33 1,386 3.9
.64

1.38

10.05 7,627 21.6






2.18 1,658 19.62


3.31
1.64
.99
.39

.86
1.41
.76
1.35 1,407 3.9
26.79 20,336 57.6


Total
               34,869  100   75,917  100    3,451   100    3,573   100   3,415  100   35,262  100
                                             A-12

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MOTORCYCLE POPULATION
     YEAR - 1977

      MOTOR VEHICLE  gQPOIATION
Nonattain- Grand
Statewide
COUNTY
Alcona
Alger
Al lagan
Alpena
Antrim
Arenac
3araga
Barry
Bay
Benzia
Semen
Branch
Calhoun
Cass
Charlavoix
Cheboygan
Chippewa
Clara
Clinton
Crawford
Delta
Dickinson
Eaton
Smmet
Ganesea
Gladwin
Gogebic
Gd. Traverse
Gratiot
Hillsdale
Houghton
Huron
I.ignam
Ionia
losco
Iron
Isaoella
Jackson
Kalamazoo
KalXaska
Kant
Keweenaw
Lake
x 103
.27
.34
2.4S
1.10
.36
.38
.30
1.73
3.12
.34
4.36
1.38
4.63
1.94
.73
.73
1.11
.63
2.23
.30
1.19
.99
3.14
.33
12.32
.53
.48
1.79
1.74
1.53
.39
1.16
3.12
2.19
.34
.41
1.29
4.32
6.70
.27
13.77
.33
.17
%
0.1
0.1
1.0
0.4
0.2
0.2
0.1
0.7
1.3
.1
1.3
0.5
1.9
0.3
0.3
0.3
0.4
0.3
0.9
0.1
0.5
0.4
1.3
0.3
5.2
0.2
0.2
0.7
0.7
O.S
0.4
0.5
3.3
0.9
0.4
0.2
0.5
1.9
2.7
0.1
5.6
0.0
0.1
ment Counties Raoids Lansing Flint Detroit
x 103


2. 43




1.73
3.12

4.56
1.33
4. S3
1.94




2.28



3.14

12.32



1.74
1.53

1.16
3.12
2.10



4.32
6.70

13.77


% x 103 % x 103 * x 103 % x 103 %


1.1




0.3
1.4

2.1
0.6
2.1
0.3




1.0 2.28 16.3



1.4 3.14 23.2

5.9 12.32 100



0.3
0.7

0.5
3.7 3.12 60
1.0



2.2
3.1

6.3 13.77 72.7


                                     (continued)
          A-13

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                    MOTORCYCLE  POPOLATION
                         YEAR - 1977
                                           (Continued)
                          MOTOR VEHICLE POPULATION
Nonattain- Grand
Statewide
couwn
Lapeer
L«elanau
Lenawee
Livingston
Luce
Mackinac
Ma comb
Manistee
Marquette
Mason
Macosta
Menominea
Midland
Hissaukee
Monroe
Montcalm
Montaiorency
Muskegon
Newaygo
Oakland
Oceana
Oqemaw
Ontonagon
Osceola
Cscoda
Otsego
Ottawa
Preseoiie Isle
Soacomnran
Saginaw
St. Glair
St. Joseph
Sanilac
Schooler aft
Shiawassee
Tuscola
Van Suren
Waahtenaw
Wayne
Wexford
Foreign
x 103
2.43
.36
3.06
2.32
.18
.35
16.91
.61
2.30
.97
.75
.32
2.30
.35
4.13
1.76
.24
S.1S
1.37
24.73
.75
.50
.26
.64
.23
.52
5.15
.44
.55
5.77
4.15
2.20
1.43
.35
2.90
1.98
2.03
6.77
42.09
.93
.16
4
1.0
0.1
1.2
1.1
0.1
0.1
6.3
0.2
1.1
0.4
0.3
0.3
0.9
0.1
1.7
0.7
0.1
2.1
0.6
10.0
0.3
0.2
0.1
0.3
0.1
0.2
2.1
0.2
0.2
2.3
1.7
0.9
0.6
0.1
1.2
0.3
o.a
2.7
17.0
0.4
0.1
meat Counties Rao ids Lansing Flint
xlO3
2.43

3.06
2.32


16.91

2.30



2.30

4.13
1.76

5.15

24.73






5.15


5.77
4.15
2.20
1.43

2.90
1.98
2.03
6.77
42.09


% X 10 % X 103 * x 103 %
1.1

1.4
1.3


7.7

1.3



1.1

1.9
0.3

2.4

11.3






2.3 5.15 27.2


2.6
1.9
1.0
0.7

1.3
1.0
0.9
3.1
19.3


Detroit
x 103 %






16.91 17.9







4.13 4.4




24.73 26.1

















6.77 7.1
42.09 44.5


247.42  100   213.64  100   13.92  100   13.54  100   12.32  100
                                                                    94.63  100
                               A-14

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       APPENDIX B




LEGISLATIVE CONSIDERATIONS

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                                APPENDIX B
                     LEGISLATIVE CONSIDERATIONS

B.I  INTRODUCTION
     Well-designed  legislation  is needed  in any area  to properly
implement any program or to create the  authority to carry out particular
responsibilities.   The purpose  of the following appendix is to review
legislation in effect in the State of Michigan and to determine
the applicability of such legislation to  the implementation of an  I/M
program.  The enabling legislation for  such a program will be developed
in part by reviewing existing legislation to determine the need for and
extent of additional legislation.
     The basic approach used in analyzing the legislative issues and
requirements consist of a review of  (1) existing Michigan legislation,
and (2) results of  studies by state legislatures that have implemented
existing I/M programs.  This review provides excerpts from example
state legislation to indicate certain important dimensions that should
be incorporated in  any proposal.  Obviously, the evejitual legislation
and implementation  authority rests with officials of  the State of Michigan.

B.2  EXISTING MICHIGAN LEGISLATION
B.2.1  MICHIGAN MOTOR VEHICLE CODE: INSPECTION
     The authorization for and  enforcement power of the Michigan Motor
Vehicle Code derives from Act No. 300 of  the Public Acts of 1949, which
is in part
    "....AH act to provide for  the registration, titling, sale
     and transfer,  and regulation of vehicles operated upon the
     public highways of this state; to provide for the licensing
     of vehicle dealers and wreckers; to  provide for  the examina-
     tion, licensing and control of operators and chauffeurs;
     to provide for the giving  of proof of financial  responsibility
     and security by owners and operators of vehicles; to provide
     for the imposition, levy and collection of specific taxes
     on vehicles, and the levy  and collection of sales and use
    _taxes, license fees and permit fees; to provide  for the
                                 B-l

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     regulation and use of streets and highways; to provide
     penalties for violation of any of the provisions of this
     act; to provide for civil liability of owners and operators
     of vehicles and service of process on nonresidents; and
     to repeal all other acts or parts of acts inconsistent
     herewith or contrary hereto."

     This act has been amended since 1949 and several sections dealing
with motor vehicle operation have been added.  Section 257.715 (a)
and (b) deals with the inspection of vehicles and equipment.  This
section was enacted to enforce safety legislation, and the authority
for such inspection was delegated to the Department of State Police.
This section is quoted in its entirety below.

     257.715  Inspection of vehicles and equipment.  MSA 9.2415
              Amended by Public Act 510
        Sec. 715  (a) Equipment on motor vehicles as required
     under this.act shall be maintained as provided in this act.
     Any uniformed policy officer shall be authorized on reason-
     able grounds shown to stop any motor vehicle to inspect the
     vehicle, and if any defects in equipment are found, to issue
     an appropriate citation under section 728 or 742 to the
     driver and to order the driver to have the defect or defects
     repaired immediately.  In case of accident any policy officer
     may make inspection of the cars involved.

         (b) The director of the department of state shall cause
     inspection to be made of motor vehicles operating on the
     public highways to detect defective equipment or other vio-
     lations of law governing the use of public highways by motor
     vehicles, operators and chauffeurs.  For such purpose the
     director may establish temporary vehicle check lanes at ap-
     propriate locations throughout the state for checking those
     inadequacies and violations.  A county, city, village or
     township police department may also operate such a tempor-
     ary check lane within its limits with the express authorization
     of the director and under the direct supervision of a
     designated representative of the director.

     Section 257.683 of the Public Act No. 300 deals with equipment,
condition, and inspection of motor vehicles.  This section was used
in conjunction with Section 257.715 to enable the State Police to

enforce  safety requirements for vehicles and allow inspection.
                                 B-2

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     257.683  Equipment, condition, inspection.  MSA 9.2383
       Sec.  683.   (a)   It is a misdeamanor for any person
     to drive or move or for the owner to cause or knowingly
     permit to be driven or moved on any highway any vehicle
     or combination of vehicles which is in such unsafe con-
     dition as to endanger any person, or which does not
     contain those parts or is not at all times equipped with
     such lamps and other equipment in proper condition and
     adjustment as required in this chapter, or which is
     equipped in any manner in violation of this chapter, or
     for any person to do any act forbidden or fail to per-
     form any act required under this chapter.
       (b)   Any police officer shall be authorized on reasonable
     grounds shown to stop any motor vehicle and inspect the
     same,  and if any defects in equipment are found, to arrest
     the driver in the manner provided in this chapter.
       (c)   Nothing contained in this chapter shall be construed
     to prohibit the use of additional parts and accessories
     on any vehicle not inconsistent with provisions of this
     chapter.
       (d)   The provisions of this chapter with respect to equip-
     ment on vehicles shall not apply to implements of husbandry,
     road machinery, road rollers, or farm tractors except as
     herein made applicable.

     The safety inspection of motor vehicles has since been abandoned

 by the State of Michigan.  Annual enforcement is operative only for

school buses.

     (Senate Bill No.  360 was passed in the regular session of 1978 and

amended Section 707 (a-f) of the Act No. 300 of the Public Acts of 1949.
This amendment specifically deals with the Michigan Vehicle Noise Con-
trol Act, and grants no further inspection authority to any organization.)
B.2.2  MECHANIC CERTIFICATION

     The Motor Vehicle Service and Repair Act was passed in 1974 and

was included as Sections 257.1301 through 257.1340.  This act was

established "to regulate the practice of servicing and repairing motor

vehicles; to proscribe unfair and deceptive practices; to provide for
                                 B-3

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 training and certification of mechanics; to provide for the registration
 of motor vehicle repair facilities; to provide for enforcement; and to
 prescribe penalties."
      An amendment has been proposed that the Michigan Motor Vehi-
 cle Code add Section 257.7196 which proscribes tampering with motor
 vehicle emission control equipment.  However  this possible modifica-
 tion of the Code is still under review by the State Legislature.  The
 status of this bill is uncertain.

 B.2.3  SUMMARY
      We find that no legislation is currently in force in the State of
 Michigan for the operation and enforcement of an I/M program.  Separate
 legislation would be needed, which would specify the required budget
 appropriation, and the delegation of authority and administrative
 responsibilities to a particular state department or departments, and
 the eventual enforcement of the law to the same and/or different
 departments (s).  Experience has shown that an effort should still
 be made where possible to consolidate the new legislation into existing
 legislation.

B.3  LEGISLATION REVIEW;  GENERAL
     Several issues relevant to I/M legislation were identified during
a literature review.  Each issue is discussed below, first in general
terms, second, in terms of extant legislation in 11 other states, and
third, in terms of Michigan specifically, where appropriate.  Discussion
of these issues is intended only for guidance and information to
Michigan's decision makers.
     There were essentially 24 issues identified during review of
extant legislation.  The review covered all pertinent literature and
documentation from around the United States.  The Environmental Protection
                                   B-4

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Agency was initially contacted to obtain necessary documentation.
Subsequently, State and/or local governmental units in locations where
I/M legislation or an ordinance has been enacted were contacted to
obtain a copy of their legislation and to solicit their comments on
problems encountered.  A conclusion drawn from the findings was that, at
minimum, the issues listed below should be thoroughly treated in any
relevant I/M legislation.
     The first 20 issues should constitute a basic framework of any I/M
legislation whether state-, contractor- or private garage-operated.
     The last four elements identified need not be included for consid-
eration of a state-operated program, but should be dealt with in a
contractor- or private garage-operated option.

         Recommended Components and Issues for Treatment in
                    Michigan I/M Legislation
     1.  Authority or purpose of program
     2.  Definitions
     3.  Applicability and frequency of tests
     4.  Test procedures
     5.  Emission standards
     6.  Certification
     7.  Agency responsible for implementation
     8.  Licensing of personnel and equipment
     9.  Retest policy
    10.  Repair cost limits
    11.  Fleet inspections
    12.  Registration in county other than that of residence
    13.  Test fees
    14.  Time frame of implementation
    15.  Annual study
    16.  Tampering with emission control equipment
                                B-5

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    17.  Penalties
    18.  Warranty provisions
    19.  Exceptions
    20.  Variances
     (The following four additional items should be included if the
State of Michigan decides to utilize a private contractor or individual
garages.)
     1.  Authority to contract with private contractor(s)
     2.  Monitoring performance of private contractor(s) and/or garages
     3.  Conflict of interest
     4.  Licensing of inspection facilities

B.3.1  AUTHORITY OR PURPOSE
     The basic purpose of the I/M program should be included at the
beginning of the legislation, generally as a preamble.  This section
may also provide the statutory authority to implement an I/M program.
A lead agency could be designated in this section.  The two examples
illustrate differing approaches to this essential component.
     The, first example is from the act entitled "Air Quality Regulations
for Mobile Equipment" in the State of Nevada, which was approved
August 16, 1978.
                  WHEREAS,, the Nevada State Implementation Plan
     shows that from the available ambient air quality data for
     carbon monoxide and oxidants, Clark County, specifically
     the Las Vegas Valley, and Washoe County, specifically the
     Truckee Meadows, is in violation of the State and national
     ambient air quality standards; and
                  WHEREAS, such standards were promulgated by
     the United States Environmental Protection Agency and the
     State Environmental Commission for the express purpose of
     protecting the health and welfare of the citizens residing
     therein; and
                                 B-6

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                  WHEREAS,  the control strategy for reducing
     carbon monoxide and the oxidant levels by the reduction
     of the carbon monoxide and hydrocarbon emissions respec-
     tively includes the implementation of a strategy for
     inspecting and maintaining in-use motor vehicles; and

                  WHEREAS,  the Fifty-Ninth Session of the
     Nevada State Legislature provided guidance to the State
     Environmental Commission to establish an annual inspection
     and maintenance program in progressive steps; and

                  WHEREAS,  the State Environmental Commission
     now deems said inspection program necessary to aid in the
     achievement of the required ambient air quality standards;
     and

                  WHEREAS,  the Fifty-Ninth Session of the Nevada
     Legislature established authority for the Department of
     Motor Vehicles to promulgate requirements for licensing
     and inspecting authorized stations;

                  NOW, THEREFORE, be it resolved that the
     State Environmental Commission and the Department of Motor
     Vehicles promulgate these regulations with the express
     purpose of developing data upon which to define the re-
     ductions in emissions for in-use motor vehicles and to
     affect a portion of the implementation plan for the reduc-
     tion of emissions to aid in the achievement of the ambient
     air quality standards which are presently being violated
     predominantly because of motor vehicle emissions; and be
     it further resolved that such progressive step implemen-
     tation is based on the requirements of Chapter 445 of NRS;
     and be it further resolved that a cooperative study to be
     completed by January 1979, such study will show acceptance
     by and protection of consumers, cost for improvement of
     air quality, and the effectiveness of the program as a
     whole; and be it further resolved that the motor vehicle
     owner will be provided with information explaining the
     reason for the methods of inspections.
     The second example is taken from the "model I/M legislation" pro-
vided by the U.S. EPA, which sets forth the following preamble:
                                 B-7

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      MODEL LEGISLATION FOR MOTOR VEHICLE  POLLUTION  CONTROL
      "Purpose

      Legislative  Findings:   For  purposes  of  public  health and
      safety, the  	 finds:

      (1)   That  the  emission  of pollutants from motor  vehicles
      is  a  significant cause  of air pollution in  many  sections
      of  the State of 	.

      (2)   That  the  control and elimination of such  pollutants
      are of utmost  importance for the  protection and  preserva-
      tion  of the  public health,  safety and well-being.

      (3)   That  each state  has a  responsibility to establish
      procedures,  regulations and other provisions which comply
      with  any promulgated  federal laws to control or  eliminate
      each  pollutants.

      The state  Environmental Agency  and all  other agencies,
      departments  or divisions of said  departments and agencies
      shall provide  by rules  and  regulations  standards,  guide-
      lines, for the inspection of all  registered vehicles
      (with promulgated exceptions) in  said state, for the pur-
      pose  of controlling exhaust emissions of any air contaminants."
B.3.2   DEFINITIONS

      All legislation reviewed included a separate section of definition

 of terms commonly associated with an I/M program, or of those terms

 used in the text of the specific enactment.   The purpose of a definition

 section is to provide a clear,  unambiguous meaning to some terms in

 order to avoid legal problems,  misinterpretations or conflicts.   The

 following section of definitions is excerpted from the State of

 Nevada's regulations:

 ARTICLE 1 - DEFINITIONS

 1.1     AMBIENT AIR:  That portion of the atmosphere surrounding people,
         animal, and plant life.

 1.2     APPROVED INSPECTOR:  An individual person who has qualified
         by passing  the written examination as prepared by the Department
         of Motor Vehicles, and has successfully demonstrated the ability
         to operate  the required diagnostic equipment, and has been
         issued a license as an approved inspector.
                                 B-8

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1.3      AUTHORIZED STATION:   As defined in subsection 1 of Chapter 445
         of NRS,  means,  a station licensed by the Department of Motor
         Vehicles for inspecting motor vehicles and pollution control
         devices  for compliance with Chapter 445 of NRS or any applicable
         federal  or Commission regulation and for installing, repairing,
         and adjusting pollution control devices and motor vehicles
         to meet  the Commission's requirements.

1.4      CARBON MONOXIDE (CO):  A colorless, odorless, highly toxic
         gas that is a normal byproduct of incomplete fossil fuel
         combustion.

1.5      CERTIFICATE OF COMPLIANCE:   A certificate, issued by an approved
         inspector in an authorized station which declares that the
         motor vehicle identified on the certificate is properly equipped
         with the pollution control devices indicated on the certificate
         that such devices conform with the requirements of Chapter 445
         of NRS and rules and regulation as adopted by the State Envi-
         ronmental Commission.

1.6      COMMISSION:  The State Environmental Commission, as defined
         in Chapter 445 of NRS.

1.7      CRANKCASE-EMISSIONS:  Air contaminants emitted into the atmos-
         phere from any portion of the engine crankcase ventilation
         or lubrication systems.

1.8      DEPARTMENT:  The Department of Motor Vehicles.

1.9      DIAGNOSTIC EQUIPMENT:  Tools used to diagnose engine performance.

1.10     EMISSION:  The act of passing into the atmosphere an air con-
         taminant or a gas stream which contains, or may contain, an
         air contaminant; or the material passed to the atmosphere.

1.13     EXHAUST  EMISSIONS:  Air contaminants emitted into the atmos-
         phere from any opening downstream from the exhaust ports of
         a motor  vehicle engine.

1.14     EXHAUST  GAS ANALYZER:  A device for sensing the amount of air
         contaminants in the exhaust emissions of a motor vehicle.

1.15     FLEET OWNER:  An owner or lessee of three "or more motor vehicles.

1.16     FLEET STATION:   as defined in subsection 4 of Chapter 445.610
         of NRS,  means a facility which is licensed by the Department
         to conduct inspections of the motor vehicles of qualified
         owners or lessees.
                                B-9

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1.17     GROSS VEHICLE WEIGHT:   The manufacturer's gross weight rating
         for the individual motor vehicle.

1.18     HEAVY-DUTY MOTOR VEHICLE:  A gasoline fueled motor vehicle
         whose GVW is greater than 2,721 kilograms (6,000 pounds).

1.19     HYDROCARBONS:  A family of compounds containing carbon and
     - .  -hydrogen in various combinations, found especially in fossil
         fuel.

1.20     INSPECTION/MAINTENANCE:  A strategy to reduce emissions from
         in-use motor vehicles by identifying vehicles that need
         emissions-related maintenance and requiring that such main-
         tenance be performed.

1.21     LIGHT-DUTY MOTOR VEHICLE:  A passenger car or passenger car
         derivative capable of seating 12 persons or less and having
         a GVW rating of 2,721 kilograms  (6,000 pounds) or less; or
         a motor vehicle designed primarily for the transportation
         of property, or the derivation of such a vehicle, having a
       .  GVW rating of 2,721 kilograms  (6,000 pounds) or less.

1.25     NEW MOTOR VEHICLE:  A motor vehicle that has never been
         registered with the Department, and has never been registered
         with the appropriate agency of authority of any other state,
         the District of Columbia, any territory or possession of
         the United States or foreign state, province, or country.

1.26     NITROGEN OXIDES:  A gas formed in great part from atmospheric
         nitrogen and oxygen when combustion takes place under high
         temperature and high pressure, as in internal combustion
         engines.  All oxides of nitrogen except nitrous oxide, which
         is not considered toxic at ambient concentrations, as measured
         by test methods set forth in this part.

1.29     REGISTERED OWNER:  An individual, firm, corporation, or
         association whose name appears in the files of the motor
         vehicle registration division of the Department of Motor
         Vehicles as the person to whom the motor vehicle is registered.

1.34     TAMPERING:  Rendering inoperative, or intentional misadjustment
         of any motor vehicle device or element of design intended to
         control exhaust emissions.

1.37     WAIVER:  A document which would permit registration of a
         vehicle that does not meet the emission standard as set forth
         by the State Environmental Commission, and is issued only by
         the Department of Motor Vehicles, which shall expire one
         year from the date of issuance.
                                 B-10

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 1.38     The  abbreviations  used in these regulations have the following
          meanings:
                     °C  -  degree Celsius   (centigrade)
                     CO  -  carbon monoxide
                    GVW  -  gross  vehicle weight
                     HC  -  hydrocarbons
                     kg  -  kilogram (s)
                     Ib  -  pound  (s)
                    NO   -  nitrogen oxides
                    ppm  -  parts  per million
      The  number  of  definitions  provided  by the  Nevada regulations
 may be  considered excessive (fewer than  half  the  total appear above).
 However,  any  section of definitions should be as  comprehensive as the
 scope of  the  enactment  requires.
B.3.3  APPLICABILITY AND FREQUENCY  OF  INSPECTIONS
     This  issue  covers three  separate  elements:  geographical area in
 which the  program is to be operated, class(es) of  vehicles  to be covered,
 and  the frequency at which these vehicles must be  tested.   Most of the
 legislation reviewed limited  the geographical area of  coverage to within
 the  commonly understood political boundary  lines of counties, cities,
 or for the entire state.  Some  states  have  established urban  area popu-
 lation thresholds below which an area  would not qualify for program
 implementation owing to the presumption of  limited program  effectiveness
 in less densely  populated areas.
     State of Arizona House Bill 2319, Chapter 158, states  that "the
 Director shall administer a comprehensive annual emissions  inspection
 program which shall require the inspection  of vehicles in this state
 in accordance with the provisions of law or administrative  regulations
 pursuant to this article.  Such inspection  shall commence in  counties
 with a population in excess of 350,000 by January  1, 1976.  Inspection
 in other counties of the state will commence when  required  by the
 director to meet air pollution  control standards or upon application
                                 B-ll

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by a county board of supervisors for participation in such inspection
programs, subject to approval by the Director."
     Setting the threshold at 350,000 population automatically pro-
vides for the inclusion of other areas as population grows.  The State
of Michigan, in order to limit the geographic range of an I/M program,
might consider a simple statement such as "This program is applicable
to (vehicles categories) in the counties of	 in the State
of Michigan."
     In addition to defining the geographical coverage of the I/M
program, the enabling legislation must specify the type of vehicles
to be included in the program.  The study presently underway should
provide guidance to state officials toward reaching a decision on
vehicle coverage.  In the legislation reviewed, vehicle types are gen-
erally separated on the basis of gross vehicle weight (GVW).  The
following categories are generally utilized:
         LDV - light-duty vehicles (all passenger cars)
        LDT1 - light-duty trucks with GVW less than 6,001 Ibs
        LDT2 - light-duty trucks with GVW greater than 6,000
               but less than 8,501 Ibs.
         HDD — diesel-fuel-powered trucks of greater than 8,500
               Ibs GVW
     In addition to those for vehicle coverage, most states with I/M
have provisions for used autos sold by dealers, autos sold by one
individual to another, new autos, and autos belonging to residents
moving into the affected geographical area from outside the area.
Moreover, most states require that if a vehicle in a category subject
to testing is sold by one party to another,  evidence of inspection
must be presented prior to the completion of the title change.  In
the event a test certificate has expired, no new title will be issued
until the car is inspected and a new certificate issued.
                                 B-12

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Vehicles owned by an individual moving into the covered geographical
area may be processed as new cars.  The State of Nevada's legislation
dealt with this problem by including a statement which in part reads:
          In accordance with Chapter 445 of NRS, on or after July 1, 1977,
          all used light-duty motor vehicles being registered to a new
          owner or being registered for the first time are required
          to have evidence of compliance, in Clark County.
          In accordance with Chapter 445 of NRS, on or after July 1, 1979,
          all used light-duty motor vehicles being registered or re-
          registered are required to have evidence of compliance, in
          Clark County.
     The procedures cited assume that vehicle registration will be
the mechanism utilized for enforcement.
     The last element to be addressed here is the frequency at which
a vehicle should be tested.  It is shown elsewhere in this report that
tailpipe emissions are lowest after an inspection.  The emissions
deterioration curve (rate of increasing emissions) gradually rises over
time until about the ninth or tenth month after inspection, at which
point it has reached or surpassed preinspection emission intensity
levels.  It is from this standpoint, and as a matter of practicality,
that most programs have settled on an annual inspection cycle.  Usually,
this annual inspection is integrated with motor vehicle registration,
thereby combining requirements and resulting in a lower outlay than
would be required by a nonintegrated program.

B.3.4  TEST PROCEDURES
     The legislation review revealed divergant approaches to the adop-
tion of test procedures.  Some states have not addressed this issue
at all, effectively leaving definition and implementation of the actual
procedures to the authority of a department or a director.  Conversely,
other states have gone to considerable length to lay out the process
step-by-step.  Differing approaches are shown in the two examples that
                               B-13

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follow.

     Example one, from New Jersey, contains a simple, relatively non-

specific process description.  Example two, from the State of Oregon,

provides step by step instructions for testing.


                          EXAMPLE ONE
                     Prescribed Inspection
                        Test Procedure

     STEP 1:  All measurements are to be made after engine has
     been operating a sufficient period of time to attain normal
     operating temperature.

     STEP 2:  With the vehicle in neutral gear, all accessories
     off, handbrake secured, accelerate engine and observe for
     continuous visible smoke in the crankcase emissions after
     vehicle has reached a steady state condition.

     STEP 3:  With the engine running at idle, insert sample
     probe of gas 'analytical system into the engine exhaust
     outlet.  The steady state levels measured as percent car-
     bon monoxide and parts per million of hydrocarbons in the
     exhaust gas shall be the inspection test result.


                          EXAMPLE TWO

     24-310 Light-Duty Motor Vehicle Emission Control Test Method

          (1)  The vehicle emission inspector is to ensure that
     the gas analytical system is properly calibrated prior to
     initiating a vehicle test.

          (2)  The Department approved vehicle information data
     form is to be completed at the time of the motor vehicle
     being  inspected.

          (3)  Vehicles having coolant, oil or fuel leaks or
     any other such defect that is unsafe to allow the emission
     test to be conducted shall be rejected from the testing
     area.  The emission test shall not be conducted until the
     defects are eliminated.
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     (4)  The vehicle is to be in neutral gear if equipped
with a manual transmission, or in "park" position if
equipped with an automatic transmission.

     (5)  All vehicle accessories are to be turned off.

     (6)  An inspection is to be made to ensure that the
motor vehicle is equipped with the required functioning
motor vehicle pollution control system in accordance with
the criteria of section 24-320(3).  Vehicles not meeting
this criteria shall be rejected from the testing area with-
out an emission test.  A report shall be supplied to the
driver indicating the reason(s) for rejection.

     (7)  With the engine operating at idle speed, the
sampling probe of the gas analytical system is to be inser-
ted into the engine exhaust outlet.

     (8)  The steady-state levels of the gases measured
at idle speed by the gas analytical system shall be recorded.
Except for diesel vehicles, the idle speed at which the gas
measurements were made shall also be recorded.

     (9)  Except for diesel vehicles, the engine is to be
accelerated with no external loading applied, to a speed
of between 2,200 and 2,700.  The engine speed is
to be maintained at a steady speed within this speed range
for a 4 to 8 second period and then returned to an idle
speed condition.  In the case of a diesel vehicle, the
engine is to be accelerated to an above idle speed.  The
engine speed is to be maintained at a steady above idle
speed for a 4 to 8 second period and then returned to an
idle speed condition.

    (10)  The steady state levels of the gases measured
at idle speed by the gas analytical system shall be recorded.
Except for diesel vehicles, the idle speed at which the gas
measurements were made shall also be recorded.

    (11)  If the vehicle is equipped with a multiple exhaust
system, then steps (7) through (10) are to be repeated on
the other exhaust outlet(s).  The readings from the exhaust
outlets are to be averaged into one reading for each gas
measured for comparison to the standards of section 24-330.
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          (12)  If the vehicle is capable of being operated with
     both gasoline and gaseous fuels, then steps  (7)  through  (10)
     are to be repeated so that emission test results are obtained
     for both fuels.

          (13)  If it is ascertained that the vehicles may be  emit-
     ting noise  in excess of the noise standards adopted pursuant
     to ORS 467.030, then a noise measurement is to be conducted
     in accordance with the test procedures adopted by the Com-
     mission or  to standard methods approved in writing by the
     Department.

          (14)  If it is determined that the vehicle complies
     with the criteria of section 24-320 and the standards of
     section 24-330, then, following receipt of the required  fees,
     the vehicle emission inspector shall issue the required
     certificates of compliance and inspection.

          (15)  The inspector shall affix any certificate of
     inspection  to the lower left-hand side  (normally the driver's
     side) of the front windshield, being careful not to obscure
     the vehicle identification number nor to obstruct driver
     vision.

          (16)  No certificate of compliance or inspection shall
     be issued unless the vehicle complies with all requirements
     of these rules and those applicable provisions of ORS 468.360
     to 468.405, 481.190 to 481.200, and 483.800 to 483.825.


B.3.5  EMISSION  STANDARDS

     There is an inverse relationship between I/M program stringency

 factors and permissible emissions per vehicle.  As stringency is
 increased (0 to  50 percent),emission cutpoints are lowered, thereby
 increasing failure rate.  Conversely, as stringency is decreased  (50 to

 0 percent), emission standards are relaxed, thereby decreasing the failure  rate.

     There are essentially two methods  of  setting standards

 cutpoints.  The  first method is to delegate authority to a particular

 agency or individual.  This is the case of the State  of Arizona,  in

 which  I/M legislation stipulates that "the director shall adopt minimum

 emissions standards pursuant to section 36-1717 with  which the various

 classes of vehicles shall be required to comply after January 1,  1977.
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For the purpose of determining compliance with minimum emissions stan-
dards, vehicles shall be required to pass only the idle test condition.
The loaded test condition shall be administered at the official emis-
sions inspection stations for diagnostic purposes only.  Vehicles which
fail the idle test solely because of air gas mixture shall be entitled
to a certificate of waiver upon correction of the problem, after having
furnished satisfactory evidence of correction to the director on a form
to be prescribed by the director."
     This clause empowers the Director of the Bureau of Vehicular Emis-
sions Inspections to revise the standards upward or downward depending
on the actual testing results, number of cars failed, and the state
of new technology.
     In the second method, standards are incorporated into the legis-
lation itself.  This could involve establishing cutpoints specific
to the type and model year of the vehicle, which ensures that the pro-
gram is equitable in the sense that older, less controlled cars are
subject to more lenient standards than late model vehicles.  A somewhat
more inclusive criterion for establishing cutpoints is recommended
by EPA in its draft legislation.  Cutpoints are classified by vehicle
model year according to the type of test implemented.  The following
cutpoints are suggested by the EPA:
                      IDLE EMISSIONS TEST
Model Year
Pre-1968
1968-69
1970-74
Post-1974
Maximum Allowable
HC (ppm)
1,000
600
500
150
CO (%)
6.0
5.0
4.0
1.5
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                       LOADED EMISSIONS TEST
Model
Year
Pre-1968
1968-69
1970-74
Post 1974
Number of
Cylinders
4 or less
5 or more
4 or less
5 or more
4 or less
5 or more
4 or less
5 or more
Maximum Allowable HC (ppm) and CO (%)
Idle
HC
1300
1000
800
600
550
500
150
150
CO
8.0
6.0
6.0
5.0
5.0
4.0
1.5
1.5
Low Cruise
HC
1000
700
600
400
400
350
120
120
CO
6.0
5.2
4.2
3.5
3.5
3.0
1.0
1.0
High Cruise
HC
1000
700
600
400
400
350
100
100
CO
5.0
4.2
3.8
3.0
3.0
2.5
0.9
0.9
       Whatever the approach taken for establishing outpoints, it is
suggested that this aspect be studied in greater detail.  Stringent
standards spread the burden of repair costs over a large number of vehicle
owners, and may increase the frequency of consumer complaints despite a
lower average per-vehicle repair cost.  On the other hand, relaxed stan-
dards result in lower total repair costs to the driving public, but the
"gross emitters" identified in the program may suffer very high average
per-vehicle repair liabilities.  Because these drivers may tend to be
relatively disadvantaged economically, questions about the social equity
of the program can arise.

B.3.6  CERTIFICATION
       Certification is necessary to the succesful implementation of any
I/M program.  It ensures compliance with laws and regulations by motor
vehicle owners.  The instruments most commonly used to certify passage
of emission requirements are vehicle stickers and the annual registration
process.  A majority of states with programs utilize the  registration
method as an effective enforcement technique.  This mechanism obligates
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the individual to an emissions test prior to the renewal of his vehicle's

operating license.  In the event of an unrepaired failure, or failure

to get the car tested, sanctions are brought into play.

       For example, Senate Bill No. 231, enacted by the General Assembly

of the State of Colorado, makes the following provisions:

           42-4-312.  Periodic emissions inspection required.
       (1)  Beginning January 1, 1980, those motor vehicles spec-
       ified in section 42-4-307 (4),  for the model year 1977 and
       later models, which are registered in the counties of Adams,
       Arapahoe, Boulder, Denver, Douglas, El Paso, Jefferson,
       Larimer, and Weld shall be inspected once each year at
       twelve-month intervals, and an official certificate of
       emissions compliance shall be obtained for and displayed
       by each vehicle, except as otherwise provided in subsec-
       tion (3) of this section.

           (2)  Those motor vehicles required to be inspected
       under subsection (1) of this section shall be initially
       inspected during the calendar year in which inspection is
       first required as provided in subsection (1) of this sec-
       tion, and such motor vehicles shall then be required to
       obtain a certificate of emissions compliance.  The execu-
       tive director shall promulgate regulations to provide for
       the scheduling of said emissions inspections for said
       vehicles in approximately equal numbers during said
       calendar year and may provide for expiration dates applic-
       able thereto.

           (3)  New motor vehicles required by subsection (1) of
       this section to obtain the certificate of emissions com-
       pliance shall be issued such a certificate, without inspec-
       tion, to expire in the twelfth month after delivery or
       initial vehicle registration.  Prior to said expiration,
       said vehicles shall be required to be inspected and to
       obtain a certificate of emissions compliance which shall
       expire in the twelfth month after the month of inspection.

           (4)  Each certificate of emissions compliance shall be
       obtained during the calendar month respectively assigned.
       The certificate of emissions compliance shall be issued to
       expire in the twelfth month after the month of inspection,
       so that every motor vehicle registered in the designated
       counties shall be inspected during its assigned month in
       each calendar year.
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          (5)  The emissions inspection required under this sec-
     tion shall include an analysis of tailpipe exhaust gas
     emissions by means of an idle mode test to determine com-
     pliance with applicable exhaust gas emissions regulations
     adopted by the commission.

          (6)  Effective January 1, 1980, or later if so scheduled
     by regulations of the department, every motor vehicle of
     the model year 1977 or later registered in this state in a
     county not specified in subsection (1) of this section may
     be required, at least once each year at twelve-month inter-
     vals, to obtain and display a certificate of emissions
     exemption, but said vehicle shall not be required to be
     inspected therefor.  In addition to the issuance thereof
     by emissions inspection station licensees, the executive
     director shall by regulation provide for the issuance,
     by licensed safety inspectors or by other means, of said
     certificates under this subsection (6).  The executive
     director also may, by rule and regulation, prescribe
     methods of identifying pre-1977 model year vehicles not
     readily distinguishable from vehicles affected by this
     section.

          (7)  Every motor vehicle specified in subsections  (1),
      (3), and  (6) of this section shall be required to obtain
     and display a currently valid certificate of emissions
     inspection, as defined in section 42-4-307  (2), in such
     a position as to be visible from the outside of the
     vehicle and located on the vehicle in accordance with
     the rules and regulations of the department.

          (8)  The department may suspend the registration of
     any motor vehicle required to be inspected for emissions
     for which a certificate of emissions compliance has not
     been obtained.
B.3.7  AGENCY RESPONSIBLE FOR  IMPLEMENTATION

      Identification  of  the  agency  or  agencies  responsible  for program

 implementation  could be addressed  either  in the  Authority  section of

 an  I/M bill  or  under its own separate heading.   An existing department

 (e.g., "Michigan  Department of Transportation")  could be designated

 the sole  lead agency, or specific  responsibility could be  allocated
                                 B-20

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among different departments  (Department of Transportation, State
Police, Attorney General, etc.).  A third option does exist: creation
of a new department solely for this purpose.  The last option might
be difficult to implement due to growing public concern over the
increase in government bureaucracy.
     Most I/M states and localities have opted to delegate implemen-
tation responsibility to an  existing department.  The State of Rhode
Island provides in its legislation that "....on and after November 1,
1977, the Director of Transportation shall at least once each year,
but not more frequently than twice each year, require that every
vehicle, trailer, semi-trailer, or pole trailer registered in this
state or upon a retail seller's premises be inspected and that an
official certificate of inspection and approval be obtained for each
such vehicle...."

B.3.8  LICENSING OF PERSONNEL AND EQUIPMENT
     Legislative detail on the specifics of this issue varies from
state to state.  Some I/M legislation specifies licensing, training,
and monitoring of inspectors and the equipment used to test vehicles.
Other states leave this activity to the discretion of the designated
implementing agency.  An example of provision for the licensing of
inspectors is contained in the Oregon legislation, excerpted below.
         24-340 CRITERIA FOR QUALIFICATION OF PERSONS ELIGIBLE
     TO INSPECT MOTOR VEHICLES AND MOTOR VEHICLE POLLUTION CON-
     TROL SYSTEMS AND EXECUTE CERTIFICATES
        (1)  Three separate  classes of licenses are established
     by these rules.
             (a)  Motor vehicle fleet operations
             (b)  Fleet operation vehicle emission inspector
             (c)  State employed vehicle emission inspector
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     (2)  Application for a license must be completed on
a form provided by the department.

     (3)  Each license shall be valid for 12 months following
the end of the month of issuance unless revoked, suspended,
or returned to the Department.

     (4)  No license shall be issued until the applicant
has fulfilled all requirements and paid the required fee.

     (5)  No license shall be transferable.

     (6)  Each license may be renewed upon application
and receipt of renewal fee if the application for renewal
is made within the 30 day period prior to the expiration
date and the applicant complies with all other licensing
requirements.

     (7)  A license may be suspended, revoked, or not
renewed if the licensee has violated these rules or
ORS 468.360 to 468.405, 481.190 or 483.800 to 483.820.

     (8)  A fleet operation vehicle emission inspector
license shall be valid only for inspection of, and execu-
tion of certificates for, motor vehicle pollution control
systems and motor vehicles or the motor vehicle fleet
operation by which the inspector is employed on a full-
time basis, except as provided in subsection  (a).

           (a)  A fleet operation vehicle emission inspector
employed by a governmental agency may be authorized by the
Department to perform inspections and execute Certificates
of Compliance for vehicles of other governmental agencies
that have contracted with that agency for that service and
that contract having the approval of the Director.

     (9)  To be licensed as a vehicle emission inspector,
the applicant must:

           (a)  Be an employee of the Vehicle Inspection
Division of the department, or

          (b)   Be an employee of a licensed motor vehicle
fleet operation.

          (c)   Complete application.
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               (d)  Satisfactorily complete a training program
     conducted by the department.  Only persons employed by
     the department or by a motor vehicle fleet operation shall
     be eligible to participate in the training program unless
     otherwise approved by the Director.   The duration of the
     training program for persons employed by a motor vehicle
     fleet operation shall not exceed 24 hours.

               (e)  Satisfactorily complete an examination per-
     taining to the inspection program requirements.  This
     examination shall be prepared, conducted, and graded by
     the department.

          (10)  To be licensed as a motor vehicle fleet operation,
     the applicant must:

               (a)  Be in ownership, control, or management, or
     any combination thereof of 100 or more Oregon registered
     in-use motor vehicles, or 50 or more publicly owned vehicles
     registered pursuant to ORS 481.125.

               (b)  Be equipped with an exhaust gas analyzer
     complying with criteria established in section 24-350 of
     these rules.

               (c)  Be equipped with a sound level meter conform-
     ing to "Requirements for Sound Measuring Instruments and
     Personnel" (NPCS-2) manual, revised September 15, 1974, of
     this department.

          (11)  No person licensed as a motor vehicle fleet
     operation shall advertise or represent himself as being
     licensed to inspect motor vehicles to determine compliance
     with the criteria and standards of sections 24-320 and
     24-330.

     A similar requirement may be included in the licensing of test
equipment.  The State of Oregon legislation contains the most compre-
hensive licensing requirement found in the review.  The relevant
section is provided below as an example of the degree of detail pos-

sible on this issue.
                                 B-23

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  24-350 GAS ANALYTICAL SYSTEM LICENSING CRITERIA

     (1)  To be licensed? an exhaust gas analyzer must:

          (a)  Conform substantially with either:

               (A)  All specifications contained in the
document for Exhaust Gas Analyzer System Including Engine
Tachometers" dated July 9, 1974, prepared by the depart-
ment and on file in the office of the Vehicle Inspection
Division of the department, or

               (B)  The technical specifications contained
in the document "Performance Criteria, Design Guidelines,
and Accreditation Procedures For Hydrocarbon (HC) and
Carbon Monoxide (CO) Analyzers Required in California Of-
ficial Motor Vehicle Pollution Control Stations", issued
by the Bureau of Automotive Repair, Department of Consumer
Affairs, State of California, and on file in the office
of the Vehicle Inspection Division of the department.
Evidence that an instrument model is approved by the Cali-
fornia Bureau of Automotive Repair will suffice to show
conformance with this technical specification.

          (b)  Be owned by the licensed motor vehicle
fleet operation or the Department.

          (c)  Be span gas calibrated a minimum of once
a month (at least every 30 calendar days) by a licensed
inspector.  The calibration and the inspector's initials
are to be recorded on the back of the exhaust gas analyzer's
license for verification by the department.

     (2)  Application for a license must be completed on
a form provided by the department.

     (3)  Each license issued for an exhaust gas analyzer
system shall be valid for 12 months following the end of
the month of issuance, unless returned to the department
or revoked.

     (4)  A license for an exhaust gas analyzer system
shall be renewed upon submission of a statement by the
motor vehicle fleet operation that all conditions pertain-
ing to the original license issuance are still valid and
that the unit has been gas calibrated and its proper oper-
ation verified within the last 30 days by a vehicle emission
inspector in their employment.
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           (5)  Grounds for revocation of a license issued for
      an exhaust gas analyzer system include the following:
                (a)  The unit has been altered, damaged, or
      modified so as to no longer conform with the specifica-
      tions of subsection (1)(a) of this section.
                (b)  The unit is no longer owned, controlled,
      or managed by the motor vehicle fleet operation to which
      the license was issued.
                (c)  The department verifies that a Certificate
      of Compliance has been issued to a vehicle which has been
      emission tested by an analyzer that has not met the require-
      ments of subsection (1)(c) of this section.
           (6)  No license shall be transferable.
           (7)  No license shall be issued until all requirements
      of subsection (1) of this section are fulfilled and required
      fees paid.
B.3.9  RETEST POLICY
     This policy addresses the retest of cars that have failed to meet
the established emission standards.  Most states deal with test fail-
ures by having failed vehicles return for retesting after appropriate
maintenance within a prescribed time period such as 30 days.  A deci-
sion must be reached as to whether retest is to be provided free of
charge, or an additional fee is to be charged for this "second chance."
It was found that most I/M states, in order to minimize consumer resis-
tance, allow a free retest within the prescribed time period.
     Rhode Island has included the following phrase in its legislation:
"Any person whose vehicle has been inspected at an official inspection
station, shall, if such vehicle was not found to comply with the minimum
standards, have his vehicle repaired and have the right within twenty
(20) consecutive days, but not thereafter, to return such vehicle for
one (1) reinspection without charge."
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     Arizona legislation allows a somewhat longer period (30 days),
but reads essentially the same:  "Any person whose vehicle has been
inspected at an official inspection station, shall, if such vehicle
was not found to comply with the minimum standards, have his vehicle
repaired and have the right within 30 consecutive calendar days, but
not thereafter, to return such vehicle for one reinspection without
charge."
     In general, a second failure results either in a waiver of fur-
ther testing requirements or a stipulation that the vehicle owner must
pay for a second and, if needed, subsequent retests.

B.3.10  REPAIR COST LIMIT
     It is politically prudent and may enhance social equity to impose
"ceiling" on the cost of the repairs necessary to bring a vehicle into
compliance with test standards.  This limit should prevent excessive
financial hardship for low income drivers.  In some instances, the cost of
repairing a vehicle exceeds the vehicle'-a NADA Blue Book value.  A repair
cost limit also precludes the premature retiring of certain vehicles.
     A cost ceiling may be expressed in one of two ways, either as a
fixed value ($50, $75,or $100), or as a fixed percentage of the vehicle's
current market value.  The State of New Jersey places the following
limit on the repair of a vehicles for emission purposes.
           (b)  Whenever the estimated cost of emission compliance
      for reinspection exceeds one hundred dollars  ($100) for a
      vehicle 10 years or older, the owner of such vehicle may
      apply to the Department for a waiver of compliance present-
      ing the vehicle repair cost estimate from a licensed rein-
      spection center.  Such application must include vehicle
      license, make, year, date, reinspection center and mechanic's
      name.
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B.3.11  FLEET INSPECTIONS
     Fleets include vehicles in generic categories such as taxi-cabs,
rental vehicles, state vehicles, police vehicles, and any other groups
of vehicles which, as a class, are owned by private concerns or govern-
ment.  If the number of vehicles in a particular fleet is quite large,
it may be more cost-effective to have the fleet operator certify all
vehicles under his charge rather than to have each individual vehicle
driven to a testing station.  However, a criterion should be estab-
lished for certifying fleet vehicle inspectors in order to insure a
proper implementation of the intent of the law.
     Most I/M states have provided a section of legislation that deals
with the inspection of fleet vehicles.  Generally, a fleet is classi-
fied as having over 15 vehicles.  However, one state considers
that as few as three vehicles constitute a fleet.  Each of the states
justifies its provision for certified inspection by fleet owners on the
basis of the desire to minimize inconvenience to these owners and to
reduce the number of facilities needed.  However, each state realizes
that an essential element in the success of its fleet inspection pro-
gram is adequate supervision and related quality assurance.  Each of
the states has made provision for licensing of fleet inspection facil-
ities, surveillance procedures, and revocation of permit.
     The State of Rhode Island's approach is shown below.
           31-38-13.  FLEET OPERATORS. - Every person who shall
      provide maintenance facilities for the servicing of vehicles
      used in his business except licensed motor vehicle dealers,
      which facilities shall be approved by the Director of the
      Department of Transportation, and shall maintain such records
      and follow such procedures as shall be established by the
      Director, shall be qualified as an official inspection sta-
      tion for such vehicles.  Such person shall not issue inspec-
      tion certificates for any vehicle not used in the operation
      of such business.
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     The State of Arizona is much more circumspect in its regulation

of fleet inspections.  Chapter 158 of House Bill 2319 lists the fol-

lowing requirements for fleet inspections:

           36-1776.  Fleet emissions inspection stations;
                     certificates of inspection; dealer's
                     inventory; investigations; revocation
                     of permit

           A.  Any registered owner or lessee of a fleet of at
      twenty-five vehicles may apply to the director for a permit
      to establish a fleet emissions inspection station.  The
      director shall not issue any fleet emissions inspection
      station permit until he has found that the applicant:

               1.  Maintains an established place of business
      for the repair and maintenance of applicant's fleet of
      vehicles.
               2.  Has obtained approved machinery, tools and
      equipment to adequately conduct the required emissions
      inspections.
               3.  Employs properly trained and licensed per-
      sonnel with which to perform the necessary labor.
               4.  Agrees to provide data as may be prescribed
      by the director.

           B.  Any operator of a fleet emissions inspection
      station under a valid permit shall, upon filing an appli-
      cation in the manner and form prescribed by the director
      and paying the prescribed fee, receive a sufficient number
      of certificates of inspection for each vehicle in applicant's
      fleet.  No certificate of inspection shall be placed on
      or affixed to any fleet vehicle until it has been inspected
      and found to comply with all the minimum standards that
      such vehicle would be required to meet at any official
      emissions inspection station.

           C.  No holder of a fleet emissions inspection station
      permit shall inspect or certificate any vehicle for which
      such permittee is not the registered owner or lessee, unless
      authorized by the director.

           D.  Vehicles owned by a licensed vehicle dealer and
      which are held for resale as a part of the dealer's business
      inventory shall be deemed a part of such dealer's vehicle
      fleet for purposes of this section.
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           E.  Every vehicle over eight thousand pounds subject
      to the provisions of this section and registered in this
      state shall be inspected in accordance with the provisions
      of this article at least once within each twelve-month
      period following any original registration or reregistra-
      tion.  A vehicle shall not be reregistered until such
      vehicle has passed inspection.

           F.  The director shall investigate the operation of
      each fleet emissions inspection station as the conditions
      and circumstances of such operation may indicate.  He may
      require the holder of any fleet permit to submit such
      documentation required concerning the operation of such
      inspection station.  The director may revoke and require
      the surrender and forfeiture of any fleet emissions inspec-
      tion station permit and certificates of inspection of such
      permittee if he finds that such station is not operated
      in accordance with this article and the lawful rules and
      regulations adopted by the director or the holder of such
      permit has failed or refused to submit records or docu-
      mentation required.
B.3.12  REGISTRATION IN COUNTY OTHER THAN THAT OF RESIDENCE

      If the coverage of this program is not statewide and is limited

to certain counties, instances could result in which individuals or

fleet owners register their vehicles in a county other than that of

residence in order to circumvent the inspection requirement and thus

undermine the purpose of the I/M program.  This problem could be

alleviated by including a penalty provision in the legislation.

      The State of Arizona has done this in section 28.301.01 of its

Act:

           "Any person who registers a motor vehicle belonging
      to him in a county other than the county where he main-
      tains his permanent and actual residence with intent to
      evade the provisions of this article is guilty of a mis-
      demeanor; and any county assessor who registers a motor
      vehicle illegally for a person not residing in the county
      shall transfer any and all monies collected and retained
      by the county in connection with such registration to the
      county assessor of the county of such person's permanent
      and actual residence."
                                 B-29

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B.3.13  FEES

     Inspection fees are usually based on the premise that the fee

should be sufficient to cover the cost incurred to the state and/or

contractor plus, in the latter instance, a small profit.  This fee

structure is therefore intended to assure program self-sufficiency.

     Most states set a maximum fee for performing a vehicle inspection.

This fee usually allows for the cost of reinspection of an assumed

proportion of vehicles.  Arizona specifies the fee ceiling that will

be charged for inspection in the I/M legislation itself:

      "Emission Inspection Fees; Composition and Disposition

           A.  The director shall fix, regulate and alter in
      accordance with this section, the fees, not to exceed five
      dollars per inspection, required to be paid for the inspec-
      tion of every vehicle inspected pursuant to this article.

           B.  The director shall fix the fees, not to exceed
      five dollars per inspection.  Such fees shall be originally
      fixed and thereafter adjusted by the director to reflect
      the contractual charge payable in costs to the state of
      providing and administering emissions inspection services.

           C.  The fees charged for official emissions inspection
      shall be uniform as applied to each class of vehicle which
      shall be defined by the director.  Except for fees collected
      by the director pursuant to Section 36-1776, the inspection
      fee shall be collected with the registration fee by the
      county assessor at the time and place of motor vehicle
      registration pursuant to title 28, chapter 3, section 1,
      and:

               1.  The assessor of each county is constituted
      an agent of the department of transportation for the col-
      lection of the emissions inspection fee.
               2.  All monies received from inspection fees by
      the county assessor shall be immediately transferred by
      the collecting officer to the state treasurer and by him
      to the emissions inspection fund.

           D.  Any person whose vehicle has been inspected at
      an official emissions inspection station shall, if such
      vehicle was not found to comply with the minimum standards,
                                 B-30

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      have his vehicle repaired and have the right within thirty
      consecutive calendar days but not thereafter to return
      such vehicles for one reinspection without charge."

     Rhode Island's legislation deals with the issue of fees in the

following manner:

      "31-38.3  Inspection Fees;  Composition and Disposition.

           a.  The registrar (of Motor Vehicles) shall fix,
      regulate and alter in accordance with this section, the
      fees required to be paid for the inspection of every
      vehicle inspected pursuant to this chapter.  Such fees
      shall be originally fixed and thereafter adjusted by the
      registrar to reflect the contractual charge payable to
      any independent contractor as well as any increase or
      decrease in the costs to the state of providing and admin-
      istering inspection services.

           b.  The fees charged for official inspection shall
      be uniform throughout the state and shall be collected at
      the point of inspection.

           c.  Any person whose vehicle has been inspected at
      an official inspection station, shall, if such vehicle
      was not found to comply with the minimum standards, have
      his vehicle repaired and have the right within 20 calendar
      days, but not thereafter, to return such vehicle for one
      (1) reinspection without charge."
BS3.14  TIME OF IMPLEMENTATION

     A general implementation schedule should be included in the enabling

legislation.  Some states have implemented their programs in phases,

beginning with either a voluntary program, or a mandatory trial program

covering a small geographic area.  This approach can be instrumental

in gauging public response to a program in operation and to discover

and correct operational problems in the familiarization phase.  It

thus presents the opportunity for the public to become familiar with

the program before it is expanded to its fullest coverage.
                                 B-31

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     The State of California in Assembly Bill No. 4161 called for such
a phased program:

      It is, therefore, the intent and purpose of the legislature,
      in enacting this program to establish a demonstration pro-
      gram in Los Angeles, Orange, Riverside, San Bernardino,
      Santa Barbara, and Ventura Counties for the periodic inspec-
      tion of motor vehicles."

     Arizona initiated a one-year mandatory inspection program with no

required maintenance as a prelude to its general program.  The legis-
lation states:

          "A.  Pursuant to ARS  36-1772, all vehicles required
      by this article to be subjected to the mandatory vehicular
      emissions inspection shall be required to be inspected,
      but, from 12:01 a.m. on January 1, 1976 to 12:01 a.m. on
      January 1, 1977, shall not be required to pass inspection.

           B.  All vehicles required by this article to be sub-
      jected to the mandatory vehicular emissions inspection
     .shall be required to pass the inspections subsequent to
      12:01 a.m. on January I, 1977."

Section 36-1772 of the Arizona Revised Statutes is referred to by this

passage.  Section 36-1772 established I/M in Arizona.  Regarding pro-

gram commencement it states in Part A of this section that "such in-
spection shall commence in counties with a population in excess of
three hundred fifty thousand by January 1, 1976."


B.3.15  ANNUAL STUDY                                             '

     Even though administrative monitoring must be an ongoing aspect

of any I/M program, it is recommended that a comprehensive study be

performed annually.  The purpose of the study is to present an update

and status report to the legislature concerning the progress made

in achieving the intent of the program.  It is also to provide grounds

for making necessary revision(s) to the I/M legislation, or to make

specific corrections to alleviate certain problems.
                                  B-32

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     Some states have addressed this issue by authorizing an existing

agency to perform the annual review, whereas others have formed a

Commission for this purpose.  The State of California in House Bill

No. 4161 addresses this issue in the following manner:

           9889.59:   (a)  The department  shall conduct ongoing
      cost-benefit analyses and other evaluations of the inspec-
      tion program, including, but not limited to, observed
      patterns of malfunctions in inspected motor vehicles'
      emissions control and quantifications of reductions in
      vehicular emission in the geographical area subject to
      the provisions of this chapter, and recommendations for
      legislation to improve the inspection program.  The
      department shall deliver periodic written reports to the
      Legislature on such analyses and evaluations at least
      every 12 months commencing not later than July 1, 1978.

                      (b)  The department  shall study and submit
      recommendations to the Legislature  no later than July 1,
      1982, on whether the inspection program should be extended
      and, if so, to what extent to other areas of the state.

                      (c)  The Legislature shall create a joint
      committee to receive and evaluate the reports and recom-
      mendations submitted by the department to the Legislature
      pursuant to this section.  On the basis of such evaluation,
      the committee shall, from time to time, recommend to the
      Legislature supplementary legislation it deems advisable
      to facilitate motor vehicle emissions inspections.

     The State of Minnesota is presently  drafting I/M legislation.
The proposed Minnesota statute makes the  following provisions for
data collection and studies:

      "Subd.  2.   (STUDIES, DATA COLLECTIONS, ANNUAL REPORT.)

      The commissioner and the (pollution control)  agency shall
      collect data and undertake studies  as are necessary to
      evaluate the cost, effectiveness,  and benefits of the
      motor vehicle inspection program.   The director,  the com-
      missioner,  the commissioner of transportation and the
      director of the energy agency or their designees,  shall
      jointly constitute an advisory committee to consider among
      other issues related to motor vehicles inspection the
      following:
                                B-33

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      a.  the cost, effectiveness, and benefits of the inspec-
          tion program;
      b.  whether vehicles weighing over 8,500 pounds should
          be included in the inspection program;
      c.  whether mandatory inspection of motor vehicles should
          be extended to other areas of the state;
      d.  the desirability of certification, licensing, or
          bonding of repair facilities for the protection of
          the public; and
      e.  the desirability of allowing official inspection
          facility personnel to make minor adjustments with
          the consent of the motor vehicle owner.

      The director of the agency, or his designee, shall be the
      chairman of the committee.  The director and the committee
      shall seek information from the general public, consumer
      groups, environmental groups, and the repair and parts
      industry regarding these matters, and may establish an
      advisory committee on motor vehicles inspection if it deems
      advisable.  The agency shall report on these matters and
      the general operation of the motor vehicle inspection pro-
      gram to the legislature on or before January 1, 1982 and
      each four years thereafter."
B.3.16  TAMPERING

     This issue has been identified as critical in most legislation

reviewed.  States are intent on preventing individuals from physically

altering or otherwise thwarting the function of emission control equip-

ment, and on providing penalties for such tampering. Legislation has
been drafted in the State of Michigan to prohibit emission control

tampering.  The proposal, in part, reads as follows;

           Sec. 27.  (1)  A person shall not remove or render
      inoperative, or cause to be removed or rendered inoperative,
      an air cleaning device, or an element of an air cleaning
      device required to be installed on or in a motor vehicle
      engine or exhaust system by federal law or regulations.
      This subsection shall not apply to:

           A.  The repair or proper replacement of the air clean-
      ing device or an element of the air cleaning device.
                                B-34

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            B.  The installation of another air cleaning device,
       or element of an air cleaning device, if the device or
       element is certified by United States Environmental Pro-
       tection Agency as more effective than the original device
       or element in reducing the emission of air contaminants
       into the atmosphere.

            C.  A motor vehicle which is used exclusively for
       competition and is not operated on a public street or
       highway.

                      (2)  A person shall not advertise to remove
       or render inoperative an air cleaning device, or an element
       of an air cleaning device required to be installed on or
       in a motor vehicle engine or exhaust system by federal
       law or regulation, except for the purpose of replacing
       the device or element with an air cleaning device or element
       certified by the United States Environmental Protection
       Agency as more effective than the original device or element
       in reducing the emission of air contaminants into the
       atmosphere.

                      (3)  As used in this section, "motor
       vehicle" means a vehicle propelled other than by muscular
       power, except a vehicle which travels only upon rails or
       a tract.
     Section 203 of the Clean Air Act contains similar provisions

which basically are reflected in the Michigan proposal.  If this legis-
lation is enacted prior to the implementation of an I/M program, a
simple statement referring to the tampering legislation might be

sufficient.  The other option is to include tampering prohibitions

explicitly in the I/M legislation, thereby complementing or superseding
legislation in effect at that time.


B . 3.17  PENALTIES

     Provision for penalties is essential to the enforcement of any
program.   Without suitable penalties for violation, I/M regulations

would be ignored, thereby negating the intent of the legislation.  The
State of Rhode Island in Section 31-38-8 classifies violations of I/M

program regulations by severity:
                                  B-35

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      "31-38-8.  Penalties.

      a.   Except as provided in subsection (b)  of this
 section, any person who violates any provision of this
 chapter or any rule or regulation of the registrar adopted
 pursuant to this chapter,  is guilty of a misdemeanor.

      b.   Any person who makes or issues any limitation or
 counterfeit of any official certificate or certificates
 of inspection is guilty of a felony.

      c.   Any person who demands or collects a fee for the
 inspection of a vehicle other than the fee fixed by the
 registrar for the inspection of vehicles is guilty of
 a misdemeanor.

In the Minnesota legislation the following penalties are stipulated:

 "Section 9.   (PENALTIES.)   Subdivision 1.
 (a)   Any employee of an official inspection station or
 of a fleet inspection station who certifies a motor
 vehicle as in compliance without having inspected its
 equipment and mechanisms,  or who wilfully certifies a
 motor vehicle which has equipment and mechanism which do
 not meet or exceed the criteria and standards therefore,
 shall be guilty of a misdemeanor."

 "(b)  Any employee of an official inspection station who
 undertakes to furnish information to, recommend, suggest,
 or designate to a motor vehicle owner or operator, or any
 other person connected therewith, the name or any other
 description of a parts or repair facility or any other
 place where parts, repairs, or adjustments may be obtained
 to being a motor vehicle into conformance with inspection
 requirements, whall be guilty of a misdemeanor."

 "(c)  Any person who materially alters or changes any
 equipment or mechanisms of a motor vehicle that has been
 certified to comply with standards promulgated under
 this act, which causes the motor vehicle to be in non-
 compliance with the standards and criteria, shall be
 guilty of a misdemeanor."
                            B-36

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      "(d)  Any person who provides information to an inspection
      station on the extent or cost of repairs done to bring
      a motor vehicle into compliance with the standards promul-
      gated under this act, when such repairs were not undertaken
      or when the cost was not as represented, shall be guilty
      of a misdemeanor."
B.3.18  WARRANTY
     Some states have a special provision for warranty protection in
connection with emission equipment and/or repair work performed sub-
sequent to emission testing.  Most of the warranty provisions derive
from Section 207 of the Clean Air Act of 1977.  This section mandates
a new vehicle engine emission control warranty, which includes a general
defect warranty in 207(a),  a performance warranty in 207(b), and an
enforcement and recall provision in 207(c).
     Some states have included a simple warranty statement in their
legislation.  For example,  Section 7:27 - 15.8 of New Jersey's legis-
lation reads:
            (a)   Whenever a motor vehicle is rejected for emis-
      sions and if such model vehicle classification is not in
      compliance with a correlative test as determined by the
      Administrator of the Environmental Protection Agency, the
      cost of repair of such vehicle shall be borne by the
      manufacturer if the owner has complied by the manufacturer's
      warranty requirements for emission control.

B.3.19  EXCEPTIONS
     A tendency of existing I/M legislation is to exclude certain types
of vehicles from inspection procedures.  These exclusions are based
upon the predominant use of certain vehicles in off-road activities
(i.e., agricultural implements), on presumed low-use characteristics,
or on the difficulty for certain vehicles in meeting emissions inspec-
tion standards.  A partial list of exception criteria that have been
adopted in various states is presented below.
                                 B-37

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           •  Vehicle age    (Certain states have a "moving" exception;
              for example, Arizona exempts vehicles more than 13 years
              old in a given year.)
           •  Vehicle type    (Some states tend to exempt trucks with
              a gross vehicle weight of 8,500 Ibs or more.)
           •  Junk  (hobby) vehicles
           •  Vehicles for special use on private property, such as
              golf  carts
           •  Off-road vehicles
           •  Agricultural vehicles (tractors, trucks with farm plates, etc.)
           •  Special purpose transit vehicles
     Obviously, the more vehicle categories that are exempted from
testing, the greater the attention that must be directed to emission
standards for test  subject vehicles in order that overall emission
reduction goals are met.

B.3.20  VARIANCES
     Variance is another issue that should be addressed in a section
of I/M legislation.  If one make or model of a certain year is not
capable of repair,  retest or meeting established emission levels,
a variance could be granted for that particular make/model year vehicle
to remain out of compliance, rather than relaxing relevant standards
for engine displacement or age on account of that particular vehicle.
     The State of New Jersey is considering a regulation to amend its
existing I/M legislation.  The proposed regulation addresses the issue
of variances as follows:
      7;27-15.10  Cj.5.6] Variances
          Qa)  Whenever the Director, Division of Motor Vehicles,
      has reason to believe that any model year of vehicle  (or
      classification of light-duty gasoline-fueled vehicles)
      up to and including 1967 cannot comply with the emission
      standards as  set forth in Section 15.4, he shall so advise
      the Commissioner, Department of Environmental Protection,
      stating the manufacturer, model, year and classification
      of such vehicles.  After consultation with the Commissioner,
                                 B-38

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      Department of Environmental Protection, the Director,
      Division of Motor Vehicles, may waive any inspection
      standards for such motor vehicles 7J

            (a)  Whenever the Commissioner has reason to believe
      that any model year vehicle cannot comply with emission
      standards set forth in Sections 15.3, 15.4, and 15.5 of
      this Subchapter, he shall consult with the Director, Divi-
      sion of Motor Vehicles, stating the manufacturer, model
      year, and classification of such vehicle.  The Commissioner,
      after determining that compliance with emission standards
      as set forth above is not possible, may waive any emission
      inspection standard for such vehicle or establish alter-
      native standards for such vehicle.  Such waiver or alter-
      native standards may apply to any specific classification
      deemed necessary, be it by manufacturer, model year,
      engine displacement, etc.

            (b)  Whenever the estimated cost of emission compliance
      for reinspection exceed one hundred dollars ($100) for a
      vehicle 10 years or older, the owner of such vehicles may
      apply to the Department for a waiver of compliance pre-
      senting the vehicle repair cost estimate from a licensed
      reinspection center.  Such application must include vehicle
      license, make, year, date, reinspection center and mechanic's
      name.
B.4  SUPPLEMENTAL ISSUES

     If a state is considering implementation of an I/M program through

private contractor(s), four additional issues should be addressed in

the legislation.  These issues are discussed below.


B.4.1  ESTABLISHMENT OF CONTRACT WITH PRIVATE CONTRACTOR

     If an emission testing program is to be operated by a private

contractor, the state agency directed to administer the program should

also be empowered to let bids for a contract for services and to select

and enter into contract with the successful bidder.  The State of Arizona

in Chapter 158 of House Bill 2319 dealt with this question as follows:
                                 B-39

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           "36-1775.  Agreement with independent contractor;
      qualifications of contractor; agreement provisions.

           A.  The Director is authorized to enter into an
      emissions inspection agreement with one or more indepen-
      dent contractors subject to public bidding, to provide
      for the construction, equipment, establishment, mainten-
      ance and operation of an official emissions inspection
      stations in such numbers and locations as may be required
      to provide vehicle owners reasonably convenient access to
      inspection facilities for the purpose of obtaining compli-
      ance with this article and the rules and regulations adop-
      ted pursuant hereto."
B.4.2  MONITORING OF CONTRACTOR PERFORMANCE

     It is imperative that the State retain the authority to observe

the activities of the contractor at all times as a quality control

mechanism.  Contractor monitoring enhances program acceptance by the

public in a context in which there is distrust of the auto repair

industry and related enterprises, no matter in what capacity.

     The state of Arizona provides for contractor monitoring including

it in the description of the State's authority and by powers over the

private test station operator:

      "... 3. The minimum requirements for adequate staff, equip-
      ment, management and hours and place of operation of
      official emissions inspection stations.  4.  The submission
      of such reports and documentation concerning the operation
      of official emissions inspection stations as the director
      may require.  5.  Surveillance by the Department of Health
      Services to ensure compliance with vehicular emissions
      standards, procedures, rules, regulations and laws.
      6.  Any other provision deemed necessary by the Director
      for the administration of enforcement of the emissions
      inspection agreement."


B.4.3  CONFLICT OF INTEREST

     It is essential for purposes of consumer protection that a con-

tractor operating an I/M program shall not stand to profit by an increase

in the number of vehicle failures.
                                 B-40

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Licensing of Authorized Station Required
                                                i
The Department of Motor Vehicles shall investigate any
applicant for an authorized station license, and before
an applicant for an authorized station is approved, an
inspection of the premises will be made by an authorized
representative of the Department of Motor Vehicles.

No license shall be issued to an applicant unless the
applicant employs at least one approved inspector, who
may be the station owner.

All inspections must be performed only at the established
place of business using an approved exhaust gas infra red
analyzer and diagnostic equipment.

The authorized station license and all other licenses
issued to approved inspectors shall be displayed in a
conspicuous place under glass or other transparent mater-
ial within the authorized station.

Authorized station shall be required to keep attached to
their infra red analyzer manufacturer's quick reference
guides for hookup and testing procedures for their infra
red equipment.

Application, Fee for Authorized Stations;  Issuance of
License Certificate

Application for an authorized station license shall be
filed upon forms supplied by the Department of Motor
Vehicles, and the applicant shall furnish:

     Such proof as the Department of Motor Vehicles
may deem necessary that the applicant qualifies as an
authorized station, including proof that the applicant
has an established place of business in this State:

     Fee of $25.

License expires at midnight on December 31 of each calen-
dar year.

Upon receipt of such application, when satisfied that the
applicant is entitled thereto, the Department of Motor
Vehicles shall issue to the applicant an authorized station
license certificate containing the station's name and the
address of his fixed place of business.
                           B-41

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     Most states employing a private contractor for vehicle inspections
specifically prohibit the contractor from repairing or maintaining
failed vehicles.  Section 9889.52, Part C of the California legislation
notes that "...A private entity operating any portion of the inspection
program shall not have any financial interest in any automotive repair
station located within the geographical area in which the program is
being conducted."
     Section 4 of the pending Minnesota legislation decrees that
"...The agency shall not contract with any person who is engaged in
the business of selling, maintaining, or repairing motor vehicles or
selling motor vehicle replacement or repair parts at retail in this
state, except that the contractor may repair any motor vehicle owned
or operated by the contractor."  Subdivision 2 (repairs) states, "The
word 'inspection' as used in this section shall not include repairs
and adjustments.  Repairs or adjustments necessary to bring a motor
vehicle into conformance with the criteria and standards under this
act shall be the responsibility of the motor vehicle owner and may be
made by the owner of any repair facility of his choosing."

B.4.4  LICENSING OF INSPECTION FACILITIES
     Some section of I/M legislation should ensure that if private
garages are to be utilized as inspection stations, then only those
garages having proper equipment and qualified personnel to inspect
the vehicles will perform inspections.  The state of Nevada, in which
the I/M program is based on the existing private garage system, pro-
vides an excellent example of appropriate legislative provision for
the licensing of inspection facilities.
                                  B-42

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         APPENDIX C




PUBLIC INFORMATION STRATEGIES

-------
                           APPENDIX C
                 PUBLIC INFORMATION STRATEGIES

C.I  OVERVIEW
     An I/M program, by virtue of its impact on the habits of society,
creates a climate in which people may be intensely sensitive to the
issues, and which can turn quickly and radically negative if communi-
cations between responsible government officials and the general
public are poor.  I/M procedures to the layman may seem tortuous and
protracted; strategies and policies may be framed in terms that are
intelligible only to experts.   If program implementation is handled
clumsily, the government authority may ultimately be perceived as a
dehumanized technocracy, indifferent to opinion and unresponsive to
protest.  Within the context of representative government, I/M is
one of those areas in which the need to create and maintain a good
relationship with the public is self-evident.
     Communications are the essential element in this program; they
form the bridge which will act as a framework for participation and
allow the exchange of attitudes and ideas between the general public
and the government officials.   The term "public relations" embraces
the set of activities involved in the communication of issues, poli-
cies, and operations to a constituency.  Publicity is only one facet
of these activities, and a great deal of interactive public relations
work needs to be done at the grass roots level prior to the implementa-
tion of any I/M program.  A properly implemented public relations effort
prior to instituting an I/M program will facilitate the phase-in of
such a program in the State of Michigan.
     This section is intended to be a guide for effective public rela-
tions toward successful implementation of an I/M program in the State
of Michigan.  Its purpose is to put public relations in perspective,
to explain various public relations techniques, and to show how these
can be used in the course of an effective public relations campaign.
                                 C-l

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Only a framework of activities for the campaign effort is
presented, in that a public relations expert could easily expand on
the ideas expressed and tailor them to Michigan conditions.  Techniques
are consistent with and in most cases seek to amplify procedures dis-
cussed in EPA's draft Expanded Guidelines on Public Information and
Involvement in the Transportation-Air Quality Planning Process (June 1, 1979).

C.2  THE FUNCTION OF PUBLIC INFORMATION
     Prior to proceeding with a discussion 'of the actual public infor-
mation program, a general description of the function of various
elements of a public information program might be appropriate.  Figure C-l
represents a typical public information/relations flow chart.
     This functional flow chart starts with the media.  The term "media"
means all forms of communication reaching the public, including radio,
television, newspapers, magazines and mail advertising, which influence
public perceptions and decisions.  "Public" means every individual,
organization, or group whose attitudes or opinions can affect the success
of a program.  It includes the general public, which in this context
refers to unorganized and special-interest groups.  The effect of the
media on the general public depends on two things - the existing attitudes
of the public and the nature of the ideas or messages reaching the public.
     Progression of a public relations campaign from media effort to
action posture is a multi-step procedure as shown in C-l.  The ideas or
messages reaching the public influence their attitudes and are transformed
into opinion, which may be favorable or unfavorable.  Public opinion about
any organization or program is a key factor in the Integration of the
Organization (or Program) with its Environment.  Public Information
policies are formed from the recommendations made in this step.  These
recommendations go on to Management, where results depend on the
Organizational Characteristics and Intervening Variables.  All variables
are integral to the decision made by the organization responsible,
                                 C-2

-------





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whether it be tor determination of a policy and program for making
decisions known, or otherwise.  The last step, Action » is obviously
the pivotal point of the process.  The quality of the communication
and the effectiveness with which it carries the organization's message
to the various publics «re vital points of the public information function.
     From the posture and behavior of the organization - and from its
outbound communication - a Feedback through to Media develops.  The
process is continuous, self-adjusting, and each link is part of this
Public Information/Relations Flow System.
     Some of the steps mentioned in the discussion above have already
been undertaken by the Michigan Department of Transportation.  They
include the definition of the objectives, the formulation of the central
ideas, and the formulation and conduction of an opinion poll.  There
are essentially four remaining elements which need to be resolved in
order to catalyze public acceptance of an I/M program.  These decisions
concern:
          1.  Who should be the target(s) of a public relations campaign;
          2.  How should they be approached;
          3.  What information is important; and
          4.  When should this campaign commence in relation to the
              implementation of the I/M program.  These issues are at
              the focus of discussion below.

C.2.1  IDENTIFYING THE PUBLIC:  TARGET GROUPS
     A community should be considered not merely an aggregation of
citizens living in the same general area, but as a set of groups who
share certain values, ideas, and a sense of what the future should be.
We are to consider those societal values pertaining to the ownership
and operation of a motor vehicle.  This criterion identifies a target
group - all residents except those under the age of 18.   This, of course,
targets a very broad cross-section of the public for the campaign.
                                 C-4

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     Any targeted public can be divided into two groups - organized
and unorganized.  It is easier to identify and direct an approach to
the organized group.  Unorganized groups may be accessible only through
a mass media strategy.
     The group that should initially be targeted is the employees of
the State of Michigan.  This group can be reached at minimal cost,
and the propagational benefits deriving from such an informed core
of supporters can be substantial.  That is, a program of sound internal
communication will not only stimulate and maintain employees' interest,
but can also make them better public relation representatives to the
rest of the community.
     Section F.2 of EPA's draft Public Information Guidelines cites
identification of and interaction with "affected and interest con-
stituencies of the public" as an essential element of an effective
program.  Government agencies are encouraged to tap and build upon
the contacts and expertise of such groups in a close working relation-
ship.  There are many private and public organizations that should be
targeted in the public information effort.  These groups should be
made acquainted with the potential detrimental effects of air pollution
on individual health, the part that an effective I/M program can play
in the reduction of air pollution, and other expected benefits such
as fuel savings and warranty protection.  Candidate organizations
should include chapters of nationally-oriented groups such as Lung
Associations as well as locally-based groups such as individual Chambers
of Commerce.  Groups that should be involved from the early stages of
a public relations program for Michigan are listed below.  Early
targeting need not, however, be limited to these organizations.
ORGANIZATIONS INVOLVING ELECTED OFFICIALS
     Michigan Municipal League
     Michigan State Legislature Board
     National Association of Counties
    (Other Associations of Elected Officials)
                                  C-5

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PUBLIC INTEREST GROUPS
     League of Women Voters of Michigan
     Michigan Citizens Lobby
     Michigan Health and Safety Institute
     American Lung Association
     Sierra Club of Michigan
     Consumer Protection Organizations

AUTOMOBILE-RELATED GROUPS
     Michigan Automobile Dealers Association
     Automotive Service Council of Michigan, Inc.
     Automobile Club of Michigan
     American Academy of Transportation
     Michigan Trucking Association

CIVIC GROUPS
     Local Chambers of Commerce
     Jaycees
     Kiwanis
     Urban League
     NAACP
MEDIA
     Local Newspapers
     Local Radio Stations
     Local Televisions Stations
     Radio-Television News Directors Association
LABOR GROUPS
     United Auto Workers
     AFL-CIO
                                  C-6

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C.2.2  HOW TO ENLIST HELP FROM GROUPS
     The groups identified above could be contacted directly, possibly
on an individual basis.  It should be recognized that each of these
groups is devoted to a relatively specialized purpose, so the campaign
might be tailored to the special interest of each.  Some of the groups
might distribute appropriate I/M literature through regular mailings,
while others would invite a guest speaker to a regularly scheduled
meeting, presenting the opportunity for direct interpersonal dealings
with membership.  Whatever the approach, establishment of liaisons
and informational exchanges with these groups is probably the most
cost-effective strategy with respect to benefits derived (public reached)
versus expenditures incurred.  Listed below are some additional activities
that could be undertaken in the interest-group setting.
          - Workshops, seminars, and public meetings arranged through
            the interest group.
          - Where meetings are infeasible, provision of I/M literature
            through the mail.
          - Presentations before public meetings where air quality
            is a topic of discussion.
          - Distribution of materials through trade or organizational
            publications and newsletters.
          - Screening of the American Lung Association/EPA film "On the
            Road to Clean Air" at various meetings.
          - Sponsoring of contests with air quality and I/M in particular
            as the central theme.

 C.2.3  CONVEYING THE MESSAGE TO A BROADER AUDIENCE
     Beyond the special group focus, a public relations campaign must
succeed in informing a much larger, more amorphous class of citizens,
the general public.  There are different techniques for this purpose,
ranging from newsletters, brochures, direct mailings, and poster displays
to the mass media of newspapers, magazines, television, and radio.  It
                                  C-7

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is here, particularly in the latter categories, that the greatest
expense of mounting a campaign is likely to be borne.
     •  Newsletters-- A newsletter can be a mechanism for regular
communication to relatively large audiences.  Its purpose is to sustain
the interest and involvement of its recipients in the issues it addresses.
An I/M newsletter should be mailed on a scheduled basis and cover
the status of current I/M prospects and/or programs.  For a program
already adopted, the newsletter should provide testing locations,
their hours of operations, features on the experience of drivers who
have had their cars tested, and other relevant material.  The most
significant cost of producing such a newsletter is not the publishing
cost, but the mailing cost.  Mailing costs may be minimized by using
bulk-rate rather than first-class postage.  In general, however, the
overall cost does make this a prohibitive alternative for public at large.
     •  Brochures -Brochures, pamphlets or booklets are an important
medium for dissemination of information in states that now have
I/M programs in force.  The major difference between
a newsletter and a brochure is that a newsletter is published on a
regular calendar basis, whereas a brochure is a single publication
that, if carefully constructed, may be adequate for the life of an I/M
program.  Preparation of a brochure that intelligibly explains the
why and how of an I/M program in Michigan may be a critical milestone
in ultimately achieving the goal of enhanced public acceptance.  At a
minimum, the brochure should present the purpose of the selected I/M
program, its benefits, the locations of testing facilities, hours of
operation, an explanation of quality assurance mechanisms, and a section
in question/answer format addressing known or anticipated public concerns.
The responsible organization might consider updating the brochure at
yearly intervals, or even more frequently.
     The methods of disseminating these brochures range from inclusion
with mailed notification to vehicle owners of the annual vehicle
                                  C-8

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registration requirement, to open distribution at shopping centers,
gasoline stations, repair garages and other locations frequented by
the driving public.  These methods tend to keep distribution costs low.
  • Mass Media. -   Mass media probably provide the best mechanism
for reaching the braodest possible segment of the public.  Mass media
include newspapers, wire services, television, radio, trade journals
and magazines.   There are several techniques for deploying these tools
to obtain favorable publicity.
     • General News Release - This is the basic, and perhaps the most
widely used, method of obtaining publicity.  News releases should be
delivered to editors of local papers well ahead of the time desired
for their presentation to the public.  Any release should include a
newsworthy item which justifies it.  This may be a compendium of new
test or study results, official statements, views or other material
which could be used in the formulation of a feature story should an
editor so desire.
     • News Conference - The news conference has become a very popular
technique for the dissemination of official views and public information.
The appearance of state officials, such as legislators or the Governor,
in a context supportive of I/M program generates favorable publicity.
Experience in other states has indicated that pictorial coverage of a
high public official  (e.g., Governor Milliken) in the process of having
his car inspected is an inestimably important selling point for I/M.
Publicized debate or seminars also attract needed attention.
     • Featured Article - A feature article covers a subject much more
thoroughly than a straight news announcement.  The interest of a feature
writer in the topic of I/M may be whetted by providing him or her with
frequent notices about programs and prospects.  To follow up, the writer
would seek additional information for his article, thus assuming the
burden of in-depth evaluation.  More pointedly, if a writer is on record
as expressing a particular interest in environmental issues, then he or
she might be encouraged to devote favorable articles to the I/M issue.
                                C-9

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     The broadcast media should be utilized differently from the print
media.  News releases and conferences and even general news broadcasts
are limited with respect to the audience reached.  Fortunately, Federal
Communications Commission (FCC) regulations provide automatic access
to a large, random cross-section of the public.  The FCC requires radio
and television stations to make commercial time available for public
service announcements.  This free time should be used to as great an
extent as possible.  Spot announcement slots are usually available in
10, 20, or 30 second increments.  The EPA has prepared several public service
announcements covering I/M and ozone-health effects topics which fit
these slots and which may be obtained free of charge through regional
offices.  Unfortunately, due to the large demand for public service
announcement time, the number of I/M announcements that could be pre-
sented is limited.  Moreover, public service announcements are often
presented at marginal viewing hours (between midnight and 7 a.m.).
Because the scheduling of these announcements is at the discretion of
each station, not much can be done about this.   It has been suggested,
however, that stations tend to broadcast those announcements which are
interesting and eye-catching more frequently, often in prime time.
      • Direct Advertisement - All of the publicity measures mentioned
previously are competing with perhaps hundreds of other publicity items
which are considered to be important by their sponsors.  With the
proliferation of these announcements, the I/M message is often lost.
Therefore, in order to carry out a complete public information program,
advertising space in newspapers and commercial slots on television and
radio must be purchased.
     Table C-l presents the estimated cost or resource requirements of
various advertising media.  The figures are based on national averages.
                                 C-10

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       Table C-l.  INITIAL/ONGOING PUBLIC INFORMATION PROGRAM FOR ONE YEAR
                                    HYPOTHETICAL LOCATION
PROGRAM TYPE


ADVERTISEMENTS

    1.  Public Service Announcements

        Newspaper


        Television


        Radio
    2.   Pamphlet
        Development/preparation

        Printing
    3.   Bumper Sticker
    4.   Transit Aids
COST DESCRIPTION
Full page advertisement 172-inch
@ 1.65 per inch.

1-minute announcements @ $40 per
per 10-second or $240 per minute.

1-minute announcements @ $200
per minute (includes radio and
commission).
Artist (logo and cover design)
plus commission @ 20 hours.

Pamphlet printed on 20 Ib paper,
1 color, foldout 7%" x 11"
6 million copies).

Printed on 6 Ib all weather paper,
1 color.  $60,000/4.5 mil. veh.

Space cost on 35 buses, $102 per
month per bus (both sides).
                                     C-ll

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C,3  OVERALL PROGRAM COSTS
     The cost of a public information program is largely a function
of its location and breadth of coverage.  Hamilton Test Systems, Inc.,
under contract to the State of Arizona, considers $0.12 per vehicle
as an adequate investment for an effective public information program.
This figure includes the initial and ongoing cost of production and
distribution of brochures, radio spot announcements, and news coverage.
However, this allocation may be low for 1979, because the publicity
effort on which it was based was completed several years ago, and the
ongoing Arizona effort is minimal.  Therefore, computations have been
utilizing alternative figures.  These figures are presented in Table C-2.
For the purpose of this study, costing of the public information effort
assumes a value of $0.25 per vehicle (last row of the table).
     For an example funding mechanism, one might again cite the State
of Arizona, which has included provision for the public information
program cost in its testing fee structure and has thereby recovered
these costs automatically.  The State of Michigan might consider a
similar mechanism.  To supplement, Section F.7 of the draft EPA Public
Information Guidelines recommends the allocation of 20 to 30 percent
of funds authorized under Section 175 of the Clean Air Act as Amended
to organizations directly responsible for promulgation of public aware-
ness in nonattainment areas.  The total amount of these funds will
vary as a function of nonattainment area population and severity of
the air pollution problem.
     These public information costs are not total costs and should be
apportioned among selected available publicity measures in order to
gain the maximum exposure for the money expended.  Table C-3 suggests
a possible breakdown of the public information budget.  This breakdown
was arrived at after consulting various advertising agencies.  However,
the local situation should be taken into consideration when deciding
to allocate resources among various media.  For example, if an area
does not have a local television  station, but is instead served by
radio and newspaper, then television's  share might be split between
                                 C-12

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Table C-3.  PUBLIC INFORMATION
            RESOURCE ALLOCATION
TYPE
Presentation
Film
Slide Show
Guest Speaker
Newspaper
Television
Radio
Pamphlet
Bumper Sticker
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10
5
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              C-14

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Table C-4.  VARIOUS ALLOCATIONS VS POSSIBLE METHOD OF ADVERTISEMENT



                         IN THE DETROIT AREA
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PRESENTATION
Film
Slide
Guest
NEWSPAPER
TELEVISION
RADIO
PAMPHLET
BUMPER STICKER
TRANSIT ADS
OTHER
0.12
30,000
2,000
68,640
62,670
83,560
29,840
14,920
23,870
8,950
0.15
30,000
2,000
87,640
80,010
10,670
38,100
19,050
30,480
11,430
0.20
30,000
2,000
119,300
108,930
145,240
51,870
25,935
41,500
15,560
0.25
30,000
2,000
150,970
137,840
183,790
65,640
32,820
52,510
19,690
                                C-15

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these two available outlets.  Table C-4 presents an example budget
for the Detroit nonattainment area based on the figures from Tables C-2
and c-3.  The same rules would apply to budget computations from the
other nonattainment areas.

C-4  IMPLEMENTATION SCHEDULE
     In order to maximize the likelihood of positive public acceptance
of an I/M program, a public information campaign should be phased in
systematically over a period of time.  Failure to allow for appropriate
phasing may render the entire public relations outlay futile.  A public
relations program commenced prematurely can exhaust available resources
early, rendering pursuit of the campaign impossible at its most critical
period - that of I/M implementation.  Conversely, a program commenced
at an advanced date of I/M development might not be able to neutralize
the suspicions or hostilities of the general public to an extent suffi-
cient to make I/M politically tractable.
     Based on discussions with professional publicists and with officials
in the State of Arizona, a public information timetable has been completed
for Michigan.  This timetable is presented in Figure C-2.  This
timetable pertains only to the official preimplementation campaign
conducted pursuant to obtaining necessary I/M enabling legislation.
It should be noted that the State of Michigan has instituted and will
continue to pursue an active public awareness effort prior to legislative
adoption of I/M, for the purpose of communicating to the citizens of
the State just what I/M is, why it is needed, and what will be its
trade-offs.  This effort is undertaken jointly with public and special
interest groups statewide.  Because the effort is wholly within the
context of established structures and budgeting arrangements, no
special costs are assigned.
     In general, it is recommended that the preimplementation infor-
mation campaign be initiated 12 months prior  to  the actual imple-
mentation of the I/M program.  Campaign activity should be most intense
                                 C-16

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immediately prior to the implementation of the program, at the point
at which the program is implemented, for 2 or 3 months thereafter,
and finally at the conclusion (results phase) of the program.
     Most publicity efforts should focus on health topics.  There are
activities that should be ongoing, such as distribution of brochures,
public service announcements, and reminders for testing of vehicles.
It is also recommended that an annual progress report be presented
to the public in the media, commending citizens on their contribution
to the reduction of the pollution problem.  This can create an aura
of good will and a feeling of meaningful participation by the public
at large, which ultimately enhances receptiveness to any program
which requires private inconvenience for the common good.
                               C-18

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            APPENDIX D




MECHANICS TRAINING FOR VALID REPAIR

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                           APPENDIX D

                 MECHANICS TRAINING FOR VALID REPAIR
D.I  OVERVIEW
     The quality of repairs is the major factor contributing to
the success of a vehicular emissions I/M program.  An adequate
number of  trained mechanics is necessary in  order  to properly
repair vehicles that  fail the emissions inspection.
     The complexity of emissions control systems has been increasing
almost annually, resulting in a severe burden on mechanics in the
field, who must constantly update their knowledge  of new systems and
techniques of repair.  However, regular enhancement of mechanics'
knowledge of emission control systems has not generally been the case.
The result of this shortfall of knowledge is substandard repair on
the motor vehicles, which in turn results in widespread public dis-
satisfaction with and often mistrust of the repair industry.
     Public dissatisfaction may be expected to grow when an I/M pro-
gram is implemented, and some vehicle owners find that they must have
their cars or trucks retested two or three times due to the inferior
quality of work being performed by some mechanics.  In order to
avoid general public unrest and to improve the quality of emission
system repair, a mechanics training program should be considered by
the State of Michigan.

D.2  EXISTING CONDITIONS
     The State of Michigan has empowered into law Act No.  300 of  the
Public Acts of 1974, generally known as the  "Motor Vehicle  Service
and Repair Act."  This act was passed for the purpose of regulating
the motor vehicle repair and  service industry.   The Act requires  each-
repair facility to have at least one specialty o>r master mechanic
in its employ who is certified in each category  of repair  that  the
facility provides until December 31, 1980.   Thereafter,  all mechanics
doing major repair work must be certified.   Persons wishing to become
certified may obtain a mechanic trainee permit and perform major repairs
under the direct supervision of a master mechanic.
                                  D-l

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     One of the"repair categories is vehicle tune-up, which in most cases
includes general emissions-related work such as carburetor adjustment,
PCV valve replacement, charcoal canister replacement and so forth.
However, some aspects of tune-up have been classified as minor repairs
which need not be performed by a specialty or master mechanic.  Some
of the emission-related components that are classified as minor repair
items include:
                    - Air cleaner element
                    - Air pump belt
                    - Air pump hose
                    - Fuel filter element
                    - Fuel filter and associated lines and hoses
                    - Crankcase closed vent valve
                    - Crankcase vent air cleaner
                    - Crankcase vent air cleaner hose
                    - Exhaust pipe and associated attaching parts
                    - Vapor canister hose
     Section 12 of the Act requires an applicant to have passed an
examination designed to test competency in the specific category for
which the applicant is applying.  Section 13 of the Act provides for
mechanic trainees.  This section requires the administrator to
...."Establish and operate a mechanic trainee training program designed
to provide the training necessary to become certified under this Act.
Instead of establishing and operating the program, the administrator
may appoint schools, academies, or other similar establishments to
engage in mechanic trainee training if those establishments, schools,
or academies meet the criteria established by the administrator, after
consultation with the Department of Education and the United States
Department of Labor, Bureau of Apprenticeship and Training.  The
establishments may be designated by the administrator to engage in
a continuing education and training program for specialty and master
mechanics."
     It is apparent from the review of existing legislation that the
State of Michigan has provided for certain aspects of a mechanic training
program.  Although the legislation was written to cover motor vehicle
repairs as a whole, more emphasis will probably be needed on the
emission-related equipment.
                                 .D-2

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D.3  METHODS OF MECHANIC TRAINING
     Various approaches have been utilized by different states with
I/M in effect toward instituting a mechanics training program.  These
efforts have ranged from a government-sponsored mechanics training
program in the State of Arizona to no program at all in the City of
Chicago.  The State of Arizona is considered the pioneer in implemen-
tation and coordination of mechanics training for emission control
repair.  Some of the methods suggested below have been utilized by
Arizona, whereas others are in use or have been proposed for other
areas.
       * Workshops - These workshops should involve vocational
         education instructors, and be carried out several
         months prior to the implementation of the I/M program.
         Topical coverage should include the diagnosis and
         repair of emission control equipment.  The desired
         effect of such a program is that knowledge of proper
         repair procedures "pyramids" downward from workshop
         participants to trainees in the vocational education
         classes they conduct.
       9 Training Clinics - The intention of training clinics is
         to inform both mechanics and the general public.  It has
         been the experience that these clinics are in greatest
         demand during the early stages of the program.  The
         clinics should be about 4 to 5 hours in length and should
         present both the theoretical aspects of repair and the
         opportunity for actual "hands-on" experience.
       • Mini-schools - The "mini-school" concept is very similar
         to that of the training clinics, with the exception that the
         mini-school program would be taken directly to the prac-
         tising mechanic in the field.  That is, sessions are
                                  D-3

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         conducted in larger private repair facilities with
         the cooperation of employers.   This method provides
         the greatest possible access to the state-of-the-art
         methods and maximum participation opportunity for the
         practicing mechanic without making an exceptional
         demand on his or her time.
       • Fleet Mechanic Training and Certification Program -
         This program should be designed to qualify fleet
         mechanics for emission repair.   These mechanics
         would be licensed to perform maintenance on vehicles
         in private or public fleets.  Arizona designed a program
         which takes two days and which requires a passing grade
         on an examination at the conclusion of the course.
         Once licensed, the fleet mechanic is annually required
         to attend a half-day refresher course and to pass a
         recertification test.
       0 Vocational Course - Auto mechanics courses are regu-
         larly offered in the public schools and are usually
         taken by students seeking basic maintenance and repair
         skills.  Material relating to emission control equip-
         ment should be emphasized in order that new mechanics
         entering the field will have appropriate background
         sufficient to enable the repair industry to handle
         the increased demand due to I/M.
     An additional source of mechanics training, the automobile industry
itself,has not been included in this discussion because it has tradi-
tionally provided advanced training courses to certify its own repair
personnel.  However, it should be noted that the automotive industry
has recently begun to play a very active role in training its mechanics
for emission repair in programs that include updated bulletins and
schools.
                                   D-4

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D.4  APPROACH TO MECHANICS TRAINING
     A comprehensive approach is projected for the mechanics training
program in the State of Michigan.  A two-phase program has been pro-
posed by state officials.  The first phase will be devoted to the need
for identification and the training of the instructors, while the
second phase will be devoted entirely to the actual training of mechanics.
     The rationale for this recommended two-phase program is the fact
that a great deal of information on emission control systems currently
resides with automobile manufacturers and dealers and service station
personnel;  however, much of this information is so fragmented or
unsystematically organized that the appropriate use cannot be made
of it.  Furthermore, classes for emission control systems are currently
offered at community, state and private colleges, technical schools,
and even in the high schools of Michigan.  The result is redundancy
or even competition among schools in a given geographic area.  Due to
these and other problems, it was deemed necessary to determine the
actual locations where emission control systems are presently taught,
the comprehensiveness of instruction, and the extent of practical
knowledge gained that is translated into improved quality of service
provided by participating mechanics.  It would also be necessary to
determine whether a given training course emphasizes theory or prac-
tical experience.
     At the conclusion of this state-of-the-art survey, a format would
be developed along with the materials and teaching methods for an
instructor's course.  A possibility exists that the materials presently
used might be reassembled into a format suitable to transmit to a
teacher of emission control courses, thereby saving course development
costs.
     The last task of Phase I would place emphasis on upgrading the
knowledge of the instructors  themselves.  One or more training sessions
                                  D-5

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for instructors could be taught by Michigan personnel or by Colorado
State University staff, who have had considerable experience in this
field.  The cost for these training sessions could be defrayed in
either of two ways.  The first, obviously, is to charge the instructors
a fee for attendance.  However, in order to encourage participation,
the second alternative is that courses would be provided free of charge
to participants with EPA, local MPOs,or the state itself funding the
program.  Provisions would have to be made for refresher (update)
classes or bulletins to keep instructors at the state-of-the-art tech-
nical levels after the initial training course.
     The second phase of this program would be directed toward training
of mechanics in the vocational and technical schools, community and
other colleges in those areas of Michigan in which an I/M program will
be implemented.  This would be done either through a series of state-
sponsored workshops or clinics, or through an intensive effort to
encourage vocational schools and community colleges to offer courses
on automobile emission control.  The approach utilized in these
courses should familiarize the mechanics with emission control systems
in a generic sense rather than on an individual basis.  However,
materials should be provided to mechanics indicating the specifications
and operation of the emission systems for individual makes and models.
Once the effort to train the mechanics employed in the field is completed,
emission control systems should be integrated into the regular
mechanic training curriculum, thereby teaching new mechanics the field.
D.5  MATERIAL COVERED BY MECHANICS TRAINING
     Each method of mechanics training should emphasize material
tailored to the background and interest of the specific audience.
However, at the completion of the training session, each of the par-
ticipants should be able to accomplish the tasks and to possess the
knowledge listed below.  These are recommended minimum automotive
                                  D-6

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mechanics standards of the American Association of Motor Vehicle

Administrators.

                     Tasks to be Performed

                     Diagnose—malfunctions

                     A.   Fuel pump
                     B.   Emission system
                     C.   Analyze combustion
                     D.   Carburetor--repair and/or replace
                     E.   Fuel storage tank
                     F.   Indicator gauge
                     G.   Fuel pump
                     H.   Air filter
                     I.   Carburetor
                     J.   Heat riser valve
                     K.   Exhaust manifold
                     L.   Intake manifold
                     M.   Resonator


                     Knowledge—Information

             1.   Safety  factors
             2.   Type and characteristics of fuels
             3.   Types and use of filters
             4.   Principles of design, construction,
                 operation and their relationship to
                 component parts
             5.   Type and use of testing instruments
             6.   Diesel  engine principles
             7.   Use of  manufacturers' service manuals
             8.   Use of  special tools and equipment
             9.   Types and uses of lines and fittings
            10.   Use of  heating and welding equipment
                                 D-7

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D.6  COST OF MECHANICS TRAINING
     It is difficult to estimate the total cost of mechanics training
at this point in the study.  A generalization could be made on the
costs.  It is assumed that whatever the cost of mechanics training,
the State of Michigan will fund the program in its early stages; in
later stages, the program could be made self-sufficient through
reimbursement from mechanics.
     There are basically two types of program costs involved.  The
first type is the initial outlay, considered a one-time cost.  The
second type is the recurrent cost elements.  These are incurred with
every scheduled class.
     One-time costs include the costs to develop the training curriculum.
Colorado State University has produced an extensive array of materials
on this subject which could be utilized for developing curriculum.
Curriculum costs vary by the comprehensiveness or theme of material.
A list of the material and the associated costs is included as Appendix D-II
in this section.  In general, it has been estimated that one-time costs
of $3,500.00 would be incurred for curriculum development.
     The second type of costs would essentially consist of materials
costs plus salary for instructors and clerical assistants.  In the cost
estimate, it is assumed that a rental charge would be incurred at the
location where the classes will be held.  In the event the classes are
held at community colleges, high schools or other public facilities,
the rental charge would be zero.  This would reduce the total program
cost.
   Estimate prepared by SCI,  Inc.
                                 D-8

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     The cost of a mechanics training program is calculated under
the following assumptions:
     • There are 20 students per class, except where instructors
       are students, in which case the number of students per class
       is 12.
     • Instructors' salaries are computed at the base rate of $6.80/hr
       except where instructors are pupils  (Phase I), in which case a
       rate of $9.00/hr is used.
     • Rent  (including utilities) is calculated at  the rate of $7.50/sq  ft
       per year.
     • One set of tools at a cost of $1,000  each is assigned to each
       instructor.
     • There are 17,579 tune-up mechanics targeted  for training.
       (Source: MOOT officials)
     • 100 percent participation by mechanics is presumed.
     • The ratio of instructors to pupils is assumed to be five percent.
     • Twenty hours of classroom training is presumed for mechanics
       and 40 hours for instructors.
              Table D-l.  ESTIMATED INSTRUCTION COST  (1978 dollars)

                                         PROGRAM PHASE
EXPENDITURE ITEMS

Instructors

Rent

Curriculum Development

Handouts
Audio-Visual

Tools
No. of Students

Cost per Student
PHASE I
PHASE II
TOTAL
$26,280
6,750
3,500
14,600
600
2,0.00
53,730
879
$61.13
$127,296
42,189
0
71,021
2,700
9,000
252,206
17,579
$14.35
$153,576
48,939
3,500
85,621
3,300
11,000
305,936
18,458
$16.57
                                  D-9

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D.7  CERTIFICATION OF MECHANICS
     Consideration of emission control systems is part of the overall
tune-up phase of automobile maintenance.  Emission control systems
cannot be assigned to a specific or traditional repair category such
as brakes or front-end alignment.
     An adequate tune-up of post-1968 vehicles requires knowledge of
emission control components.  Knowledge of these recent engines in their
entirety is necessary for a mechanic to possess an understanding of
the purpose and function of emission control components sufficient
to diagnose, adjust and repair failures.  This interdependence prompts
the following recommendations.
     It is recommended that no new repair category be added to the
present mechanics certification program.  This would make amendments
to the present mechanics' registration act unnecessary.  The present
mechanic certification tests for tune-up and master mechanics categories
should be modified to include questions on emission control systems.
With the onset of a mechanics training program for I/M, only mechanics
holding current certification as master or tune-up specialists will
be eligible for training as emission control mechanics.  Following
the initial phase-in period, mechanics applying for certification
as tune-up or master mechanics will be eligible for emission control
training prior to testing.  The classification of emission control
systems under the tune-up category would enhance quality control by
minimizing the chance of a "front end alignment" mechanic performing
emission-related repairs.

D.8  IMPLEMENTATION SCHEDULE
     A recommended implementation schedule for the mechanics training
program is presented in Figure D-l.  This schedule is based on the
assumption of an I/M program start-up date of January 1, 1983.  In the
event this start-up date is either advanced or delayed, the entire
mechanic training program should be rescheduled correspondingly.
                                  D-10

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APPENDIX D-II

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                          Materials Developed at  the
             Center  for Motor Vehicle Emissions Control and Safety

            Available Through the Department of Industrial Sciences,
             Colorado State  University,  Fort Collins,  Colorado 80523

                                                               Reference
                                                                 Number    Cost

Motor Vehicle Emissions Control  Instructional Materials          1122-0    $290.00
Packet

     Designed as a complete multimedia training course which
includes:  Technical related narrative, 35mm slides and audio
cassette tapes, test questions with answers and laboratory
exercises with tool  list.  This  instructional packet  is de-
signed for vocational automotive teachers who wish to train
future mechanics, mechanics in the field and additional
teachers on the basic concepts of emissions and vehicle
emissions control systems.

Instructor's Guide for use with  Vehicle Emissions Control        0331-3      12.00
Instructional Materials Packet

     Designed to aid the instructor in class preparation,
demonstrations, "hands on" sessions and the presentation
of the "Colorado Emissions Control Packet"  (0331-1) and/
or the "Motor Vehicle Emissions  Control Packet" (1122-0).
It consists of key points for improving classroom pre-
sentation, suggestions for dramatic "table  top" and
"live vehicle" demonstrations as well  as class formation,
time budgeting and effective use of components for de-
monstration purposes.

Emissions Control Multi-Media Kit                                1122-1     300.00

     Designed as a complete multi-media auto mechanics
training course.  This Kit includes 359 slides (35 mm);
8 audio cassettes; test questions with answer key and '
laboratory exercises (including  tool  list)  plus a complete
easy to follow instructor's guide.   This kit has been de-
signed primarily to be used in the teacher  training work-
shops but is available as an excellent instructional  aid
for teachers with some background in emissions control
instruction.  The kit includes 1122-0 and 0331-3.

Chemistry of the Internal  Combustion Engine - Running            1122-2     75.00
Time (41 min_.)

     A 3/4 inch color video presentation on fuel  composition
and changes resulting from the combustion process.
                                   D-II.l

Effective 4/1/79

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                                                                Reference
                                                                 Number     Cost

Motor Vehicle Emissions Control - Series of Seven Books          1159-1    $20.00

     A series of seven illustrated self-instructional books
(391 total pages) designed to teach the concepts of emissions
control systems.  The seven topics covered are:   Positive
Crankcase Ventilation Systems; Thermostatic Air Cleaner
Systems; Air Injection Reaction Systems; Fuel  Evaporation
Control Systems; Exhaust Gas Recirculation Systems; Spark
Control Systems; and Catalytic Converter Systems.   Allow
one kit for each student since it is a consumable workbook.

Emissions Control Training Mechanics Handouts                     1167-1      4.00

     Designed to be used in conjunction with the "Motor
Vehicle Emissions Control  Instructional Materials Packet"
(1122-0).  The booklet contains handouts, laboratory ex-
ercise worksheets and other related information.  It is
intended for mechanic use  while attending an instructor
facilitated workshop.
     It is not designed for use alone, or as a self-
instructional device or textbook.

A Primer On Auto Emissions Systems for Home Mechanics            1167-2      6.00

     A book designed to acquaint the vehicle owner who likes
to maintain his automobile with the basic emissions control
systems and components installed on today's cars.  It con-
tains animated, easy to understand, step by step procedures
for checking various components related to emissions control
systems.  This book is not intended to be a substitute for,
or replace a good emissions control service manual.

Instructor's Guide for Vehicle Emissions Control Training        1167-3      8.00

     A self-contained curriculum .with narrative, illustra-
tions and overhead transparency masters.  It is designe.d
for instructors with limited background and equipment, who
want to teach the basic concepts and key points of vehicle
emissions control systems.
     This guide is part of a training package consisting
of "Instructor's Guide" (1167-3) "transparency Masters"
(1167-4) and "Student Workbook" (1167-5) designed to be
used together.

Transparency Masters for use with  Instructor's Guide for         1167-4      6.00
Vehicle Emissions Control

     This training aid provides all the transparency
masters which are identified in the Instructor's Guide.
Effective 4/1/79                     D-II.2

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                                                               Reference
                                                                 Number    Cost

Student's Workbook for Vehicle Emissions Control Training        1167-5    $6.00

     A workbook designed to lead students through key points
of vehicle emissions control concepts.  This workbook paral-
lels the presentation given in the "Instructor's Guide"
(1167-3) and requires the student's participation by re-
sponding to questions and key points and by performing
simplified "hands on" exercises.

Teacher Classroom Kit                                            1167-9     20.00

     A self-contained curriculum complete with all materials
and instructions necessary for instructors with limited back-
ground and equipment to teach the basic concepts and key points
of vehicle emissions control systems.  The kit includes 102
page instructor's guide, 116 transparency masters and 1 copy
of the student workbook (99 pages).  All teaching aids employ
a low verbal-pictorial approach.  The kit includes 1167-3,
1167-4 and 1167-5.

Electronic Ignition Systems                                     1167-6     70.00

     An introductory level approach to electronic ignition
theory and operation with comparisons to conventional
systems.  It is designed to be incorporated into the
"Motor Vehicle Emissions Control Instructional Materials
Packet" (1122-0).
     The media used is an audio cassette tape, slides,
narrative, test questions and answers.

Colorado Vehicle Emissions Control  Mechanic Workbook            0331-2      4.00

     Designed to be used by the student in conjunction
with the "Colorado Emissions Control  Packet" (0331-1) and/
or the "Motor Vehicle Emissions Control Instructional Ma-
terials Packet" (1122-0).  Each segment of this student
workbook contains emissions concepts, laboratory exercises,
self-check questions and related information.  It is not
designed for use alone, or as a self-instructional device
or textbook.

Introduction for Vehicle Emissions  Control                      0331-4    200.00

     Two 3/4 inch color video cassettes of an animated
introduction to emissions control systems.  There are
eight (8) presentations with an approximate running
time of 10 minutes each.  The tapes were produced from
the booklet, A Primer On Auto Emissions Systems for
Home Mechanics.
Effective 4/1/79                      D-II-3

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                                                                Reference
                                                                 Number        Cost
Inspector's Guide for Vehicle Emissions Control                   1167-7      $7.00

     An illustrated book to provide the emissions control
inspector with basic information needed to understand the                              <
various aspects of inspection/maintenance programs, con-
cepts of the various emissions control systems, cause and
effect of vehicle emissions and a basic understanding of
how the infrared analyzer is used to determine exhaust
emissions levels.
                                                                                       i
Fuel Injection Systems                                            1191-1      75.00

     An introduction to fuel injection systems.  Material
covered includes theory, electronic and mechanical fuel
injection systems and their respective components.  It is
designed to be incorporated into the "Motor Vehicle Emis-                              '
sions Control Instructional Materials Packet"  (1122-0).
The media used is an audio cassette tape, slides, nar-
rative, test questions and answers.
 Effective 4/1/79
                                      D-II.4

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               APPENDIX E




CONSUMER PROTECTION AND QUALITY ASSURANCE

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                           APPENDIX E
           CONSUMER PROTECTION AND QUALITY ASSURANCE

E.I  OVERVIEW
     Effective consumer protection and quality assurance elements
are important to the success of any I/M program.  Consumer protection
not only protects the public from unnecessary costs and inconveniences
during emission system checkup and repair, but also helps to eliminate
inequities caused by drivers who should have their vehicles repaired
but avoid doing so by successfully circumventing the intent of vehicle
inspection.  A quality assurance program results in maintaining uniformity
and a high degree of precision in emission testing.  The successful
implementation of both elements could secure public acceptance of I/M,
thereby avoiding build-up of adverse publicity.
     There are mechanisms to ensure compliance with a two-faceted con-
sumer protection element.  In order to minimize unnecessary costs and
inconveniences to the public, technical and administrative safeguards
built into post-inspection failure diagnosis facilities and repair
garages could best serve the purpose.  Examples of specific procedures
include consumer hotlines, complaint investigators, repair cost ceilings,
and approval and/or certification of repair shops.  Some of these
elements have been included as program costs in Section 5.0.  In the
event of a motorist trying to circumvent the inspection system, safe-
guards should be in place so the likelihood of cheating the
system is minimized.   Mechanisms to thwart the invalidation of emission
inspections by motorists include dummy tailpipe checks and non-tamperable
carburetors.
     The element of quality assurance addresses the reliability of the
actual emission tests as well as the collection and analysis of inspec-
tion information.   It involves instituting periodic and/or daily
equipment checks and performing preventive maintenance, but also
                                 E-l

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includes proper selection of analysis equipment at the outset of the
program.  The mechanisms dealing with consumer protection and quality
assurance are discussed in detail in this appendix.

E-2  EXISTING CONSUMER PROTECTION MECHANISMS IN MICHIGAN
     Act No. 300 of the Public Acts of '1974 sets conditions on the
practice of servicing and repairing motor vehicles.  It proscribes
unfair and deceptive practices and provides for enforcement and
penalties.  Section 257.1309 of the Act in part directs the adminis-
trator to "....establish procedures for receiving complaints relating
to alleged violations of the act or rules promulgated pursuant to
the act."  Accordingly, the Department of State, Bureau of Automotive
Regulations, has published general rules in regard to vehicle repairs.
The general rules set up requirements for repair facilities to post
their registration certificate, to provide written estimates for
repairs over $20.00, invoices of all labor and parts, and to provide
the toll-free phone number of the agency responsible for consumer
protection.  This toll-free number is accessible from anywhere in
the state.  The Prosecuting Attorney's office handles consumer pro-
tection cases on the county level.  If a consumer is dissatisfied
with a product or service and feels that he/she has been the victim
of unscrupulous business dealings, a complaint can be filed with the
"Office of Consumer and Business Affairs" (or comparable office) of
the Prosecuting Attorney's office.  Even though the Prosecuting
Attorney's office is expected to handle complaints on the county
level, the majority of complaints are currently processed by the
Bureau of Automotive Regulations because its toll-free number has
made that office more accessible.
                                 E-2

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E.3  CONSUMER PROTECTION AS A FUNCTION OF ADMINISTRATIVE MODE
     Consumer protection needs vary depending on the program's adminis-
trative approach—state-operated, contractor-operated,or private
garage.  In general, the consumer protection element is similar for
the state and the contractor-operated centralized program, with the
exception that the State would retain authority for supervision over
the contractor's facilities and its operation.  Therefore, consumer
protection is discussed as a function of centralized or
decentralized facilities.
     As stated previously, one function of consumer protection is to
protect the consumer from receiving inaccurate test results.  In this
context, a centralized inspection approach provides the best protection
to the consumer.  Centralized facilities permit the use of standardized
testing and calibration procedures using professionally trained per-
sonnel.-  By contrast, in a decentralized program the chances of
inaccurate tests are greater due to the difficulty in achieving uniform
testing and calibration procedures.

E.3.1  CONSUMER PROTECTION ASPECTS OF A CENTRALIZED PROGRAM
     A centralized inspection program has several advantages in pro-
viding a consumer accurate and consistent test results.  In a centralized
program,  the vehicles are tested by an independent organization which
has no interest in auto repairs.   Tests are conducted in high volume
facilities utilizing standardized testing procedures in conjunction
with specially trained personnel and automated equipment.   Testing
is the only function performed by these facilities.  In the event of
failure,  an owner has the option to undergo vehicle repair at the
garage or service center of his choice, prior to returning his/her
vehicle for retest.   This retest provides verification of  proper vehicle
repair to the motorist.   Additionally, dependent upon the  type of
                                 E-3

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equipment and the mode of calibration, hourly instrument calibration
could be instituted along with daily checks, thereby assuring accurate
results.  Calibration checks are further discussed in a later section.
Since the number of testing facilities is limited, personnel and equip-
ment performance can be more closely monitored.  In the event of improper
testing procedures, an employee could be retrained to correct his/her
deficiencies.  A centralized program can also eliminate the recording
error for test results if the process is fully automated.
     In a state-operated centralized program, it is presumed that hourly
and daily calibration of equipment would be sufficient to assure proper
operation and accurate test results.  However, in a contractor-operated
program, it is suggested that additional measures be implemented not
only to guarantee the accurate, testing of vehicles (ensuring that the
contractor is complying with the contract), but also to gain public
acceptance of the program.  There are two methods for developing a
verification regimen for emissions testing as an aspect of consumer
protection.  These two methods,(1)  referee stations,  and (2) correlation
car, are discussed below.

E.3.1.1  Referee Station
     Customer complaints arise regarding the reliability of emission
test results, especially in cases where a vehicle fails an emission
test after the recommended repairs have been performed.  In order to
resolve complaints of this nature, a referee station is used.  The
use of a referee station provides an additional check on emission test
facility instrumentation, engine diagnosis, and mechanic capability.
For customer convenience, as an alternate, mobile test units could be
used as referee stations.   Upon receipt of a customer complaint and
request for verification of emission test results, an appointment is
made to conduct the verification test at the test facility in question.
To avoid an overload on the system, specific criteria have to be developed
                                 E-4

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to single out complaints for verification testing.  For example,
vehicles which have failed after the recommended repairs were performed
and/or vehicles for which the recommended repair costs are above some
predetermined level would be eligible for verification testing.

E.3.1.2  Correlation Car
     In addition to the regularly scheduled calibration checks, cor-
relation vehicles with a known level of emissions could be used to
further standardize the station-to-station equipment complements.
The correlation vehicle is altered in such a way as to reduce to a
minimum those parameters that might cause variations in the emission
levels due to inconsistent energy demands on the engine (e.g., power
brakes, air conditioning, fuel composition, fuel temperature, etc.).
An emission test performed using a highly standardized correlation ve-
hicle provides a quality check on the entire analytic system of
anlayzer, sample collection system, tachometer  and inspection personnel.

E.3.2  ASPECTS OF DECENTRALIZED I/M CONSUMER PROTECTION
     The chances are great that conditions exist in a decentralized
I/M program which may prevent motorists from receiving an accurate
emissions test.  For example, there is limited standardi-
zation of inspection procedures, equipment maintenance, and cali-
bration schedules from one garage to another.  In addition, garages
are also subject to time and cost pressures on the use of a bay for
inpsections.   Although the decentralized inspection program can incor-
porate additional consumer protection components, some consumer
dissatisfaction may still result from the lack of consistency in the
enforcement of emission standards among garages.
     Methods to compensate for the lack of standardization of equipment
calibration and inspection procedures are discussed below.
                                 E-5

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E.3.2.1  Challenge Garage
     A challenge garage, similiar to a referee station, is a State-
operated facility where vehicle owners may obtain an independent
emissions test to compare to a test from a licensed station.  U.S. EPA
has specified that at least one referee station must be present in
each I/M metropolitan area where a decentralized program is in effect.
There are no requirements for the size of the facility; thus it may
take the form of a garage bay, a mobile van, or even a portion of a
parking lot, so long as the test methods are sound.  Providing a referee
station will give motorists an opportunity for an objective inspection,
independent of any special interests of the repair industry.  The
challenge garage may also be a center for handling consumer complaints
relating to the diagnosis and repair of vehicle emissions malfunction.
E.3.2.2  Garage Inspection Program
     By making periodic inspections, the State garage inspectors can
verify that the garages' equipment is calibrated, is in proper working
order, and can provide accurate test results.  This activity is a
necessary element in a decentralized inspection program,  without sur-
veillance, the garages may allow their testing procedures and quality
control to slip.  The correlation of instrument readings among inspection
facilities should also be checked at this time.

E.3.2.3  Garage/Inspector Licensing Program
     Garage and inspector licensing ensures that the individual con-
ducting inspections at the garage has received instruction in the
proper use of the emissions analyzer and in vehicle testing methods.
Licensing of the garages, in addition, ensures that all garages have
proper analytical instrumentation and sufficient space to provide
inspections.
                                E-6

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E.4  QUALITY ASSURANCE FOR TESTING
     Maintaining uniformity and high precision in emissions testing
is vital to the successful implementation of any inspection/maintenance
program.  The reliability of the test procedure is central to the  issue
of quality assurance.  The generation of accurate information is
necessary to correctly assess the effectiveness of the program in
lowering emissions from motor vehicles and maintain public interest
and participation in the program.  If I/M is perceived as an arbitrary
and haphazard program, enforcement problems will be encountered.
     There are two essential aspects of quality assurance.  They are
CL) establishment of inspection and maintenance equipment standards,
and (2)  inspection system quality assurance. The first aspect seeks
to assure from program start-up the adequate performance of testing
equipment and the neutralization of problems associated with the analysis
of vehicle exhaust gas emissions.  The second aspect involves the
development of a plan to repeatedly ensure the proper operation of
these instruments.

E.4.1  INSPECTION AND MAINTENANCE EQUIPMENT CONSIDERATIONS
     Equipment considerations are classified and discussed according to
two categories:  sample collection system considerations and gas
analyzer considerations.  The sample collection system and gas analyzer
considerations deal with various technical problems and solutions
associated with the analysis of vehicle exhause gas emissions.

E.4.1.1  Sample Collection System Considerations
     Because exhaust gases are extremely complex mixtures of HC,  CO ,
CO, NO ,  aldehydes,  particulates,  water, nitrogen,  oxygen,  hydrogen,
and many other compounds, the application of proper gas sampling tecn-
niques and careful sample handling treatment prior to instrument analysis
                                . E-7

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are necessary to measure any single pollutant accurately.  The basic
consideration is to obtain a sample of exhaust gas which is completely
representative of the vehicle exhaust for the operating condition of
interest.
     Therefore, it becomes necessary to selectively remove those
materials and compounds which affect the absolute measurement of the
subject pollutant without changing the concentration or characteristics
of that pollutant.  In a practical sense, this generally means reducing
the water vapor level in exhaust gases and filtering ouj: the particulates
before passing the gas sample through a measuring instrument.  Additionally,
the sample handling system should also provide for the periodic inputting
of zero and span check gases and calibration gases.
     In order for a system to effectively perform those operations,
the following items should be considered when making a sample collection
system selection:
     • Avoidance of materials that are subject to corrosion and
       deterioration.
     • Adequate flow rates for fast system response.
     • Rugged construction of sample lines and probes to withstand
       heavy usage.
     • Filtering system of adequate capacity and serviceability.
     • Adequate provisions for water removal.

E.4.1.2  Gas Analyzer Considerations
     The heart of any automobile exhaust emission test system is the
instrument component required to measure the levels of pollutants.
Depending on the type of test being conducted, the analyzers vary
from relatively simple and inexpensive to highly sophisticated.
     A large number of sophisticated exhaust gas analysis systems have
been assembled and used in research programs and in the certification
and quality audit of new cars to evaluate their compliance with state
                                E-8

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 and federal standards.  At the other end of the spectrum, some relatively
 simple analyzers are being used by garage mechanics and tune-up tech-
 nicians to assist in adjusting engine operating parameters during
 maintenance.  The instrument system required in a mandatory inspection
 program probably lies somewhere between these extremes.
      An important consideration in the selection of the instrumentation
 is the wide range of values required to measure HC concentration in
 the various modes of vehicle operation.  During vehicle testing, HC
 concentrations of a. few thousand ppm are commonly observed and,
 occasionally,  values in excess of 10,000 ppm are observed.  Conversely,
 observed values of less than 50 ppm are common in the exhaust of well
 adjusted 1972  and 1974 emission controlled cars operating in steady-
 state modes; even lower values are observed with 1975 and later vehicles.
      For the I/M exhaust emission program,, the NDIR analyzer is probably
 the choice because it is reasonably stable and trouble free.  Calibration
 maintenance procedures are well defined and their effectiveness well
 established.  Many thousands of these instruments, produced by several
 major manufacturers, are being used very successfully in automotive
 exhaust emissions analysis.
      For the final analyses,  the selection of HC instrumentation depends
 on the degree  of measurement accuracy and ranges required based on an
 evaluation of  the exhaust emissions inspections standards established
 by the state.

 E.4.2  INSPECTION SYSTEM QUALITY ASSURANCE
      A plan should be developed to daily ensure the proper operation
 of inspection  instruments.   Such a plan could be divided into four
 components.  Those are,(l)  daily operational checks and adjustments,
(2)  scheduled preventive maintenance,(3)  major maintenance and repair,
 and 4)  periodic instrument calibration checks.   The first two components
 are classified as routine,  as required procedures and are performed
                                 E-9

-------
during normal working hours by inspection facility personnel.  Major
maintenance should be available on an on-call basis by fully trained
service personnel supplied by the appropriate instrument manufacturing
company.  The major maintenance service personnel should repair and
overhaul major equipment and have available a complete stock of spare
parts and major equipment replacement units.  Periodic instrument
calibration checks need to be performed by qualified state inspectors
dispatched from a central state-operated facility.  The state inspectors
could conduct the calibration checks using a fully equipped mobile test
unit or a correlation vehicle.

E.4.2.1  Daily Operational Checks and Adjustments
     Daily operational checks of the vehicle inspection system can
be performed by inspection facility personnel prior to opening for
business.  The three daily checks are for (1)  NDIR Gas Analyzer,
(2)  -Sample Handling, and (3)  gas supply.
     The NDIR gas analyzers require initial zero and span check to verify
that the test lane operational status is according to specifications.
These gas analyzers must be zeroed and spanned manually at the
beginning of each work shift by the supervising inspector or surrogate.
For the remainder of the shift, the inspector can then compensate for
minor zero or span shifts once every six tests.  Repeated zero and
span drift error usually means that the analyzer requires preventive
maintenance.
      At the beginning of each shift, the temperature of the calibration
gas water bath should also be checked and adjusted as required.  The
pressure and flow of the exhaust sampling system should be checked
and adjusted to specified values by the supervising inspector or other
inspection personnel.  Cylinder pressure of the working gases  (zero
and span for the NDIR analyzer) also needs to be checked each shift,
and new cylinders should be installed by the facility personnel if
the pressure drops below 100 PSI.
                                E-10

-------
E.4.2.2   Scheduled Preventive Maintenance
     Preventive maintenance of the vehicle inspection system should
be accomplished on a scheduled basis and integrated into the daily
operational checks by an inspection facility's supervising inspector.
Preventive maintenance for the sampling system should be performed
at the beginning of each shift.  The tail pipe sample probe and sample
line must be checked for damage and restricted sample flow.  The water
trap and aspirator are checked for deposits, along with the exhaust
gas filter.

E.4.2.3  Major Maintenance
     Those system problems which are easily handled by the station
personnel can be addressed either of two ways.  A repair staff could
be retained at the regional level, or major problems could be referred
to the manufacturers themselves. In either case, equipment downtime
must be kept to a minimum.

E.4.2.4  Periodic Calibration Checks
     Periodic calibration checks should be performed at specified intervals
by qualified state inspectors.  The state inspectors can operate out
of a mobile test unit dispatched from a centrally located state facility.
The mobile test unit must be equipped with an NDIR gas analyzer, remote
tachometer, one percent calibration gases, tachometer calibrator, and
field-type diagnostic equipment.  In a decentralized program, the calib-
ration checks would be prearranged to allow for scheduled downtime.

E.5  PROTECTION FOR MOTORISTS WHO FAIL INSPECTION
     Consumer protection mechanisms for motorists who fail inspection
may be divided into two categories.  The first category is comprised
of specific active procedures set up to deal with consumer complaints
as they occur.  These include consumer hotlines and diagnostic checks
                               E-ll

-------
for redundancy.  The second category consists of features built into
the system which protect consumers from inequities or abuses.  Some
of the elements included under this category are
          1.  Maximum repair cost limit;
          2.  Private garage analyzer testing by state authority; and
          3.  Confirmation of manufacturer's specification tuning
              at the referee station.
The elements in each category are discussed below.

E.5.1  CONSUMER HOTLINES
     Consumer hotlines serve the purpose of providing information to
the consumer as well as a central source where complaints regarding
any procedural aspects may be registered.  In some cases, a complaint
can be resolved by phone merely by providing the correct information,
while in other instances the complaint may have to be referred to
another department for proper follow-up.  If the complaints seem to
be generated from one predominant source, a spot investigation would
alleviate the problem before it mushrooms.  Thus, consumer hotlines
can contribute to the overall public information effort.
     The Department of State, Bureau of Automotive Regulation, currently
maintains a toll-free number for registering complaints in regard to
vehicle repair.  This service should be expanded to handle complaints
arising from vehicle emissions testing and repair services.  Present
personnel could be utilized for this purpose with additional training.
The current toll-free number could be utilized by consumers for both
obtaining information and registering complaints.  Records of all
comp.l aints and the follow-up action should be maintained on paper or
computer tape.

E.5.2  DIAGNOSTICS
     In the event of an inspection failure, the  States of Arizona and
California both provide diagnostic information on the probable cause of
failure.  The purpose of this diagnostic information is to provide a
guide for both the repair mechanic and the owner of the vehicle.  The

                                E-12

-------
   mechanic saves a substantial amount of time which would have been spent
   searching for the cause of failure, thereby resulting in a lower labor
   charge, and the consumer can determine justified repairs in contrast to
   unnecessary repairs which are performed in the guise of emission control.
        For example, the major causes of elevated hydrocarbon emissions
   are improper timing, ignition system malfunction, and malfunction of
   emission control devices.  In no way is any repair to radiator or brakes
   connected with possible emissions reductions.  However, an ordinary
   motorist not familiar with the inner workings of an automotive system
   might be convinced of such a relationship by a mechanic, resulting
   in a higher bill for the consumer.
        Table E-l lists the most common systems and components, ways in
   which their operations can vary, and the resultant effect on carbon
   monoxide and hydrocarbon emissions.  (See Appendix C in Volume I)

    Table 5-1.  EFFECT OF ENGINE COMPONENT OPERATION ON EMISSIONS
COMPONENT
Decreased air-fuel ratio
Decreased engine idle speed
Restricted PCV valve
Restricted air filter
Choke malfunctions
Carburetor malfunctions
Ignition system malfunctions
Advanced spark timing
Stuck heat riser valve
Exhaust valve leak
intake manifold leaks
Emission control device malfunction
Catalytic converter breakdown
Change in Emissions
Carbon Monoxide
Increase
Increase
Increase
Increase
Increase
Large Increase


Increase

Increase
Increase
Large Increase
Hydrocarbon
Increase
Increase
Increase
Increase
Increase
Increase
Large Increase
Decrease

Increase
Increase
Increase
Large Increase
Source:  U.S. Environmental Protection Agency
                                    E-13

-------
E.5.3  MAXIMUM REPAIR COST
     Repair cost limits were discussed to a limited extent in Appendix B
(subpart C.3.10).   To reiterate, the repair cost limit is a maximum
dollar amount that a motorist is obligated to spend on repairs for his/her
motor vehicle in order to meet the emissions standards.  This cost
ceiling prevents I/M from becoming a severe penalty on vehicle owners
in lower income brackets.  On certain vehicles, the cost of repairs
might exceed the book value of the car, rendering such repairs econom-
ically infeasible.
     Repair cost ceilings are generally of two types.   In the first
case, an absolute dollar limit is set.  Thus, all vehicle owners,
regardless of the age or resale value of their cars, need spend only
up to the absolute limit in the event of a failure.  In the second
case, the maximum repair limit is determined as a percentage of the
vehicle's average retail price  (i.e. NADA's Blue Book value).
     Large-scale I/M programs presently in operation all have built-in
repair cost ceilings, with an upper limit of $50 being most common.
Data shown in Table E-2 indicate that this limit covers 80 to 90 percent
of the average repair cost.  It should be noted, however, that a $50
limit is low in term of 1978 costs in that it may fail even to cover
the cost of an engine tune-up.
     It is recommended that the State of Michigan carefully consider a
cost ceiling prior to the implementation of the I/M program.  It might
be more equitable, though more costly, to choose the type of ceiling
in which the dollar limit is computed on the basis of a vehicle's book
value.  This second option would allow more flexibility for the
individual motorist and would be no more difficult to enforce.
                                E-14

-------
   Table E-2.  REPAIR COST SUMMARY FOR EXISTING I/M PROGRAMS'
NEW JERSEY
Less than $10
$10 to $25
$25 to $50
$50 to $100
More than $100

N = 16,000
Avg. repair cost =
29.7%
26.4%
22.1%
16.1%
5.6%


$32.40
Median: 50% of repairs cost
less than $20
65% of repairs cost
than average














less

OREGON
No cost 27%
Less than $10 37%
$10 to $30 18%
$30 to $50 8%
$50 to $75 5%
More than $100 2%
N = 1,400 (primarily newer cars)
Avg. repair cost = $16.00
Median: 50% of repairs cost
less than $8
71% of repairs cost less
than average
ARIZONA
Less than $5. 27%
$5 to $10 17%
$10 to $25 24%
$25 to $50 20%
$50 to $100 10%
More than $100 2%
N = 2,000
Avg. repair coat = $23.40
Median: 50% of repairs cost
less than $15
64% of repairs cost less
less average
Source:  U.S.  Environmental Protection Agency
                                E-15

-------
E.5.4  PRIVATE GARAGE ANALYZER TESTING BY STATE AUTHORITY
     The discrepancy between test result readings of emission analyzer
equipment in use at garages where vehicles are repaired and those of
the equipment at emission testing stations has been a cause of concern
in many states with I/M presently in effect.  The State of Arizona has
taken the lead in seeking the causes of this discrepancy.  In the fall
of 1978, Arizona instituted a program in which all garage analyzers
are tested at least once every 60 days.  The reason for Arizona's
undertaking this program was growing public dissatisfaction with the
numerous trips between inspection stations and repair garages arising
from incongruous emission test output.  Arizona's program has revealed
that emission readings of private garage analyzers vary by as much as
30 to 40 percent from the true value.
     Some example variance plots from one garage analyzer monitored by
the Quality Assurance Section of the Arizona Department of Health
Services is shown in Figures E-l through E-4.  As is apparent from
these sheets, low range CO (0 to 2 percent) is generally the least
affected by inaccurate readings, whereas high range HC (1,000 to
1,600 ppm) is the cause of greatest concern.  Poor in-shop maintenance
of the analyzer, lack of outside maintenance services, and general
carelessness of the garage personnel has been blamed for these dis-
crepancies .  It is not unusual for garage repair personnel to leave
the analyzer probe on the floor where it can gather dust and grime
and be driven over by vehicles.  This contamination and abuse nega-
tively affect the accuracy of the analyzers to a significant degree.
It has been calculated that 40 percent of analyzer variance problems
are associated with damage to the probe.

     The  State  of Michigan should consider  adding private  garage analyzer
testing to its  quality assurance program.   Guidelines  should ".be estab-
lished which set forth the procedures  for  calibrating  garage^analyzers
  Mr. William F. Price, Manager, Quality Assurance, Arizona Bureau
  of Vehicular Emissions Inspection
                                E-16

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that would be followed by garage proprietors themselves.   This measure
would allow the State to increase the interval between visits to each
garage facility for the purpose of checking analyzer performance.

E.5.5  MANUFACTURER'S SPECIFICATION TUNING
     It has been demonstrated that in order to obtain the lowest
possible emissions readings, a car must be tuned to the manufacturer's
specification.  However, a significant number of mechanics prefer to
tune a vehicle to their own standards of what produces optimum perfor-
mance.  These standards tend to be different from manufacturer's
specifications.
     If a vehicle goes through the entire I/M process and returns to
the referee station, the state personnel should determine the procedures
and specifications followed by the repair mechanic.  This can be time-
consuming for these personnel.  Part of the problem will be alleviated
through the mechanics training program.  However, careful record-keeping
by the state should single out the shops and/or mechanics who are not
following prescribed procedures and specifications, in which case a
follow-up visit by quality assurance inspectors would be appropriate.
     Figure E-5 illustrates the examination report form currently in
use at State of Arizona referee stations.  This form records whether
a failed vehicle was tuned to manufacturer's specifications, and could
be used to identify repair facilities at which proper tuning procedures
are not followed.

E.5.6  REPAIR FACILITY CERTIFICATION
     The certification of repair facilities for emission work could
be substituted for some of the activities previously mentioned.  The
repair facility certification process is meant to serve two basic
purposes.  First, it gives vehicle owners some guarantee of the com-
petence of the repair facility, and second, a quality work product
                                E-21

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 STATE  INSPECTOR _

 VEHICLE LIC. NO.

 VEHICLE OWNER 	

 ADDRESS
             STATION NO.
                     DATE
VIN
                             MAKE
                                                  YR
                                   PHONE NO.
                           HIGH CRUISE
                         HC (PPM)   CTT(%).
                LOW CRUISE
              HC (PPM)CO  U)
                          IDLE          DATE/
                   HC  (PPM]CO (%)   TIME
HTS  Initial Inspection

HTS  Re inspect ion

LAB  (as-received)

LAB  (after adjustment)


REPAIR FACILITY E ADDRESS

NDIR Registration No.  	

Claimed Work
Underhood Exam
                HC
                          CO
As Rece i ved

Mfg. Specs.

COMPRESSION:
1	    3

5	    t
                                          PH
                                          NO.
  Estimated
  Repair Costs
                Receipts
                                                                     Tampering?
Reason for Failing Re inspect ion:
A/F ADJ.   RPM      TIMING    PLUGS
                                      LABORATORY  EXAMINATION
    RPH (Tran)
      WIRES
                                                      DWELL
                TIMING    (ADVAN)     PCV
                    CID   BBL   TRANS
DIST.    VAC.  LK.    INT. CARS.  ENG. MECH.
Other
Technician Comments
EXAM RESULTS:

Waiver Returned?
DATE:
                      STATE TECHNICIAN:
                  Figure E-5.   State of  Arizona's Examination Report
                                                  E-22

-------
must be assured by the facility for it to retain its certification.
Criteria such as employment of a master mechanic or a tune-up specialist
along with the availability of an emission analyzer could be established
in order for the facility to be eligible for certification.
     The State of Michigan presently requires each repair facility
to file a certificate with the Bureau of Automotive Repair.  Additionally,
it requires each facility to employ at least one speciality or master
mechanic certified in each category of repair that the facility provides.
This existing regulation with an additional requirement should be suf-
ficient to guarantee a competent repair facility.  The amended regulation
should require that every facility specializing in tune-up be able to
demonstrate the availability of an emission analyzer in order for that
facility to obtain certificate renewal.

E.6  MECHANISMS TO MINIMIZE CIRCUMVENTION OF SYSTEM
     This aspect of consumer protection is intended to preclude the
inequities caused by drivers who should have their vehicles repaired
but who avoid test failure through some form of cheating.  Subversion
of the program in this manner is unfair to individual drivers who have
undergone repairs in order to comply with emission standards,because
the contribution to clean air for which they have paid is neutralized
by the added pollution generated by cheaters.  Protection against such
acts may be provided by procedural mechanisms.  Some of these mechanisms
are discussed below.

E.6.1  DUMMY TAILPIPE CHECKS
     In order to secure a reduced emission reading during vehicle
inspections, some motorists may weld a second tailpipe onto the vehicle
exhaust system, and by creating dual channels, thus dilute the exhaust
gas concentration measured in one tailpipe.  This can also be accom-
plished by introducing a diverter valve in the exhaust system, which
                               E-23

-------
permits some of the emissions to escape prior to reaching the test
probe.  Both techniques have the effect of reducing the concentration
of regulated pollutants, thereby permitting a vehicle to pass which
should have failed.
     There are two methods of identifying such abuses.  First is a
simple visual check by the inspector prior to inserting the analyzer
probe.  Second is a safeguard built into the emission analyzer itself.
This sets the analyzer to monitor carbon dioxide (CO ) during the
inspection.  In the event of change in CO  concentration, the HC and
CO readings are adjusted conversely through carbon mass balance.  If
results of the mass balance are incompatible with meter readings, the
test is voided.

E.G.2  "MERRY-GO-ROUND" DRIVERS
     This scenario involves a motorist driving around from one testing
lane or facility to another until he/she passes inspection.  This
should be of special concern to officials since such activities create
doubts in the mind of the general public as to the accuracy and purpose
of the emissions inspection.
     A majority of existing programs have combatted this problem by
providing only one free retest and requiring the same fee as the original
test for subsequent tests.  This discourages vehicle owners from having
multiple inspections without undergoing repair, particularly as the
cumulative testing fee approaches the likely repair cost.  Another
method utilized by some states requires the motorist to present evidence
of repair in the form of a receipt or filled-out test registration
form from the repair mechanics or a receipt for parts purchased if
repairs are performed by the owner himself.  This form describes the
diagnostic information and corresponding repair.  Without such evidence,
the retest is not performed.
                                E-24

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E.6.3  REGISTRATION IN COUNTIES OTHER THAN THAT OF RESIDENCE
     This aspect of the valid testing problem has been discussed to
a limited extent under Appendix B (Section B.3.12).  The likelihood
for vehicle registration outside a control area by residents of that
area is high if I/M program coverage is not statewide (i.e., limited
to certain counties).   Vehicle owners residing in the affected counties
may register using the address of a relative or friend living in
non-I/M counties.  Temptation to do this may be greater for drivers
residing on the fringe of the control area.
     The problem of circumventing the inspection requirement could
be alleviated by including a penalty provision in I/M legislation,
as the State of Arizona has done.  Furthermore, a cross-reference
check could be made through computerized data files every year, checking
the owner's address against the address of his or her vehicle regis-
tration.  A notification to subject vehicle owners listing their
responsibilities and the penalties for fallacious registration should
promote compliance with the law.
                                E-25

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             Appendix F
UNIT COST DATA USED IN COST ANALYSIS

-------
                                 Appendix F

                     UNIT COST DATA USED IN COST ANALYSIS
     This appendix provides the detailed cost data used in  analyzing costs of
various program options.  Data are presented in the order of cost elements
listed  in Table  F-l  and are grouped into three major categories:

     •    Initial Implementation and Capital Costs (Section 1)
     •    Annual Operating Costs (Section 2)
     •    Ancillary Programs Annual Operating Costs (Section 3)

     A summary of cost data is presented in Section 6.  All cost data are
expressed in 1978 dollars.  They were developed from the Dodge,  report,  inputs
from State of Michigan, and other existing I/M program data.  Costs presented
represent average prices.  The assumptions used in the development of these
costs were:

     •    No volume or special discounts are available for materials, equip-
          ments, and land.

     •    Standard grade materials will be used.

     •    There are no labor cost premiums due to the shortage of  skilled  personnel.

     •    Labor wage rates used include:  base rates plus fringe benefits of
          25 percent.
 1979 Dodge Manual for Building Construction Pricing and Scheduling,
 McGraw-Hill Information Systems Company, N.Y., N.Y.  1979.
 Provided by the State of Michigan.
                                      F-l

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                    Table  F-l.   COMMON SET OP COST ELEMENTS


 ITEM                           _  COST ELEMENT _
MmmMMB*    — ™^«» KHMMHIK^ ^ — i _•«• — ^

   I.      INITIAL  IMPLEMENTATION AND CAPITAL COSTS (HONHECORRING)

          A.    Inj.tj.al  Implementation Costs

               1.  Site 34 lection
               2.  Bids Preparation  and Evaluation
               3.  Facilities Design
               4.  Training  Plan Development
               5.  Personnel Selection
               6.  Document  Preparation
               7.  Administrative Support
               3.  System Integration, Checkout, and Certification
               9.  Test Scheduling System Development
          3.    Capital  Coats (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.    Capital Costs (Other)

               1.   Administrative Office Equipment
               2.  Quality Control Equipment
                  a.   Mobil unit
                   b.   Referee Station
                   c.   Correlation Car
               3.  Consumer  Complaint


  II.     ANNEAL OPESATI^G COSTS

          A.    Facility Operating Costs
               I.  JsrscMiel Costs
               2.  Maintenance and Miscellaneous It 2m Costs
                   a.  Facility
                   b.  Equipment
          3.   Support Costs

               1 .  Administrative
               2.  Gata Analysis
               3 .  Training
          C.   Quality Control Operating Costa

               1.  Personnel
               2.  Supply
               3 .  Maintenance
  III.     ANCILLARY PROGRAMS ANNUAL OPERATING 'COSTS

          A.   Ancillary Program Costs

               1.  Mechanic Training
               2.  Public Information Program
               3.  Consumer Complaint
               4.  Vehicle Test Scheduling Costa
                                            F-2

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p.1.1
IMPLEMENTATION AND CAPITAL COSTS
F. 1.1.1   Initial Implementation Coats (Start-Up Costs)


     Implementation of an I/M program will require program planning, design,

and development.  Costs of these noncapital cost items are difficult to quan-

tify.  Included here are those administrative costs that are necessary to

support facility construction, program coordination in the initialization

phase.  These costs are identified in Table F-2 and the cost item is identi-

fied, according to the responsible party for each administrative option.  For

those indirect costs associated with implementation efforts, such as legis-

lation, etc., a bottom line G/A and/or overhead percentage will be applied.
                Table F-2.  COST ITEMS OF PROGRAM IMPLEMENTATION
                                         ADMINISTRATIVE OPTIONS
Contractor-
State- Operated
COST
ITEMS
Operated State
Contractor
Private Garage-
Operated
State
Service
Center
Site selection
Bids preparation and
  evaluation
Facilities design
Training plan development
Personnel selection
Document preparation
Administrative support
System integration, checking
  out, and certification
Test scheduling system
  development
                                      x
X
X
X
X
X
X
X

X
X
X
X

X
X
X


—
-
X
X
X
X
                                      X
                    X
                             X
F.I.1.2   Site Selection


     Based on the number and types of the inspection facilities, the land area

required for station placement must be identified.  This cost element includes:
          Establish guidelines for site selection
                                                  $5,000
                                       F-3

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     •    Analysis for optimal site location
            -consumer convenience
            -site costs
            -access                                         $200 per site

     •    Travel associated with site selection per site
            -manpower plus travel                           $200 per site

          Total cost » $400 per site + $5,000

F.I.1.3   Bids Preparation and Evaluation

     All necessary performance specifications of the I/M program must be com-
pleted in the form of a Request For Proposal (KFP) so that contractors may
submit bids.  The bids must be evaluated, qualifications of contractors certi-
fied, and contracts drawn for the selected parties.  Modifications to existing
facilities would be handled somewhat differently; but the cost elements would
remain basically the same.  These costs include:

                                             MANUAL DATA     AUTOMATED DATA
                                           HANDLING SYSTEM  HANDLING SYSTEM
    a.  Idle-Mode and Engine Parameter/
          Device Inspection (EPDI)
        - RFP preparation                      $ 3,000         $ 8,500
        - bid package and distribution           2,500           2,500
        - bid review and selection               3,800           3,800
            TOTAL COSTS                        $ 9,300         $14,800
    b.  Additional for Loaded-Mode             $ 4,600         $ 4,600^
            TOTAL COSTS                        $13,900         $19,400

F.I.1.4   Facilities Design

     Facilities must be designed to comply with the program requirements.  In
the case of established facilities, modification drawings must be prepared to
                                       F-4

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accommodate equipment and specify space requirements.   These costs include the
structural, architectural, mechanical, and electrical design of facilities
that meet the requirements of each community.   Normally this cost is 10 percent
of the total construction costs per facility.   However, because of similarity
of facilities designs the estimated costs are  reduced to 5 percent.

F.I.1.5   Training Plan Development

     A training plan must be developed and would include theory of operation
of the test equipment and the procedures to be followed during the conduct of
the inspection at each of the work  stations within a lane.  Anticipated cost
elements include the development of the  training program, any equipment and
documents essential to the training course, and class scheduling are:

     a.   Idle-mode                     $3,500
     b.   Loaded-mode                    5,000
     c.   EPDI test                      7,500

     The cost was developed from course development in the State of California
and from various training centers.

F.I.1.6   Personnel Selection

     Based on the personnel requirements analysis conducted for each of the
applicable option configurations, a complement of technical and administrative
personnel is identified.  The cost to staff the individual facilities would
consist of those personnel costs to recruit and hire the complement of personnel
needed for the program.  These costs are:

     Establish Requirements
       510 person hours x $20 per hour                      =  $10,200
     Advertise Personnel Vacancy
       40 person hours x $20 per hour                       =      800
     Review and Select Personnel
       900 person hours x $20 per hour                      =   18,000
     Advertisement Costs                                    =   14,000
                                                               $43,000
                                       F-5

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F.I.1.7   Document Preparation

     Document preparation include those costs associated with the clerical,
editorial, and copying costs in developing a program plan and Project Evaluation
and Review Technique (PERT)  chart to record the plans, schedule, and analytical
results associated with the planning and development phase.  These costs are:

     Document Preparation
       450 person hours x $20 per hour                 =  $ 9,000
       Reproduction                                    =    1,000
                                                          $10,000

F.I.1.8   Administrative Support

     Administrative support include those costs associated with the facility
construction, equipment purchase, personnel selection, and system installation
and checkout.  These costs are:

     5,200 hours x $30 per hour                             =  $156,000

F.I.1.9   System Integration, Checkout, and Certification

     System integration involves the interfacing of individual system elements,
which may have been procured from different suppliers, and the testing of
hardware and software as a total entity to establish  compliance with procure-
ment specifications.  The average costs per facility  are:

     a.   For Idle-Mode
            Test individual equipment
              10 hours x $25 per hour                  =   $  250
            Test Software
              10 hours x $30 per hour                  =     300
            Integrated test
              30 hours x $25 per hour                  =     750
                                                           $1,300
                                       F-6

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     b.   For Loaded-Mode
            Test individual system elements
              10 hours x $25 per hour                  =  $  250
            Test all hardware
              10 hours x 325 per hour                  =     250
            Test all software
              20 hours x $30 per hour                  =     600
            Perform integrated test
              40 hours x $25 per hour                  =   1,OOP
                                                          $2,100

     c.   For EDPI
            Software test                              =  $   0
            Hardware test
              6 hours x $25 per hour                   =     150
            Integrated test
             38 hours x $25 per hour                   =     950
                                                          $1,100

     Prior to receiving and testing the first vehicle, the entire inspection
system must be evaluated and tested by the State to establish conformity to
performance specifications.  Station certification would consist of a statisti-
cal sample vehicle run to ensure satisfactory performance.  The costs associated
for initial system certification by test mode of each lane are as follows:

     Idle-Mode  (or EPDI Test Mode)
       23.5 manhours x $25 per hour                    =  $  587
     Loaded-Mode
       27.5 manhours x $25 per hour                    =     687

F.I.1.10  Test Scheduling System Development

     Initial computer software development cost for test scheduling will be
$67,000.  This estimation is based on inquiries of several software service
companies.
                                       F-7

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F.I.2          CAPITAL COSTS (CONSTRUCTION)

     Implementation of an I/M program requires initial investment in capital
goods, such, as test facilities, equipment, supportive hardware and software.
Such investment applies only to the centralized inspection facility.  For the
decentralized private garage-operated inspection facility, the assumption was
made that improvements or modifications are not required.  Only the emission
inspection equipment needs to be purchased.   For the purpose of this report,
test facility construction costs are separated into the following five major
items:

     •    Land and Site Improvement
     •    Facility Construction
     •    Instrumentation
     •    Office Equipment
     •    Computer

F.I.2.1   Land and Site Improvement Costs

     Land Cost - The land area required for station placement must be purchased
if  not already owned.  This cost element requires special consideration,
regardless if State— or private contractor-operated.  In the case of the
service centers, the construction costs are zero.

     A number of issues, are extremely crucial in estimating land costs.  The
basic unit cost as established from real estate contacts is, for example, lot-
specific to the extent that the cost per square foot within any mile square
may vary by a factor of 3; within any city or town, the cost may vary by a
factor of 10 or more.

     Land cost used for this report was developed from information  supplied by
the State of Michigan.  It represents average cost in 1978 dollars  (Table F-3).
                                        F-8

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   Table F-3.   ESTIMATED PER SQUARE FOOT LAND COSTS FOR VARIOUS  POPULATION AREAS
     	AREA CHARACTERISTICS	   COST PER SQ. FT. NOMINAL VALUE
     Major Metropolitan  (greater than
       1 million vehicles)
          urban              .                        $5.97
          suburban                                    4.02
          rural                                        .50
     Submetropolitan  (between 200,000
       and 1 million vehicles)
          urban                                      $4.02
          suburban                                    1.00
          rural                                        .11
     Minor Metropolitan  (less than 200,000  vehicles)
          urban                                      $2.00
          suburban                                     .70
     Source:  State of Michigan

     Site Improvements - The site plan for a typical three-position, two-lane
idle-mode facility is presented in Figure F-l.  Cost for site .improvement and
minimal landscaping would be $1.30 per square foot (Dodge Report).

F.I.2.2   Facility Construction

     Facility construction costs may vary in accordance with specific design
features.  The layout presented in Figure F-l was considered the minimal
facility size for a three-position two-lane system.  On the average, the test
area and office space construction costs would be approximately $20 per square
foot (State of Michigan and Dodge Report).   Costs are estimated for a facility
with:

     •    Concrete structure and floor
     •    Finished office
     •    Overhead doors
     •    Painted walls
                                      F-9

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r&'^^MEW\!
 ^iV^r^UX1'-
 --V/' V->*' < ^vii '> V
DIMENSIONS  ARE  IN  FEET
                                                                          12
       Figure F-l. Three-Position, Two-Lane, Idle-Mode Inspection Facility



      Source:  California Air Resource Board
               SCI Evaluation Engineering
                                   F-10

-------
     The same conceptual floor plan depicted in Figure F-l, with different
size requirements, would be applicable to the one-lane facility and loaded-
mode inspection facility.  Facility space requirements are summarized as
follows:

                    IDLE-MODE                          LOADED-MODE
SPACE
Lot
Test
Area
Office
Area
One -Lane
14,300 sq. ft.
(130 ' x 110')
1,200
(80 ' x 15')
540
(361 x 15')
Two-Lane
16,250 sq. ft.
(130 ' x 125')
2,160
(SO1 x 27')
540
(361 x 15')
One-Lane
14,300 sq. ft.
1,440
(80' x 18')
540
(361 x 15')
Two- Lane
16,250 sq. ft.
2,640
(80' x 33')
540
(361 x 15')
The EDPI inspection facility has the same facility specifications as those of
the idle-mode inspection facility.  Land, site improvement, and construction
costs of the different test mode inspection facilities are presented in
Table F-4.

F.I.2.3   Instrumentation Cost

     Primary Test Equipment - Equipment recommended  for a particular test mode
must be purchased and installed.  The equipment and  support instrumentation is
interdependent with, and must be defined in terms of, the test mode and appli-
cable exhaust emission standards.  The inspection test system for an idle-mode
testing facility will include an exhaust sample handling subsystem and analyti-
cal instruments.  Depending on instrument specifications and measurement
accuracy, cost of test equipment ranges from  $2,300  to $18,000  (see Table F-5).
A representative equipment of $3,000 per lane was used for this report.  For
loaded-mode test, an additional $16,500 per lane was used to include a dyna-
mometer.  The SPDI test requires diagnostic capability and special tools in
addition to the regular idle test equipment.  This amounts to an additional
$6,000 per lane for SPDI test.

     Ancillary/Maintenance Equipment - In order to ensure accurate test
results, the instruments must be properly maintained and calibrated.  Also
                                        F-ll

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safety of operating personnel must be provided for.  The ancillary/maintenance
equipment includes:

     •    exhaust ventilation system                        ($5,000 per lane)
     •    hand tools                                        ($1,300 per lane)
     •    remote tachometer                                 ($  100 per lane)
     •    tachometer calibration and working gas            ($  150 per lane)
          Total additional cost per lane                «    $6,550 per lane

     The cost estimates of ancillary/maintenance equipment are, in general,
applicable to all test modes for the centralized options.

     Private Garage-Operated Facility Instrumentation Requirements - Existing
service centers, such as auto garages and gas stations, would need to acquire
emission analyzers, dynamometers  (for loaded -mode)" ,  and some accessories.   The
analysis presented in this report assumes all service centers would purchase
necessary equipment.  Cost estimates would be $3,656 per private garage bay
for idle-mode (or EPDI test mode)  and $20,156 per  bay  for  loaded-
mode.  It is assumed that participating garages already have a diagnostic
scope analyzer.

P.1.2.4   Office Equipment

     There will be administrative support equipment required in the inspection
facility to prepare inspection forms, record inspection data, and, where
required, to record receipt of inspection fees and keep  personnel  records.
Office furniture, equipment, and incidental office supplies will also be
needed to complete the facility administrative office.  Total cost assumed is
$1,500 per facility independent of facility size and test mode.

P.1.2.5   Computer Hardware and Software

     Hardware - For each facility, the costs of an automated system  (single-
processor) are presented in Table F-6.
                                        F-14

-------
          Table F-6.   STATION SUPPORT EQUIPMENT COST ELEMENTS AS NOTED

         Semi-Automated (per lane)
                        Item                   Number   Estimated Cost ($)
Keyboard input device
Analyzer system
Test condition display
Report printer
1
1
1
1
$ 2,000
5,000
4,000
2,500
                                                             $13,500

     2.  Automated (incremental cost per lane)

         Mini-computer                         1 Syst         12,000
           CPU, Internal Memory,
           Operating Controls
         Input/Output                          1 Syst          7,000
           Teletype
           Paper Tape
         Interface/Communications              1 Syst          7,700
           ADC, Multiplexer
           TTY Line Adapter
           Data Controls
         Spares                                                  300
     a
      For loaded test mode there is a ?4,460 additional cost for a NO
      analyzer (NDIR type), if required.
     For an automated system, the approach is to use the central computer as

an information retrieval and information storage system.  Test control,

decision processing, and data input/output could be regulated at each facility

by a mini-computer as shown in Figure F-2.  The operator would input an identi-

fication number to the central computer which would return the description of

the vehicle to the operator display, and the test and decision parameters to
the site processor.  If the description matches the test vehicle, the operator
gives his approval to proceed.  The facility computer maintains control over

the test until it is completed.  The pass/fail decision would be made by the

site processor, providing the appropriate outputs both on-site and to the

central computer for inclusion in the vehicle's file.  The central file is
necessary for the mass storage of information on all cars tested in the city.


     Software - The central computer would be one of the present on-line

systems available in the State of Michigan.  The costs, as established from

contact of software companies and past experience, of developing a computer
                                      F-15

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program to provide the input of between 75 to 145 characters per vehicle and a
statistical output report ara:

     •    $30 per hour plus a purchased program package at a total cost of
          approximately $100,000.

     •    Final operations could be manual or a stand-alone computer system
          which would provide output data regarding each vehicle that would be
          forwarded to the central administrative office for processing.
          Programming cost for the automated system would be approximately
          $8,000 in addition to the above.
F.I.3     CAPITAL COSTS  (OTHER)

F.I.3.1   Administrative Office Equipment

     The capital costs associated with administrative office equipment  (e.g.;
desks, chairs, typewriters, bookcases, reference tables, etc.) is approximately
$800 per person.

F.I.3.2   Quality Control Equipment

     Mobile Unit - The mobile inspection audit system costs per vehicle are
presented in Table F-7.  The mobile inspection system could also be used for
the idle-mode only to:

     •    Support station operation during station downtime.
     •    Referee activity in urban areas.
                                      F-17

-------
                       Table F-7.  MOBILE UNIT COSTS PER UNIT
	EQUIPMENT	                     COSTS
 1. Van                                                          $12,000
 2. Van conversion (electrical, cabinets, etc.)                    3,000
 3, Analyzer (NDIR)                                                2,600
 4. working gas (2-blend)                                            100
 5. Tachometer                                                       200
 6. Gravity master gas cylinders  (5)                                 700
 7. Tachometer calibrator                                            200
 8, Hand tools                                                     1,000
 9. Digital voltmeter                                                200
10. Hitch                                                            100
                                             Total               $20,100

     The calibration check will include a five-point curve check using 1 percent
gravity master gases, and correlation tests using the van engine and State-
owned analyzers.  The State-owned analyzers will have the same capability as
the station analyzers.  The costs as noted were developed from a vendor
survey.

     Referee Stations - Customer complaints will arise regarding the reliability
of emission test results, especially in cases where a vehicle fails an emission
test after the recommended repairs have been performed.  In order to resolve
complaints of this nature, a referee station can be used.   A referee
station will also provide an additional check on emission test facility instru-
mentation, engine diagnosis, and mechanic capability.  For customer conveni-
ence, as an alternate, the mobile test units could also to be used as a referee
station.  Upon receipt of a customer complaint and request for verification of
emission test results, an appointment would be made to conduct the verification
test at the test facility in question.

     To avoid an overload on the system, specific criteria will have to be
developed to screen complaints of possible validity for verification testing.
For example, vehicles which have failed after the recommended repairs were
performed and/or vehicles for which the recommended repair costs are above
some predetermined level, would be eligible for verification testing.
                                       F-18

-------
     A referee station with loaded-mode and diagnostic capabilities is the
unit used in costing in this report.  Figure F-3 presents such a station con-
figuration.  Correlation vehicles would be checked out at this facility.  The
referee station would be set up at a central area relative to the test stations.
The referee station could also be the distribution center for instrumentation
maintenance and parts supplies.  Costs of a referee station are presented in
Table F-8.


                       Table F-8.  REFEREE FACILITY COSTS

                                                            MINIMUM SYSTEM
                            ITEMS                             (LOAD/DIAG.)
     1.  LAND SITE IMPROVEMENT AND BUILDING COST*

           Land  (14,300 sq ft @ ?5.97/sq ft)                  $ 85,400
           Site improvement  (14,300 sq ft @ $1.30/sq ft)        18,600
           Building construction  (3,440 sq ft @ 20/sq ft)       68,800

     Subtotal                                                 $172,800

     2.  EQUIPMENT

           Dynamometer                                        $ 16,500
           Driver's Aid                                          5,000
           Analyzer bench                                       16,000
           Gases                                                   900
           Miscellaneous-barometer, wet S dry bulb,
               office equipment                              	300

     Subtotal                                                 $ 39,200

     TOTAL (1 and 2)                                          $212,000

      Location of referee facility was assumed within the major urban
      metropolitan areas.


     Correlation Vehicle - In addition to the regularly scheduled calibration
checks, correlation vehicles will be used to further standardize station-to-
station equipment.  An emission test performed using a highly standardized
correlation vehicle will provide a quality check on the entire analytical
system  {i.e.,; analyzer, sample collection system, tachometer, and inspection
personnel).
                                      F-19

-------

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Figure F-3.  Inner Office and Test Area of a Referee Facility
                           F-20

-------
     The costs of a correlation vehicle are presented as follows:


                       CORRELATION VEHICLE COST PER UNIT

1.  Vehicle:   360 CID engine                                     $5,000.00
              automatic transmission
2.  Propane conversion (Emco)                                      1,000.00
3.  Take-off power items (power steering,  brakes, windows,
              air conditioning, etc.)  and
              remove vacuum advance and alternator                  500.00
4.  Install recorder and sensing device to record fuel
              temperature,  carburetor and engine rpm              1,500.00
5.  Install torque meter                                            500.00
6.  Trailer                                                       1,200.00
                                                  TOTAL          $9,700.00


F.I.3.3   Consumer Complaint


     The consumer complaint program, as discussed in Section F.3.3 of this
Appendix, requires capital investment in three  (3) complaint inspection cars.
Total cost would be $15,000 or $5,000 per vehicle.
F.2.1     ANNUAL OPERATING COSTS


     Annual operating costs of an I/M Program include:


     •    Facility operating costs

     •    Quality control operating costs

     •    Support costs


     They are discussed in the following subsections.


F.2.1.1   Facility Operating Costs


     Primary operating costs of a facility are personnel costs and facility

maintenance costs.
                                      F-21

-------
F.2.1.1.1 Personnel Costs

     Personnel requirements and costs for 3-position, 1-lane and 3-position,
2-lane inspection facilities are presented in Table F-9 and F-10 separately.
These are applicable to all emission test modes considered.  In general, an
inspection facility requires a manager, one inspector at each work position,
and one clerk.

     For the purpose of operation management, regional centers are established.
These centers manage 7 to 15 inspection facilities.  Extra personnel require-
ments for a regional center are presented in Table F-ll.

F.2.1.1.2 Maintenance and Miscellaneous Costs

     Facility Maintenance - Included under this program element are costs
associated with electricity, heat, water, building services, insurance, office
supplies, inspection forms, etc.  These costs were developed from several
sources including equipment and facility power requirements, equipment manu-
facturers, the general literature, the prevailing utility  rates in the State,
average heating requirements data for similar facilities,  insurance costs,  and
general building service requirements from existing programs.  The costs per
facility for facility support are presented in Table F-12.
      Table F-12.  FACILITY SUPPLIES, UTILITIES,  INSURANCE,  PROPERTY  TAXES,
                      AND MAINTENANCE PER TWO-LANE  FACILITY*
                 COST ITEM          STATE        CONTRACTOR
                 Supplies          $1,000        $  1,000
                 Utilities          5,000          5,000
                 Insurance          1,500          1,500
                 Property Taxes         0          1,500
                 Maintenance        1,200          1,200
                   TOTAL          $8,700        $10,200
                 a
                  For one-lane  facility, an adjustment
                  factor of 0.67  should be  applied.
                                        F-22

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                             Table F-9.
   PERSONNEL REQUIREMENTS AND ANNUAL COSTS FOR A ONE-LANE FACILITY
    PERSONNEL CATEGORY

Facility manager
Mechanical tech. II
Mechanical tech. I
Clerk I

Total


NUMBER
REQUIRED
1
1
2
1
SALARY
INCLUDING
25% BENEFIT
FACTOR
$14,652
13,956
12,636
12 , 222



TOTAL
$14,652
13,956
25,272
12,222
 $66,102
                             Table F-10.
   PERSONNEL REQUIREMENTS AND ANNUAL COSTS FOR A TWO-LANE FACILITY
    PERSONNEL CATEGORY

Facility manager
Mechanical tech. II
Mechanical techn. I
Clerk I

Total


NUMBER
REQUIRED
1
2
4
1
SALARY
INCLUDING
25% BENEFIT
FACTOR
$14,652
13,956
12,636
12,222



TOTAL
$14,652
27,912
50,544
12,222
$105,330
                             Table F-ll.
  EXTRA PERSONNEL REQUIREMENTS AND ANNUAL COSTS FOR REGIONAL CENTER
    PERSONNEL CATEGORY
                a
Regional manager
Clerk I

Total


NUMBER
REQUIRED
1
1
SALARY
INCLUDING
25% BENEFIT
FACTOR
$30,680
12,222



TOTAL
$30,680
12,222
 $42,902
 Regional administrator would supervise approximately 7 to  15 facil-
 ities.  He would be responsible for second line consumer/technician
 problems.
                                  F-23

-------
     Equipment Maintenance - Annual equipment maintenance costs are presented
in Table F-13.  These estimates include maintenance costs for both manual and
automated systems.
     Table F-13.  EQUIPMENT MAINTENANCE COSTS PER LANE FOR AN IDLE-MODE
                      (EPDI TEST MODE) INSPECTION FACILITY
                                  (Per Year)

          	EQUIPMENT5	   AMOUNT

          A.  Manual System
                Maintenance                       $1,000

          B.  Automated System Additional Costs
                Computer maintenance              $1,350
                Total automated costs             $2,350

          a
           Maintenance costs are established from similar operations as
           10 percent of the cost of  the equipment.
          b
           Loaded mode sites would be 15 percent greater for equipment
           maintenance.
F.2.2     SUPPORT COSTS


     Costs in this category include:


     •    Program administration cost
     •    Data analysis cost
     •    Training cost


F.2.2.1   Administration Cost


     Administration  cost includes primary  support  in  the  form  of  manpower,

supplies, and office rent.


     Personnel Cost  - An I/M program will  be  administered by a program manager

who  will administer  the inspection  program through the  regional supervisors.

Regional managers are assigned  only to  the more  populous  regions, with one man
responsible  for  one  or more regions or  facility  manager supervising 7  to
15  facilities.
                                      F-24

-------
     The Program Administrative Office would coordinate the following functions;

     •    Legal activity

     •    Financial including purchasing, contract management (contractor
          only),  and accounting

     •    Public relations and information program

     •    Technical reports development and reporting

     •    Mechanic's training

     •    Operations and administrative personnel training, as appropriate

     •    Consumer complaint activities

     •    Fee collection and vehicle owner notification

     •    Certification/licensing of mechanics

     The personnel required are presented in Table F-14.  The administrative
personnel include the Office Manager and staff, the Quality Control Manager
and staff, and the Field Manager and staff.

     Supplies - Annual supplies for adminstrative personnel are estimated at
$100 per person.   For 15 administrative personnel the total cost is then
$1,500.

     Office Rent - Annual cost for rental space is $0.45 per square foot per
month.  The square-foot requirements per person is approximately 150 square
feet at a monthly cost per person of $67.50, or a yearly cost of $810.  For
the 15 administrative personnel total yearly cost is estimated at $12,150.
                                       F-25

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   Table F-14.   ADMINISTRATIVE PERSONNEL REQUIREMENTS AND ANNUAL COSTS
       PERSONNEL CATEGORY
 NUMBER
REQUIRED
   SALARY
INCLUDING 25%
BENEFIT FACTOR
  TOTAL
I/M Program Manager
Secretary (Clerk Typist III)
Clerk I
Environmental Engineer
Statistical Analyst
   1
   1
   2
   1
   1
  $37,692
   14,712
   12,216
   23,916
   23,916
$ 37,692
  14,712
  24,432
  23,916
  23,916
Quality Control  Manager (Adm. 15)
Environmental Engineer
Clerk - Typist I
Statistical Analyst
   1
   1
   2
   1
  $30,672
   23,916
   12,216
   23,916
$ 30,672
  23,916
  24,432
  23,916
Field Manager  (Admin. 15)
Clerk - Typist I
Environmental Engineer

  TOTAL
   1
   2
   1

  15
  $30,672
   12,216
   23,916
$ 30,672
  24,432
  23,916

$306,624
                                      F-26

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F.2.2.2   Data Analysis Cost

     Emission data collected will have to be reviewed and reports prepared
covering various subjects as the State of Michigan may recommend.  Such
coverage includes:

     •    Repair cost and status data (current repairs, emission repairs, etc.)
     •    Emissions data status HC, CO, and NO , as appropriate
                                              X
     •    Failure rates
     •    Warranty failures
     •    Complaint data
     •    Recall action
     •    Vehicle data
     •    Failure cause
     •    Retest status
     •    County status on emissions
     •    Operation effectiveness

     From such a list it appears that monthly, quarterly, or yearly reports
would involve a sizeable expense.  The costs for processing 145 encoded mes-
sages for 250,000 vehicles and a simple statistical report would be approxi-
mately $1,000.  To process all data associated with the above would cost in
the order of $11,000 to $15,000.  The associated cost to formalize the report
are:

     Technical layout and discussion                $50 per page
     Typing and editing                              $7 per page
     Printing and collating                       $0.10 per page

     A 250-page report would cost $15,500 for preparation and publishing
50 reports.  Total cost for complete quarterly reports with all noted items
would be approximately $30,000 to $35,000.  This could be reduced by publishing
one major report with quarterly supplements.  The annual cost would be approxi-
mately $45,000.
                                        F-27

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F.2.2.3   Training Coat

     Personnel training is a continuing process.  It is required to:                     '

     •    Train new and replacement personnel

     •    Upgrade inspection personnel in new techniques and automotive technol-         <
          ogy  changes.

     The costs noted here are for continuing instruction only, and costs are
estimated as $100 per employee per year plus $250 per year for new employee              (
assuming a 15 percent termination rate.  In equation form, this can be expressed
as:

          C   = $100 x Ne + $250 x Ne x 15% = $137.5 x Ne

Where:

          C   = Training cost
          Ne  = Number of employees


F.2.3     QUALITY CONTROL OPERATING COSTS

F.2.3.1   Personnel Costs

     In addition to the administrative quality  control staff, the quality
control section would require the field personnel complement presented in
Table F-15.

     The mobile unit quality control personnel  requirements are necessary  to
provide quality control audit of each  facility  at least once every  3 months.
                                        F-28

-------
                                Table F-15.
       QUALITY CONTROL FIELD PERSONNEL COSTS PER UNIT BASIS PER YEAR
       PERSONNEL CATEGORY
 NUMBER
REQUIRED
    SALARY
 INCLUDING 25%
BENEFIT FACTOR
 TOTAL
Mobile Control Unit (Per Unit)
  Instrument specialist
  Technician I

Total
   1
   1
   $13,956
    12,636
$13,956
 12,636

$26,592
Referee Station (per unit)
  Environmental engineer
  Diagnostic mechanic V
  Test technician (instrument)
  Clerk - Steno I

Total
   1
   1
   1
   1
   $23,920
    15,418
    14,586
    12,220
$23,920
 15,418
 14,586
 12,220

$66,144
Correlation Vehicle
No additional manpower required.
This unit would be a part ot the
mobile quality control audit team.
                                     F-29

-------
     The following methodology was used to establish mobile unit personnel
requirements:

     •    A minimum of four facilities would be checked per day.  This is
          based upon a 1/2-hour test time and 1-1/2 hours travel time per
          station.

     •    Each mobile unit requires one lead instrument technician and one
          support technician.

     •    The number of mobile quality control units would depend upon the
          number of stations required to service the vehicles for the various
          geographic options.

     •    Other functions:  as a referee substitute and support in the event
          of a breakdown.

     The quality control referee station is required to provide the  following
services:

     •    To investigate consumer complaints.

     •    To institute development practices to improve operation effectiveness.

     •    To provide a supplementary lane for overflow and support queuing
          problems.

     •    To initiate new practices related to new emission control  devices.

     •    To provide a diagnostic routine for establishing repair effective-
          ness and special problem review.
                                        F-30

-------
     The referee station number requirements was established on the basis
described as follows:

     •    One referee station for the following service entity:

                                                    Radius  (Miles)
               A.  Major Metropolitan Area               20
               B.  Submetropolitan Area                 30
               C.  Minor Metropolitan Area              50

     The correlation vehicle unit would be a part of the mobile quality
control audit units.  It would be used to establish correlation character-
istics from station to station, and to support the quality control audit of
problem stations.

     Direct personnel cost for quality control can be estimated by the following
equation:

          Quality control personnel cost =

               (mobile unit personnel |       / number of    \
               cost per year         I       1 mobile units I


              / Referee facility personnel \       / number of         \
              I cost per year              I       1 referee facilities]
               ~>a CQT     number of    \    ..-,.,,..    i number of          I
               26,592 x     .. -     .      + 66,144 x  I             .  .
               1           mobile units J               I referee facilities /

Note that administrative quality control personnel cost is included  in the
administrative personnel costs.
                                   F-31

-------
F.2.3.2   Supply Costs

     Annual supplies, C  , for quality control are estimated at $100 per
person.  Therefore:

          „     ,-i««    I mobile unit\     „•,„-    /Referee station \
          C   = $100 xl         ,   I   + $100 x  I         ,       \  *
           as           I personnel   I             I personnel       /

                $200 x  (# mobile units) + $400 x  (# referee stations)

F.2.3.3   Maintenance Costs

     Mobile Units - Annual nonpersonnel costs for operation of mobile units,
C  , are based upon 25,000 miles per unit at $0.15 per mile.
 mu

          C   = 25,000 x  ($0.15) x * mobile units) =
           mu
                $3,750 x  (# mobile units)

     Referee Lanes - Annual costs for maintenance of a referee facility, C  _,
include:

     Equipment maintenance - 5 percent of original costs,  (i.e.,  $2,000 per
year per referee station.
     Building maintenance - $2,500 per year per referee station.
     Thus, C   = $4,500 x  (# referee stations)

     Correlation Vehicle Maintenance Cost - Estimated maintenance cost  is
10 percent of the vehicle  capital cost, i.e.  $1,000 per year.
     Total  annual cost  estimates of quality  control maintenance,  C_  ,  are
                                                                   tm

          C,  = C   + C . +  $1,000
            fm    mu     rf
              = $3,750  x (#  mobile units)  +
                $4,500  x (#  referee stations)  +  $1,000.
                                        F-32

-------
F.3.1     COSTS OF ANCILLARY PROGRAMS

     This section presents estimated start-up and operating expenditures for
mechanic training, public information, and consumer complaint programs.  Each
program element will take advantage of existing State resources in the form of
personnel services, equipment, and procedures.  This will reduce the initial
cost burden to institute needed consumer protection measures.

F.3.1.1   Mechanic Training

     In order to develop costing data for starting a mechanic training pro-
gram, it was necessary to calculate the minimum number of mechanics required
to support emission repair activity.

     It is estimated that 5 million vehicles will require emission testing on
an annual basis.  Assuming a 30 percent failure rate, 1.5 million vehicles
will require some form of maintenance before reinspection.  If 39 percent of
all emission repairs are performed by "do-it-yourselfers" then the remaining
915,000 vehicles will be serviced by certified emission mechanics.  The minimum
number of mechanics required to service failed vehicles is calculated as
follows:

     # vehicles serviced/mechanic/year =  (8 hrs/day)(1 vehicle/1.54 hrs)
                                          (5 days/wk)(50 wks/yr)
                                       =  1,299 vehicles

     Assuming an 85 percent manpower efficiency, the actual number of vehicles
serviced per year is calculated as 1,104  vehicles.  Therefore, the estimated
number of mechanics required is calculated as follows:

     M    .            .           915,000  vehicles/year
     # mechanics required =  -————Lr-.—:	 • *—;	
                             1,104 vehicles/mechanic/year
                          =  829 mechanics
                                      F-33

-------
     If the emission repair work only occupies 10 percent of the total work
burden, then the minimum number of mechanics required to support the I/M
program is 3,290 mechanics.

     The program costs, and other relevant information, for training these
mechanics are shown in Table F-16.  These costs were developed by assuming
that at least 30 mechanics would enroll in programs administered by State
vocational instructors.

     The above costs can be defrayed by charging a tuition of approximately $5
per student producing $165,800.  This can be allocated to pay instructor fees,
support costs (audio-visual materials).
F.3.2     PUBLIC INFORMATION PROGRAM

     To estimate the costs associated with a public information program, all
states with experience in I/M public information programs were contacted.
From contacts and additional research, a full range of possible activities was
established and basic cost figures derived  (Table F-17).  It is important to
realize that the range of possible activities and comprehensiveness of public
information programs varies considerably.

     There are essentially two program elements that are widely used as  I/M
public information techniques.  One element is the use of radio and television
public service announcements, and newspaper advertisements.  A second tech-
nique is  the development of an information phamplet that is mailed, along with
vehicle registration form to vehicle owners.

     The  cost to subsidize an initial and ongoing I/M public information
program has been estimated at $0.25 per vehicle per year.  These  funds would
finance various different combinations of informative programming.
                                       F-34

-------
           Table F-16.  ESTIMATED PROGRAM COSTS FOR MECHANIC TRAINING


	COST CONSIDERATIONS	              COSTS


A.  Personnel planning, curriculum  development
       and class scheduling                                   $3,500.00


                                          b
B.  Support costs - audio visual materials                       200.00


C.  Personnel costs:  35 instructors                          35,700.00

    Total                                                    $39,400.00
 Number of classes required assuming 30 students per class is estimated
 8,290 mechanics/30 per class = 277 classes.

 Materials estimated at $200 per course, including handouts, projection
 slides, charts, etc.
c
 Assuming that 1 instructor can teach 2 classes per day or 8 new classes per
 month  (each class 19 hrs in duration), then the number of instructors
 required is calculated (277 classes) (1 instructor/8 classes mo.) =
 35 instructors.
d
 State vocational constructors receive $13,600/yr or $6.80/hr.  Each class
 will require 19 hrs instruction or $129/class.
                                       F-35

-------
           Table F-17.  PUBLIC INFORMATION  PROGRAM COSTS FOR ONE YEAR-
            PROGRAM TYPE
            COST DESCRIPTION
A.  ADVERTISEMENTS

    1.  Public Service Announcements
          Newspaper

          Television
          Radio


    2.  Pamphlet
          Development/preparation

          Printing

    3.  Bumper Sticker

    4.  Transit aids
Full page advertisement 172-inch @ 1.65
 per inch.
1-minute public service announce-
 ments @ $40 per 10-second or $240 per
 minute.
1-minute service announcements @ $200
 per minute includes radio and commission.
Artist  (logo and cover design) plus com-
 mission @ 20 hours.
Pamphlet printed on 20 Ib paper, 1 color,
 foldout 7-1/2" x 11"  (6 million copies).
Printed on 6 Ib all weather paper,
 1 color.
Space cost on 35 buses, $102 per month
 per bus  (both sides).
    PRESENTATIONS

    1.  Films

    2.  Slide Shows
    3.  Guest Speakers
Film development  (30-minute information
 film) .
Slide  show development  $500.
Use of existing public  relations per-
 sonnel minimizes  cost.
  Telephone  contacts to various advertisement agencies,  publishing houses,  and
  printers.
                                        F-36

-------
F.3.3     CONSUMER COMPLAINT

     Two major support services provided by the consumer affairs office would
involve complaint follow-up, and service industry field check.  Cost estimation
of these was based on California's program.

     The California Air Resources Board  (ARB) conducts service warranty field
investigations to ensure that new and used car dealers have not tampered with
the emission control devices.  It is estimated that over 6,000 vehicles are
checked each year prior to sale.  In addition, the ARB also conduct field
investigations of individual vehicle owner emission control warranty complaints,
this amounts to another 250 field investigations per year.  The 250 field
investigations account for only a small portion of the complaints received;
all of the remaining complaints are resolved over the telephone.  To accomplish
these tasks, the ARB has nine field investigators.

     In order to estimate program costs, it was necessary to make the  following
additional assumptions:

     •    Ten percent of the vehicles that initially failed the emission test
          (30 percent) would fail the after-maintenance retest.

          (0.10) x  (0.30) x  (5.3 x 106) = 159,000 vehicles

     •    Owners of those vehicles that  fail the after-maintenance retest
          would be the most likely to file complaints; therefore, there would
          be 159,000 possible complaints per year.

     •    Based on ARB's experience, most complaints could be resolved over
          the telephone by field investigators.  For this study, it is assumed
          that 90 percent would be resolved over the telephone; therefore
          there would be  (0.1) x 159,000 = 15,900 possible unresolved  complaints
          per year.
                                      F-37

-------
     Based on the above assumptions, it is estimated that three field investi-

gators would be sufficient to handle the telephone-resolvable complaints and

to direct the unresolved complaints to the appropriate referee stations for

further investigation.  Cost estimates in providing such services are presented

in Table F-18.


         Table F-18.  OPERATING COSTS ASSOCIATED WITH CONSUMER COMPLAINT

                   COST CONSIDERATIONS                              COSTS
        Operating
          a.  computer time sharing  1,250 hrs @ $300
              per hour                                             375,000

          b.  personnel
                3 field investigatorsa                              38,000
                1 statistician                                      10,000
                3 clerks                                            24,000

          c.  vehicle
                gas/oil                                              3,000
                insurance                                            1,000
          TOTAL                                                   $436,000

          mm personnel required f<
     telephone and investigating.
Minimum personnel required for handling consumer complaints over the
F.3.4     VEHICLE TEST SCHEDULING
     Table F-19 enumerates operating cost expenditures associated with vehicle

notification, vehicle scheduling, etc.  Operating costs include processing
registration files, computer time, vehicle owner notification, and postage.
                                        F-38

-------
       Table F-19.   ASSUMED COST EXPENDITURES FOR VEHICLE TEST SCHEDULING
                      COST CONSIDERATIONS             COST
                                           a
                  Annual Operating Expenses
                    Processing files
                     23,000 manhours x $30/hr      $  690,000
                    Computer time
                     18 hrs x $300/hr                   5,400
                    Notification, IBM cards
                     5 million cards                  625,000
                    Postage
                     $0.OS/notification               400,000
                      TOTAL                        $1,720,400
           vehicle registration costs are included in the analysis.
F.4.1     SUMMARY

     Cost data of an I/M program vary among program options.  Major factors
that affect costs are test mode, facility size, and operation type.  Table F-20,
F-21, and F-22 present a summary of cost data that were used for I/M program
option cost analysis.  Data in the tables are arranged by following the outline
of cost elements in Table F-l.

     Highlights of cost data in Table F-20, F-21, and F-22 related to program
options are:

     •    Except for capital costs and operating costs (Items 1.2 and II) of
          inspection facilities, cost data are essentially independent of
          operation types (i.e., state-operated, contractor-operated, or
          service center-operated).

     •    Administration related and quality control costs  (Items 1.3, II.2,
          and III)  are the same for all program options.

     •    Major different cost items among test modes are capital costs
          (Item 1.2).
                                      F-39

-------
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-------
                 Appendix G







DETAILED TEST LANE REQUIREMENTS BY TEST MODE

-------
LOV IDLE TEST LANZ REQUIREMENTS
         YE&R - 1983

              SOMBER OF LAKES

CCCJTTY
Alcona
Alger
Allagan
Alp ana
Ar.tr i3
Arsnac
3araga
3arry
Say
Sanzia
Semen
Branch
Calhoun
Cass
Ciarlevoix
Cheboyyan
Chippewa
Clara
Clinton
Crawford
2elca
Dickinson
Sacon
Saunet
G«r.es«e
Gladwin
Gogecic:
Grand Traversa
Gratioc
Hillsdais
Houghtan
Huron
Ingham
Ionia
losca
Iron
Isabella
Jackson
Kalamasoo
Kalkasica
:
-------
                       L0V  1DLS TSST LAME
                                       YEAR -  1983
(Continued)
                                            NDMBER OF  LAKES

COCNTY
L»neer
Leelanau
Lanawee
Livingston
Luce
Mackinac
Macomb
Manistaa
Marquatte
Maaon
Mecosta
Ma nominee
Midland
Missaukaa
Manroa
Montcala
Montaorancy
MusJcagon
Mawaygo
Oakland
Oceans
Ogamaw
Onconagon
Gscaola
Oscoda
Ctsego
Ottawa
Presequa Isla
Roscotraaor.
Saginaw
St. Clair
St. Joseph
Sanilac
Schoolcraft
Shiawassae
Tuacola
Van 3uran
Washtanaw
Wayne
Waxford
Foraitjn

Statewide
1.42
.33
2. IS
2. OS
.IS
.23
19.53
.56
1.51
.62
.62
.63
1.37
.21
3.19
1.07
.19
3.99
.73
23.71
.47
.33
.23
.41
.16
.35
3.77
.34
.42
5.34
3.32
1.36
.93
.22
1.66
1.25
1.32
6.41
61.74
.60
.30
Nooattain-
ment Counties Grand Raoida Lansing ?lint
1.42

2.13
2. OS


19.33

1.S1



1.37

3.19
1.07

3.99

23.71






3.77 3.77


5.34
3.32
1.36
.93

1.66
1.2S
1.52
6.41
61.74



Detroit






19. S3







3.19




23.71

















6.41
61.74


Total
                237.30
                               216.01
                                                 13.52
                                                                9.92
                                                                         11.61
                                                                                   119.73
                                               G-2

-------
LDV LOADED TSST LAME
          YEAR - 1983
                ^raM3EH OF LANES

COUNT?
Alcona
Alger
Allagan
Alpena
Antrla
Ax ana c
Baraga
Barry
Bay
3anzie
Berrien
Branch
Calhoun
Cass
Chariavoix
Chaooygan
Chippewa
Clara
Clinton
Crawford
Delta
Dickinson
Satan
Esnr.et
Genesee
Gladwin
Gogebic
Grand Traversa
Graciat
Hill5ca_a
Houghcon
Huron
Ingham
Ionia
losco
Iron
Isacella
Jackson
Kalamazoo
KaUcasica
Kant
Ksweenaw
Lake

Statewide
.29
.25
2.13
.95
.43
.37
.22
1.33
3.65
.33
5.36
1.16
4.43
1.40
.60
.50
.39
.62
1.53
.27
1.10
.79
2.29
.70
13.31
.49
.54
1.73
1.13
1.17
.90
1.10
a. os
1.30
.33
.42
1.15
4.45
6.46
.29
14 . 08
.37
.20
Nonactain-
aent Counties Grand Xacids Lansing Flint De'—oit


2.13




1.3S
3.65

5.36
1.16
4.43
1.40




1.53 1.53



2.29 2.29

13.91 13.31



1.13
1.17

1.10
3.08 3.03
1.30



4.45
6.46

14.03 14.03


                                             (continued)
                G-3

-------
                       tDV LOADED TSST lASg R£QaiH£.M£HTS (Continued)
                                        YEUl - 1983

                                              SCMBER OF LANES

COUNTY
L*o«.r
Laelanau
L*nawe«
Livingston
Luca
Mackinac
Macomb
Maiustas
Marquetre
Mason
Mecosta
Ma.iciiir.aa
Midland
MiasauKea
Monroe
Montcala
Montaorency
Musicagon
Newaygo
Oakland
Ocaana
Cgaraaw
Cntonagon
Cacao la
Cscoda
Otsego
Ottawa
Preseque laia
Hoscomnon
Saginaw
St. Clair
St. Joseph
Sanilac
Schooler aft
Shiawasse«
Tuscola
Van Suren
Washtanaw
Wayne
wexJord
Torsign

Statewide
1.70
.40
2.61
2.46
.17
.27
23.37
.67
1.92
.75
.75
.75
2.24
.25
3.32
1.23
.22
4.73
.90
34.39
.36
.45
.30
.49
.19
.42
4.52
.41
.31
7.00
3.93
1.63
1.12
.26
1.93
1.50
1.32
7.63
73.96
.72
.96
NonaCtain-
mant Counties Grand Rapids Lansing
1.70

2.61
2.46


23.37

1.92



2.24

3.32
1.23

4.73

34.39






4.32 4.52


7.QO
3.93
1.63
1.12

1.98
1.50
1.32
7.68
73.96



Flint Detroit






23.57







3.32




34.39

















7.53
73.96


Total
                234.25
                                253.77
                                                  13.60
                                                                11.90
                                                                          13.91
                                                                                    143.42
                                                G-4

-------
LDV SPDI TEST LANE REQUIREMENTS
         YEAR - 1983

          MOTOR VEHICLE POPULATION

COUNTY
Alcona
Alg«r
Allagan
Alpena
Antrim
Arenac
Baraga
Barry
Bay
Benzie
Berrien
Branch
Calhoun
Cass
Caarlavoix
Cheboygan
Chippewa
Clare
Clinton
Crawford
Delta
Dickinson
Saton
Snnet
Gens see
Gladwin
Gogebic
Grand Traversa
Gratiot
Hillsdala
Houghton
Huron
Inghan
Ionia
losco
Iron
Isabella
Jackson
:
-------
                       LDV EPDI TEST LANE REQUIHEMENTS  (Continued)
                                       YEAR - 1983
                                       MOTOR VEHICLE POPULATION

COOOTV
Lapeer
Lealaoau
Lenawve
Livingston
Luce
Mackinac
Macomb
Hanistee
Marquatte
Mason
Mecosta
Menominee
Midland
Missaukee
Monroe
Montcalm
Montmorency
Mu3kegon
Newaygo
Oakland
Ocaana
Ogemaw
Ontonagon
Oscaola
Oscoda
Otsago
Ottawa
Preseque Isle
HOSCOOBBOn
Sagxnaw
St. Clair
St. Joseph
San J. lac
Schoolcraft
Shiawassee
Tuscola
Van 3uran
Washtenaw
Wayne
Hex£ocd
Foreign

Statewide
7.26
1.70
11.14
10. S -
..74
1.16
100.56
2.36
3.22
3.13
3.13
3.22
9.54
1.08
16.28
S.44
.94
20.38
3.36
146.72
2.4
1.94
1.26
2.10
.32
1.30
19.26
1.74
2.16
29.36
16.94
6.94
4.76
1.12
8.46
6.4
7.76
32.76
315.56
3.06
4.08
Nonattain-
ment Counties Grand Rao ids Lansing
7.26

11.14
10.5


100.56

3.22



9.54

16.23
5.44

20.38

146.72






19.25 19.26


29.36
16.94
6.94
4.76

3.46
6.4
7.76
32.76
315.56



Flint Detroit






100.36







16.23




146.72

















32.76
315.56


Total
              1,212.68
1,130.94
                                                 79.32
                                                               50.76
                                                                         59.36
                                                                                   611.38
                                               G-6

-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
1. REPORT NO. 2.
EPA-905/2-79-003A & 003B
4. TITLE AND SUBTITLE
Evaluation of Motor Vehicle Emissions Inspection/
Maintenance Program for Michigan.
7. AUTHOR(S)
Gunderson, J., Randall, J. , Pan, G. , Vodonick, E.,
Bhatia, V. Saricks . C.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Pacific Environmental Services, Inc. and
2716 Ocean Park Blvd., Suite 3010 Systems Control, Inc.
Santa Monica, California 90405 421 E. Cerritos Ave.
Anaheim, Ca. 92805
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region V
230 S. Dearborn Street
Chicago, Illinois 60604
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
October 15, 1979
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
#68-02-2536
Task Order #7
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
      The State of Michigan,  pursuant to the Clean Air Act as amended (1977), is re-
quired  to  consider  an  Inspection/Maintenance (I/M)  program for part or all 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.  This study evalu-
ates  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 this study are presented in two volumes.  Volume I explores a
broad range  of I/M  options while Volume II performs a comprehensive evaluation of
costs and  benefits  for a matrix of 24 program configurations differentiated by
administrative mode, inspection procedure and scope.  As a result of the comparative
analysis,  a  short list of candidate options is proposed for further study.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Mobile Source Emissions
Inspection/Maintenance Program
18. DISTRIBUTION STATEMENT
Unlimited
b. IDENTIFIERS/OPEN ENDEDTERMS

19. SECURITY CLASS (This Report/
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COSATI Tield/Group

21. NO. OF PAGES
473
22. PRICE
EPA Form 2220-1 (Rev. 4—77)   PREVIOUS EDITION is OBSOLETE

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                                                         INSTRUCTIONS

   1.   REPORT NUMBER
       Insert the EPA report number as it appears on the cover of the publication.

   2.   LEAVE BLANK

   3.   RECIPIENTS ACCESSION NUMBER
       Reserved for use by each report recipient.

   4.   TITL E AND SUBTITL E
       Title should indicate clearly and briefly the subject coverage of the report, and be displayed prominently.  Set subtitle, if used, in smaller
       type or otherwise subordinate it to main title. When a report is prepared in more than one volume, repeat the primary title, add volume
       number and include subtitle for the specific title.

   5.   REPORT DATE
       Each report shall carry a date indicating at least month and year. Indicate the basis on which it was selected (e.g., date of issue, date of
       approval, date of preparation, etc.).

   6.   PERFORMING ORGANIZATION CODE
       Leave blank.

   7.   AUTHOR(S)
       Give name(s) in conventional order (John R. Doe. J. Robert Doe, etc.).  List author's affiliation if it differs from the performing organi-
       zation.

   8.   PERFORMING ORGANIZATION REPORT NUMBER
       Insert if performing organization wishes to assign this number.

   9.   PERFORMING ORGANIZATION NAME AND  ADDRESS
       Give name, street, city, state, and ZIP code. List no more than two levels of an organizational hiieaichy.

   10.  PROGRAM ELEMENT NUMBER
       Use the program element number under which the report was prepared. Subordinate numbers may be included in parentheses.

   11.  CONTRACT/GRANT NUMBER
       Insert contract or grant number under which report was prepared.

   12.  SPONSORING AGENCY NAME AND ADDRESS
       Include ZIP code.

   13.  TYPE OF REPORT AND PERIOD COVERED
       Indicate interim final, etc., and if applicable, dates covered.

   14.  SPONSORING AGENCY CODE
       Insert appropriate code.

   15.  SUPPLEMENTARY NOTES
       Enter information not included elsewhere but useful, such as: Prepared in cooperation with, Translation of, Presented'at conference of,
       To be published in. Supersedes, Supplements, etc.

   16.  ABSTRACT
       Include a brief (200 words or less) factual summary of the most significant information contained in the report.  If the report contains a
       significant bibliography or literature survey, mention it here.

   17.  KEY WORDS AND DOCUMENT ANALYSIS
       (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms that identify the major
       concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

       (b) IDENTIFIERS AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment designators, etc. Use open-
       ended terms written in descriptor form for those subjects for which no descriptor exists.

       (c) COSATI FIELD GROUP - Field and group assignments are to be taken from the 1965 COSATI Subject Category List.  Since the ma-
       jority of documents are multidisciplinary in nature, the Primary Field/Group assignment(s) will be specific discipline, area of human
       endeavor, or type of physical object. The application(s) will be cross-referenced with secondary Field/Group assignments that will follow
       the primary posting(s).

   18.  DISTRIBUTION STATEMENT
       Denote releasability to the public or limitation for reasons other than security for example "Release Unlimited."  Cite any availability to
       the public, with address  and price.

   19. &20. SECURITY CLASSIFICATION
       DO NOT submit classified reports to the National Technical Information service.

   21.  NUMBER  OF PAGES
       Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, if any.

   22.  PRICE
       Insert the price set by the National Technical Information Service or the Government Printing Office, if known.
EPA Form 2220-1  (Rev. 4-77) (Reverse).

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