EPA-450/2-74-005
August 1974
INSPECTION AND MAINTENANCE
OF LIGHT-DUTY, GASOLINE-POWERED
MOTOR VEHICLES:
A GUIDE FOR IMPLEMENTATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-74-005
INSPECTION AND MAINTENANCE
OF
LIGHT-DUTY, GASOLINE-POWERED
MOTOR VEHICLES:
A GUIDE FOR IMPLEMENTATION
by
Transportation and Land Use Planning Branch
Strategies and Air Standards Division
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
August 1974
LIBRARY
Environ. Prot
Edison, N»w Jersey 088 1/
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This report is issued by the Environmental Protection Agency to
report technical data of interest to a limited number of readers.
Copies are available free of charge to Federal employees, current
contractors and grantees, and nonprofit organizations—as supplies
permit—from the Air Pollution Technical Information Center, En-
vironmental Protection Agency, Research Triangle Park, N.C. 27711;
or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Va. 22151.
Mention of commercial products or trade names does not constitute
endorsement by the Environmental Protection Agency.
Publication No. EPA-450/2-74-005
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CONTENTS
Page
LIST OF FIGURES iv
LIST OF TABLES iv
ABSTRACT v
1. INTRODUCTION 1-1
Legislative Review 1-1
Air Quality Criteria, Air Quality Standards,
and Pollutant Characteristics 1-3
Extent of Problem 1-7
References for Chapter 1 1-8
2. INSPECTION AND MAINTENANCE PROGRAMS 2-1
Program Description 2-1
Instrumentation and Equipment 2-11
Program Effectiveness 2-12
Program Costs 2-19
Strategy Selection Factors 2-22
References for Chapter 2 2-25
3. LEGAL CONSIDERATIONS 3-1
Enabling Legislation 3-2
Rules and Regulations 3-3
References for Chapter 3 3-6
4. IMPLEMENTATION FACTORS 4-1
Agencies Involved 4-1
Implementation Schedule 4-4
Federal Assistance 4-8
Training 4-11
Potential Problems 4-14
References for Chapter 4 4-23
5. MONITORING AND REPORTING REQUIREMENTS 5-1
Monitoring 5-1
Reporting 5-7
Public Acceptance 5-9
References for Chapter 5 5-11
6. FEDERAL AND STATE PROGRAMS RELATED TO INSPECTION
AND MAINTENANCE 6-1
Programs Sponsored by Federal Government 6-1
Programs Sponsored by State and Municipal
Governments 6-3
References for Chapter 6 6-5
APPENDIX A. ENVIRONMENTAL PROTECTION AGENCY
REGIONAL OFFICES A-l
APPENDIX B. GLOSSARY B-l
BIBLIOGRAPHIC DATA SHEET C-l
m
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LIST OF FIGURES
Figure
2-1 Derivation of Emission Standards from Cumulative
Distribution of Emissions 2-18
4-1 Estimated Time Required for Implementation of State-
Owned Inspection Lanes Using Idle- or Loaded-Mode
Tests 4-5
4-2 Estimated Time Required for Implementation of Idle
Inspection at Licensed Garages 4-6
5-1 Example of Format for Recording Vehicle Emission
Information for Idle Test 5-3
5-2 Example of Format for Recording Vehicle Emission
Information for Loaded-Mode Test 5-4
LIST OF TABLES
Table
1-1 Summary of National Air Quality Standards
for Motor-Vehicle-Related Pollutants 1-4
2-1 Engine Parameter Inspection 2-10
2-2 New Jersey-Approved Manufacturers of Low Cost
Infrared Analyzers Suitable for Use in Repair
Garages 2-13
2-3 Initial Reduction in Pollutants Using Major
Inspection Strategies 2-14
2-4 Reductions in Atmospheric Emissions from Vehicles
Subjected to Emission Inspection 2-16
2-5 New Jersey Idle Inspection Standards 2-19
2-6 Costs of Equipment for Emission Inspection 2-21
2-7 Inspection Station Cost Estimates 2-22
2-8 Total Program Costs, State of California 2-23
5-1 Inspection and Maintenance Emission Data 5-9
IV
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ABSTRACT
This document is intended to provide guidance to Federal, State, and
local agencies concerned with implementing and monitoring an emissions
inspection and maintenance program for motor vehicles. The guide provides
a discussion of major inspection and maintenance methods, legal considera-
tions, implementation factors, monitoring and reporting requirements, and
Federal and State programs in the field.
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INSPECTION AND MAINTENANCE
OF
LIGHT-DUTY, GASOLINE-POWERED
MOTOR VEHICLES:
A GUIDE FOR IMPLEMENTATION
1. INTRODUCTION
This document is intended to provide guidance to Federal, State, and
local agencies concerned with implementating and monitoring an inspection
and maintenance program for motor vehicles. Before beginning discussion of
the various aspects of an inspection and maintenance program, however, a
brief review of the evolution of the fight against air pollution, with
emphasis on motor vehicle pollution abatement, might be in order.
LEGISLATIVE REVIEW
The U. S. Congress first responded to growing public concern over
declining air quality in 1955 through legislation authorizing a Federal
program of air pollution research and technical assistance to State and
local governments (PL 84-159). This legislation established a policy,
retained in all subsequent legislation, of giving State and local govern-
ments the fundamental responsibility for local air pollution control with
the Federal government providing leadership and support.
The first Congressional efforts to bring vehicle emissions under control
were initiated in 1961 with Public Law 86-493. This legislation authorized
the Public Health Service to conduct a study of pollution caused by vehicles
1-1
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and to report the results to Congress. An amendment to this law (PL 87-761)
authorized vehicle studies on a continuing basis. As a result of this
legislation, significant progress was made toward achieving an understanding
of the vehicle-related air pollution problem and developing methods for
control. By 1963, however, it became apparent that the progress in
scientific understanding was not being translated into improved air quality,
primarily because State and local governments had neither the resources nor
the authority to adequately cope with the problem.
Results of early studies authorized by Congress indicated that motor
vehicles were contributing significantly to overall air pollution levels.
Consequently, Congress passed an amendment to the Clean Air Act in 1965
authorizing the Department of Health, Education, and Welfare to set emission
standards for motor vehicles. Initial standards pertaining to crankcase
and tailpipe emissions from gasoline-powered motor vehicles became effec-
tive in the 1968 model year. The most recent Federal legislation, the
Clean Air Amendments of 1970, established more stringent new motor vehicle
emission standards to be effective in the 1975 model year for carbon mon*
oxide and hydrocarbons and in the 1976 model year for oxides of nitrogen.
Required compliance with these emission standards has been delayed until
1976 for carbon monoxide and hydrocarbons and until 1977 for oxides of
nitrogen. Although the establishment of these new motor vehicle emission
standards are a Federal responsibility, the States are responsible for
controlling, regulating, or restricting the use, operation, or movement of
registered or licensed motor vehicles. Consistent with this policy, the
1970 Amendments directly affect State and local transportation systems by
requiring State implementation plans to include land use restrictions and
transportation control where necessary.
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AIR QUALITY CRITERIA, AIR QUALITY STANDARDS, AND POLLUTANT CHARACTERISTICS
Air Quality Criteria
The 1967 amendments to the Clean Air Act required the Department of
Health,Education, and Welfare to publish criteria of air quality judged to
be requisite for the protection of public health and welfare. Air quality
criteria are an expression of the scientific knowledge of the relationship
between various concentrations of pollutants in the air and their effect
on man and his environment. Criteria are descriptive in that they delineate
the effects that have been observed to occur when the concentration of a
pollutant in the air has reached or exceeded a specific level for a specific
period of time. Such criteria provide the most realistic basis that is
presently available for determining to what point pollution levels must be
reduced to assure the protection of public health and welfare.
As scientific knowledge grows, air quality criteria will have to be
reviewed and, in all probability, revised. The Congress has made it clear,
however, that we are expected, without delay, to make the most effective
use of the knowledge we now have.
Air Quality Standards
The 1970 amendments to the Clean Air Act required the Environmental
Protection Agency (EPA) to promulgate national air quality standards for
each air pollutant for which air quality criteria had been issued. Air
quality standards are prescriptive. They prescribe pollutant exposures or
levels of effect that should not be exceeded in a specified geographic
area.
Air quality standards for motor-vehicle-related pollutants are provided
in Table 1-1.
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Table 1-1. SUMMARY OF NATIONAL AIR QUALITY STANDARDS
FOR MOTOR-VEHICLE-RELATED POLLUTANTS
Pollutant
Carbon monoxide
Nitrogen dioxide
Nitrogen dioxide
Photochemical
oxidants
Hydrocarbons
(non-methane)
Averaging
time
8-houra
l-houra
Annual
(arithmetic mean)
l-houra
3-houra
Primary and Secondary
standards
10 mg/m3 (9 ppm)
40 mg/m3 (35 ppm)
100 yg/m3 (0.05 ppm)
160 yg/m3 (0.08 ppm)
160 yg/m3 (0.24 ppm)
.Not to be exceeded more than once per year.
The hydrocarbon standard is a guide to developing State implementation
plans to achieve the oxidant standard. The hydrocarbon standard does not
ihave to be met if the oxidant standard is met.
Air quality standards are set at two levels, primary and secondary.
Primary standards establish how clean the air must be to safeguard human
health. Secondary standards establish how clean the air must be to prevent
damage to clothes, buildings, metals, plants, animals, etc. As shown in
Table 1-1, primary and secondary standards for motor-vehicle-related pollu-
tants are the same, which means that the levels set for each pollutant are
sufficient to protect both health and welfare.
The above standards are "national" in that they apply to all 50 States,
the District of Columbia, and three U. S. territories. These political
jurisdictions have until mid-1975 (1977 in some cases) to meet the
standards.
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Pollutant Characteristics
The four air pollutants discussed below are often called motor-
vehicle-related pollutants because they are emitted by motor vehicles and
because the amounts of these pollutants emitted by motor vehicles consti-
tute a major portion of the total of such pollutants emitted by all sources.
Carbon Monoxide - Carbon monoxide is the most widely distributed and the
most commonly occurring air pollutantJ Total emissions of carbon mon-
oxide to the atmosphere exceed those of all other pollutants combined.
Most atmospheric carbon monoxide is produced by the incomplete combustion
of carbonaceous materials such as fuels for vehicles, space heaters, and
industrial processes. Man's activities are, therefore, largely responsible
for carbon monoxide contamination.
The introduction of the internal combustion engine for transportation
and the development of a number of technological processes that produce
carbon monoxide have greatly increased atmospheric concentrations. Trans-
portation activities represent the largest source category. Concern has
now broadened from the acute and often lethal effects of temporarily high
concentrations of the gas to encompass as well as those effects that may
occur as a result of considerably longer exposures to much lower
concentrations.
Nitrogen Oxides - Among the various oxides of nitrogen, the most important
as air pollutants are nitric oxide and nitrogen dioxide. The term nitrogen
oxides usually refers to either or both of these two substances. Nitric
oxide and a comparatively small amount of nitrogen dioxide are formed under
high temperature conditions such as those that accompany the burning of
2
fossil fuels. They are emitted to the atmosphere from automobile exhausts,
furnace stacks, incinerators, and vents from certain chemical processes.
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These substances are also important in air pollution control because they
are involved in photochemical reactions in the atmosphere.
Mobile sources are the largest single source category, contributing
3
over 40 percent of all man-made nitrogen dioxide in the United States.
The next largest source is electric power generation, which is responsible
for nearly 20 percent of all man-made nitrogen dioxide.
Photochemical Oxidants - As initiated by sunlight, a series of complex
atmospheric reactions between hydrocarbons and nitrogen oxides lead to the
4
formation of new substances, among which are ozone and oxidants. These
substances are chemical entities detrimental to biological systems and
destructive to certain materials. The complexity of the atmospheric
reaction has led to differences in interpretation of experimental results
by researchers. These differences relate to the degree of reactivity of
various hydrocarbons and the effects of reactivity over a period of time.
The Chemistry and Physics Laboratory of the National Environmental
Research Center, Research Triangle Park, N. C., is conducting research in
these and other areas.
Hydrocarbons - Hydrocarbons are important in air pollution control, not
because of their direct effects, but because of their role in photochemical
reactions. Hydrocarbon emissions originate primarily from the inefficient
combustion of volatile fuels and from their use in processing certain raw
materials. It was estimated that the transportation source category
contributed 52 percent of the nationwide hydrocarbon emissions in 1968.
Organic solvent use was the second largest source category, contributing
about 27 percent, and industrial processes was third, contributing 14 per-
cent.
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EXTENT OF PROBLEM
By itself, the automobile appears to be a minor air pollution offender.
The amount of hydrocarbons, carbon monoxide, and nitrogen oxides emitted by
a single automobile is small compared with emissions from industrial
sources. However, the sheer numbers of automobiles operating daily cause
serious air pollution problems in many metropolitan areas. For example,
approximately 4 million vehicles, including trucks, were registered in
Los Angeles County in 1970, or one vehicle for every two people in the
county. If the present growth trend continues, there will be approximately
6 million vehicles in Los Angeles County by 1990. In the Greater Houston
area, 1.5 million vehicles were driven about 13 billion miles in 1971, and
over 1 billion gallons of gasoline and diesel fuel were consumed in the
process. These kinds of statistics make it obvious that pollution from
motor vehicles must be controlled.
Transportation control measures are of two basic types. Measures such
as bus/carpool lanes and parking restrictions are intended to encourage the
use of more efficient modes of travel, such as buses and carpools, instead
of the single-passenger motor vehicle. As a result of a shift to more
efficient travel modes, vehicle miles of travel (VMT) are reduced and the
pollutants emitted are reduced. Measures such as retrofits of emission
control devices and inspection and maintenance prior to registration are
intended to reduce the quantity of pollutants emitted by motor vehicles.
The latter of these measures, inspection and maintenance, is required
either by the State or EPA in most of the metropolitan areas that now
require transportation controls.
An inspection and maintenance program by itself is a control measure
that can bring about substantial reductions in automobile exhaust emissions.
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More importantly, however, an inspection and maintenance program serves as
a cornerstone in any effective mobile source control program. For example,
an inspection and maintenance program is basic to any retrofit program that
may be implemented. These programs will assist in assuring that the
vehicle emission reductions required by the Federal Motor Vehicle Control
Program are actually attained.
REFERENCES FOR CHAPTER 1
1. Air Quality Criteria for Carbon Monoxide. U. S. Department of Health,
Education, and Welfare, National Air Pollution Control Administration,
Washington, D. C. Publication Number AP-62. March 1970.
2. Air Quality Criteria for Nitrogen Oxides. Environmental Protection
Agency, Air Pollution Control Office, Washington, D. C. Publication
Number AP-84. January 1971.
3. Control Techniques for Nitrogen Oxide Emissions from Stationary Sources.
U. S. Department of Health, Education, and Welfare, National Air
Pollution Control Administration, Washington, D. C. Publication
Number AP-67. March 1970.
4. Air Quality Criteria for Photochemical Oxidants. U. S. Department of
Health, Education, and Welfare, National Air Pollution Control Admini-
stration, Washington, D. C. Publication Number AP-63. March 1970.
5. Air Quality Criteria for Hydrocarbons. U. S. Department of Health,
Education, and Welfare, National Air Pollution Control Administration,
Washington, D. C. Publication Number AP-64. March 1970.
6. Transportation Control Strategy Development for the Metropolitan
Los Angeles Region. Environmental Protection Agency, Research Triangle
Park, N. C. Publication Number APTD-1372. December 1972.
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7. Transportation Control Strategy Development for the Greater Houston
Area. Environmental Protection Agency, Research Triangle Park,
N. C. Publication Number APTD-1373. December 1972,
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2. INSPECTION AND MAINTENANCE PROGRAMS
The term inspection and maintenance covers a variety of strategies for
reducing air pollutant emissions from light-duty motor vehicles currently
in use by establishing procedures that will assure proper maintenance of
control devices by the motorist. Most of the approaches have two distinct
phases: an inspection phase, in which motorists are required to periodi-
cally present their vehicles for examination; and a maintenance phase, in
which vehicles that fail the examination must be taken to a garage for
maintenance to bring them into compliance.
PROGRAM DESCRIPTION
Three classifications cover the major alternative approaches in an
inspection and maintenance program: emission inspection, engine parameter
inspection, and mandatory maintenance. Emission inspection involves
sampling the exhaust gases from the vehicle being examined and passing
these gas samples through suitable analytical instrumentation to measure
the quantities of air polluting compounds they contain. If the concentra-
tions of these compounds all fall below the applicable emission standards,
the vehicle passes the examination. Tf the concentrations of any pollutant
are above the standard, the vehicle fails. Vehicles failing the test must
then be adjusted or repaired to bring the emissions into compliance.
Following the maintenance, it would normally be required that the vehicle
be resubmitted for an emission test to determine that it is in compliance.
Engine parameter inspection involves the examination of critical
engine components and adjustments to determine whether the engine is
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functioning according to the manufacturer's specifications. If the
vehicle fails to fall within the tolerances set by the specifications,
the vehicle must be adjusted or repaired to bring it within the tolerances.
If the required maintenance is performed by a certified mechanic, there
would be no necessity for returning the vehicle for reinspection.
Mandatory maintenance avoids the inspection phase entirely. In this
approach, the vehicle must periodically undergo specified maintenance pro-
cedures at an authorized garage. The maintenace procedures are designed to
correct or avoid the most frequent types of emission-related malfunctions
of vehicles of a particular make, model, and year of manufacture.
Before discussing the various inspection and maintenance programs, it
is perhaps y/orthwhile to discuss the alternate ways in which a State,
county, or municipal agency might structure an inspection and maintenance
program.
Operational Configuration
The broad configurations of inspection and maintenance programs are:
1. Publicly operated lane system.
2. Licensed garage system.
In the publicly operated lane system, the appropriate governmental
agency performs the inspection in publicly owned and operated facilities
set up for inspection of motor vehicles. The facilities may be exclusively
devoted to emission testing or may include other types of required inspec-
tion such as vehicle safety.
In the licensed garage system, the testing is performed by existing
private service or repair agencies within the repair and maintenance
industry. The facility is certified, licensed, and controlled by the
appropriate governmental agency.'
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Generally, it is assumed that any needed repair, adjustment, or
maintenance would be done by private service garages and dealerships.
In the case of the licensed garage system described above, the garage
performing the inspection could also do the required work to bring the
vehicle into compliance.
Emission Inspection
The two major considerations in performing an emission inspection
are the emission measurement itself and the vehicle operating condition
during the measurement.
Analysis of Vehicle Exhaust Gases - The air pollutants in automotive
exhaust of concern during inspection and maintenance are hydrocarbons,
carbon monoxide, and nitrogen oxides.
Hydrocarbons may be measured by either of two methods: infrared
absorption or flame ionization detection. Infrared instruments measure
the infrared energy absorbed by the hydrocarbons in the sample gas.
Although hydrocarbon molecules with complex banding structures cannot be
detected using infrared absorption, a number of simple hydrocarbons,
known as paraffins, exhibit strong infrared absorption peaks. Current
motor vehicle exhaust compositions exhibit a reasonably constant propor-
tion between the paraffins and total hydrocarbons. The infrared
instrument is sensitized for n-Hexane, and a measure of the paraffin
content is obtained which can then be related to total hydrocarbons using
the proportionality constant.
The flame ionization detection method depends on the fact that hydro-
carbons introduced into a sample gas generate electrons in a hydrogen
flame that can be detected as an electric current by applying a voltage
across the flame. Although the analysis is not affected by the presence
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of carbon monoxide, carbon dioxide, nitrogen oxides, or water, the proce-
dure is extremely sensitive to the precise control of the sample flow rate
through the analyzer.
The presence of carbon monoxide is determined by infrared absorption.
In this case the instrument is set to respond to the particular frequencies
of infrared radiation absorbed by carbon monoxide. It is, therefore, not,
affected by the hydrocarbons present in the gas because they absorb in a
different region of the infrared spectrum.
Nitrogen oxides are really two gases, nitric oxide (NO) and nitrogen
dioxide (NC^). The nitrogen oxides in exhaust gas freshly sampled from
an engine are almost entirely nitric oxide. However, if the sample stands
for more than a minute (as it does in some sampling methods), oxygen
present in the exhaust will oxidize a portion of the nitrie oxide convert-
ing it to nitrogen dioxide. This tendency for the nitric oxide to convert
to nitrogen dioxide complicates the measurement of nitrogen oxides. Nitric
oxide can be determined by infrared absorption. However, because water
absorbs infrared radiation fairly strongly in the nitric oxide absorption
region, the gas must be first passed through a dessicant to remove all
water.
Nitrogen dioxide can be measured by ultraviolet light absorption, but
the method lacks sensitivity. When the infrared and ultraviolet absorption
instruments are used, the individual concentrations are summed to give the/
total concentration of nitrogen oxides.
In recent years, chemiluminescent instruments have become available
for nitrogen oxide measurement. They depend upon the fact that when
nitric oxide is mixed with ozone, the nitric oxide rapidly converts to
nitrogen dioxide emitting light in proportion to the concentration of
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nitric oxide present. The emitted light is measured with a photomultiplier
tube. To make the instrument measure total nitrogen oxides, the sample gas
is first passed through a stainless steel or molybdenum tube at high tem-
perature to decompose any nitrogen dioxide present back to nitric oxide.
By this procedure all the nitrogen oxides are present as nitric oxide as
they pass into the ozone reaction chamber.
This method requires a means of generating ozone and the careful
control of pressures. There may also be interference from carbon monoxide
under certain operating conditions. The chemiluminescent method is
specified in the Federal motor vehicle certification regulations for
measuring exhaust from gasoline-powered engines.
Exhaust gases contain about 15 percent water and varying levels of
particulate matter. At room temperature the water will condense in
sample lines and within the instruments. This condensation along with
the entrained particulate matter will quickly cause an analytical instru-
ment to malfunction or give erroneous readings. It is customary, therefore,
to provide a water trap to condense excess water and a filter to remove the
particulate matter. For the delicate research-grade instrumentation
commonly used in the Federal test procedure for new vehicle certification,
elaborate refrigerated condensing systems and high-efficiency glass fiber
filters are used. For the simplest instrument used by garage mechanics for
diagnostic tests, simple ambient temperature knockout traps and ceramic
filters will do the job.
The sampling system in its simplest configuration is a hand-held
metal probe attached to the instrument system with flexible tubing. A
gas pump pulls gas through the probe, the clean-up system, and the analyti-
cal instrument. Typically the concentration is expressed as volume percent
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for carbon monoxide and parts per million by volume for hydrocarbons and
nitrogen oxides.
If emission measurements that will correlate more closely with results
that would be obtained by the Federal certification procedure and provide
the same units in grams/mile are desired, a constant-volume sampling system
would be used. This system has the effect of weighting emissions at each
driving condition by the flow rate of exhaust gas at that condition. It
automatically weights and averages the emissions collected over changing
operating conditions. It also allows correct comparison of emissions from
different engine sizes. Although this procedure would provide the most
accurate results, the systems are generally large and expensive and are
only feasible where a large number of vehicles are to be processed by
each system.
Vehicle Preconditioning- Preconditioning of the vehicle is important in
achieving repeatable and meaningful results. In the Federal test procedure,
the vehicle must stand inoperative for at least 12 hours within a specified
range of ambient temperatures before the engine is started and the emission
measurement begun. This procedure, called a cold start, brings into play
the effect of choke setting on emissions.
An alternate procedure, referred to as a hot start, is to start the
test with the vehicle at or near its normal operating temperatures. For
in-use vehicle emission inspection, however, both these procedures require
more time than is normally available. Because it is not reasonable to
require the car to stand for 12 hours until inspected, some variation of
hot test preconditioning is necessary. In the case of an idle test, EPA
requires that the engine be in a warmed-up condition prior to testing. This
conditioning can be helpful if vehicles have been standing in an inspection
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line idling for some time before the start of the test. When a loaded mode
test is used, there can be some short running at a higher speed under load.
Vehicle Operating Modes - The choice of the mode or modes of operation over
which the sample is taken determines how closely the emissions measured by
the inspection procedure correspond to or correlate with the emissions to
the atmosphere from vehicles in normal use. The test modes also determine
the amount of diagnostic information the test will provide in the case of
a vehicle failing the inspection test.
An operating mode is a period of operation over which the vehicle is
either running at a constant speed or undergoing an acceleration or decel-
eration. A constant speed or cruise mode would be defined by the speed and
the time interval over which it was maintained. Idle is a constant speed
mode of zero speed. An acceleration or deceleration mode, called transient
mode, could be typified by the speed of the vehicle at the start and end of
the mode and the time interval between the two speeds.
An inspection may consist of sampling exhaust gases at one or more
modes. Up to a point, the greater the number of modes examined, the
better the correlation with emissions to the atmosphere and the more
diagnostic information available.
The idle mode is commonly referred to as a no-load mode because there
is little or no resistance to the running of the engine. All other modes
are considered loaded because wind resistance, rolling friction, and engine
friction all put a load on the engine. A chassis dynamometer is used to
simulate the action on the engine of running on the road.
A chassis dynamometer consists of a pair of parallel rollers that
support the rear wheels of the vehicle under test. The car can then be
placed in gear and the rear wheels driven on the rollers while the vehicle
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stands in place. Adjustable, heavy, inertia! weights are attached to the
rollers to resist changes in speed, thus simulating the weight of the
vehicle. Also, a power absorption unit is usually attached to the rollers
to resist their rotation and thus simulate wind and other resistances to
the motion of a vehicle. With a chassis dynamometer, it is possible to
fully simulate the engine behavior for a vehicle on the road while the
vehicle stands in place—a great convenience for emission testing.
An idle mode inspection test is the simplest emission inspection that
can be performed. It requires the simplest instrument system and needs no
dynamometer. Pass or fail can be indicated by lights on the instrument
set to activate at the fail points. The inspector need only indicate which
pollutants were above the standard. There is no need to indicate how far
above because there is little or no diagnostic content in this information.
The test should be completed in approximately 2 minutes in a licensed garage
inspection and in less than 1 minute in a lane inspection.
Loaded-mode emission tests with a dynamometer allow for a variety
of test cycles. One of the well known test cycles is the Clayton key
mode test. In this test emissions are measured under each of three
successive constant speed modes, 50 mph, 30 mph, and idle. The power
absorption is set proportional to the third power of the road speed
giving a high loading of 30 horsepower at 50 mph. Under this condition
the vehicle is at a higher load than would be experienced in level road
operation. The high engine loading is said to provide better diagnostic
information than a normal load. Fail limits can be set for each of the
conditions or for a linear combination of them. In any event, the read-
ings at all three conditions should be given to the vehicle owner on a
card so that a mechanic can use them in performing the needed maintenance.
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An example of how a mechanic might use this information is as follows: a
normal hydrocarbon level at idle and a too-high level at high speed points
to electrical problems. The reverse would indicate incorrect adjustment
of the carburetor at idle. Alternatively, a card indicating the probably
faults may be supplied.
Because only cruising speeds are used, the dynamometer for a key mode
test does not require inertia! weights. The result is a substantial re-
duction in the cost of equipment and elimination of the need to set inertial
weight for each vehicle.
The driving cycle may also involve transient operating modes. An
p
example is the so called ACID (Accelerate-Cruise-Idle-Decelerate) cycle
in which the emissions are measured while the vehicle is accelerated at a
constant rate to 30 mph, held at 30 mph, decelerated at a constant rate
to idle, and held at idle for a specified time. This cycle was designed
to operate with a constant volume sampler. Because the loading is not as
severe as with the key mode, it may not be as valuable a diagnostic tool.
The ACID cycle requires a dynamometer with both power absorption and
inertial weights so that it responds properly to the acceleration and
deceleration modes. Use of inertial weights increases the costs sub-
stantial ly.
Engine Parameter Inspection
The second major alternate strategy for inspection and maintenance is
the inspection of selected engine parameters to discover any departures
from manufacturers' specifications. Only those parameters that have an
impact on vehicle emissions need be inspected. Table 2-1 shows the signi-
ficant parameters influencing carbon monoxide and hydrocarbon emissions
3
for precatalytic emission control systems identified in one study.
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Table 2-1 ENGINE PARAMETER INSPECTION3
Subsystem
Engine parameter
Equipment
requirements
Idle adjustments
Secondary ignition
Induction
% carbon monoxide at
idle and timing
Plugs, wires, and
distributor
Air cleaner
PCV valve
Air injection
system
Infrared carbon
monoxide analyzer;
Tachometer and
timing light
Electronic engine
analyzer
Air cleaner tester
Pressure gauge
Air flowmeter
An infrared analyzer is used in measuring the idle adjustments. Here
the instrument is being used as an air-fuel ratio meter rather than as
an emission measurement, device. With the adoption of devices for con-
trolling nitrogen oxides and with the use of catalytic devices to meet
1975 and later standards, additional parameters will have to be added to
those in Table 2-1.
A check of the subsystems in Table 2-1 represents an extensive and
costly inspection procedure. Depending upon the extent of emission re-
duction expected from inspection and maintenance, a less extensive system
might be substituted.
Failure limits would be established based on manufacturer's speci-
fications, but this does not guarantee identification of all the high
emitters. The engine parameter inspection strategy specifically identifies
the maintenance to be done and, in effect, combines inspection and diag-
nosis. This also means that the car need not be reinspected if it is
repaired at a certified garage.
2-10
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Mandatory Maintenance
Mandatory maintenance eliminates the inspection step by simply re-
quiring that certain replacements and adjustments be made to the engine
periodically. This maintenance can include replacement of spark plugs,
points and condenser, air cleaner filter, catalyst, etc. and adjusting
timing, air fuel ratio, air pump belt tension, etc. In the area of ad-
justments, manufacturer's tolerances would still have to be followed so
that mandatory maintenance does not eliminate the inspection phase but
rather, makes it an integral part of the maintenance. In effect, the
certified mechanic who does the maintenance is also the inspector. Al-
though this is a simplifying step, it may result in more maintenance than
is needed to achieve the desired control of emissions from the in-use
vehicle population.
INSTRUMENTATION AND EQUIPMENT
The necessary technology for conducting vehicle inspections and re-
quired maintenance has reached a point where a State has a full range of
alternate systems to choose from without the necessity of sponsoring an
extensive development effort. The scientific instrument, computer, dyna-
mometer, and garage service industries have participated in various inspec-
tion and maintenance programs over the last 7 years and have developed a
substantial capability.
The following companies have been involved in the design and manu-
facture of emission test systems (not to be confused with manufacturers
of individual system components) for inspection and maintenance programs
and may be consulted on the overall system design:
1. Automotive Environmental Systems, Inc.
2. Beckman Instruments, Inc.
2-11
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3. The Bendix Corporation, Environmental Science Division
4. Horiba Instruments, Inc.
5. Interteck Corporation
6. Olson Laboratories
7. Sun Electric Corporation
8. Scott Research Laboratories, Inc.
The need for low cost infrared analyzers for measuring carbon monoxide
and hydrocarbons that would be suitable for use in idle emission inspection
and by repair garages has spurred a major and successful effort by the
instrument industry to develop practical devices. Consequently, a large
number of good instruments are now available. For example, Table 2-2
lists the infrared instruments currently approved by New Jersey for use
in repair garages. These same instruments would be suitable for inspection
in a licensed garage inspection system.
PROGRAM EFFECTIVENESS
The three main inspection and maintenance programs are compared in
Table 2-3 on the basis of reductions in emissions obtained immediately
4
following required maintenance. The data shown for the exhaust emissions
inspection are a combination of results obtained using idle- and loaded-
mode inspection tests. The data show that, for each of the three general
programs, it is possible to achieve significant reduction in hydrocarbons
and carbon monoxide in rejected vehicles that have been serviced, that
is, vehicles on which corrective maintenance was performed. No signifi-
cant improvement in nitrogen oxide emissions occurred for the pre-1972
vehicles tested. Because inspection and maintenance programs have so
far shown little or no effect in reducing nitrogen oxide emissions, the
emphasis in this and the remaining chapters will focus on reductions of
carbon monoxide and hydrocarbons.
2-12
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Table 2-2. NEW JERSEY-APPROVED MANUFACTURERS OF LOW COST INFRARED
ANALYZERS SUITABLE FOR USE IN REPAIR GARAGES
Supplier
Model
Allen Electric Company
American Motors Corporation3
American Parts Company
Atlas
Autoscan, Incorporated
Barnes Engineering Company
Beckman Instrument Company
Chrysler Corporation
Ford Motor Corporation
Kal-Equip
Marquette Manufacturing Corporation
NAPA Balkamp
Horiba Instruments Limited
Peerless
Stewart-Warner
Sun Electric Corporation
Womaco-Yanaco
Emission Analyzer Model 23-060
series and 23-070 series
AMserv Model 23-067 series and
23-077 series
Powerready Infrared HCKO Analyzer
Model 370-400
Exhaust Emission Tester Model 340
CO and HC Analyzer Model 710
and 4030
Emission Analyzer Model 8335
HC/CO Vehicle Emissions Analyzer
Model 590
Technican Service Equipment
Program. Model DCE-75, 23-066
series and 23-076 series
Rotunda Equipment Program
Rotunda Analyzer Model BRE-42-730
and BRE-42-731
HC/CO Infrared Emissions Analyzer
Model 4094-C
Emissions Analyzers Model 42-151 and
42-153
Infrared HC/CO Emissions Analyzer
Model 14-4787
Engine Exhaust Analyzer Models
CSM-300 and Mexa-300
Infrared Exhaust Gas Tester Model 600
Infrared Gas Analyzer Model 3160-A
Sun EET-910, U-912, (J-912-I, and
EPA-75 Exhaust Emission Testers
Exhaust Gas Analyzer Model EIR-101
Available only in new car dealers of the company.
2-13
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2-14
-------
Comparisons are made of initial reductions immediately following
maintenance—both for the vehicles that were serviced and the total fleet
(serviced and unserviced). The latter measure is a better indicator of
reductions in emissions to the atmosphere.
Based on the reductions in the serviced vehicles only, the ex-
haust emission inspection strategy (Table 2-3) appears to be substantially
more effective than either of the other two programs in the initial re-
ductions in the serviced vehicles. However, to get a more accurate com-
parison of the effectiveness of the three different types of programs, the
emission reduction for the total vehicle fleet should be considered. Based
on this comparison, the exhaust emission inspection is still substantially
more effective than the other programs. When the costs expected to be in-
curred by the average vehicle owner (see "Costs per Vehicle Inspected") is
included in the comparison, the exhaust emission inspection clearly has a
cost/effectiveness advantage.
Reductions in Atmospheric Emissions
Before data such as those shown in Table 2-3 can be translated into
reductions in emissions to the atmosphere, it is necessary to account for
deterioration in emission levels of a newly serviced vehicle as the
vehicle detunes during subsequent use. Unfortunately, there is an absence
of good experimental data in this area. The deterioration rate varies
widely in character and level from one vehicle to the next and even within
a given vehicle over time. Available data suggest that the simple assump-
tion of a linear deterioration rate over a period of a year is not grossly
in error, however. On this basis, Table 2-4 was developed to show the
percentage reductions in emissions to the atmosphere from a vehicle popu-
lation subjected to annual vehicle emission inspection.
2-15
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Table 2-4. REDUCTIONS IN ATMOSPHERIC EMISSIONS FROM VEHICLES
SUBJECTED TO EMISSION INSPECTION
(percent)
a,4
Emission inspection
Idle inspection
Hydrocarbons
Carbon monoxide
Loaded-mode inspection
Hydrocarbons
Carbon monoxide
Initial failure rate,'3 percent
10
6
3
8
4
20
8
6
11
7
30
10
8
13
9
40
11
9
14
11
50
11
10
15
12
No comparable information is presently available for emission parameter
inspection or for mandatory maintenance.
Initial failure rate is as an index of the severity of the emission
standard that would be set to achieve the levels of reductions in
emissions shown.
Establishment of Pass/Fail Standards
Table 2-4 can be used as a basis for establishing emission standards
for an emission inspection program. First, the percentage reduction in
emissions for carbon monoxide and hydrocarbons that will be needed with
the inspection and maintenance program is determined. This consideration
is part of the overall transportation plan. Once this figure is estab-
lished and a decision made as to whether an idle inspection or loaded
mode inspection will be used, Table 2-4 can be consulted to determine
what initial failure rates for hydrocarbon and carbon monoxide are
needed to obtain the desired reductions in emissions. It will then be
necessary to run an experimental program to define the distribution of
emission levels of the vehicle population. A cumulative distribution
of the kind shown in Figure 2-1 is then constructed.
2-16
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From the emission distribution of the vehicle population, the
emission standard (normally expressed as a mass emission such as percent
concentration or parts per million) that will yield the desired failure
rate can be determined. For example, suppose that the cumulative distri-
bution curve in Figure 2-1 represents the hydrocarbon emission distribution
for a vehicle population. Further suppose that the divisions on the hori-
zontal axis correspond to 200 ppm, 400 ppm, 600 ppm, and 800 ppm from left
to right on the axis. The dashed vertical line intersects the horizontal
axis at approximately 480 ppm for this example. Thus, about 80 percent of
the vehicles in the population will have hydrocarbon emissions of 480 ppm
or less. The other 20 percent of the vehicles will have emissions higher
than 480 ppm, and will fail the exhaust emission test. These vehicles will
require maintenance before their emissions can comply with the emission
standard.
Given the needed rejection rate, the standard can then be set.
Figure 2-1 illustrates the emission standard corresponding to an initial
rejection rate of 20 percent.
It needs to be emphasized again that initial failure rate is not
a prime consideration in setting the standard, but only an intermediary
between Table 2-4 and Figure 2-1 to get from the required reductions in
the atmosphere to the emission standard that will achieve that reduction.
Although this procedure can be applied to the vehicle population as
a whole, it is probably fairer to distinguish between vehicles according
to whether they have emission controls and according to the sophistication
of the emission control. This distinction obtains because an emission
inspection program is fundamentally trying to assure that a vehicle is
properly maintained and is not emitting pollutants in excess of its original
design intention.
2-17
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100
80
u
oc
LU
0.
LU
60
40
20
EXHAUST EMISSION LEVEL,
ppm or % concentration
Figure 2-1. Derivation of emission standard from cumulative
distribution of emissions.
New Jersey, for example, whose idle inspection program became fully
operational on February 1, 1974, has segregated vehicles into three classes
and developed the emission standards shown in Table 2-5.
These standards become increasingly stringent over time. An advantage
of starting with less stringent standards and tightening them is that it
gives both the public and the repair industry an opportunity to become
accustomed to the system before the standards come into full force. Most
States, however, are required to implement inspection and maintenance pro-
grams on an established schedule. This schedule, in most cases, will not
allow much time for starting with a low failure rate and easing into the
failure rate that is required.
2-18
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Table 2-5. NEW JERSEY IDLE INSPECTION STANDARDS
Vehicle model year
Pre-1968
1968 - 1969
1970 - 1974
Estimated failure rate, %
Effective
Feb. 1, 1974
CO,
%
10.0
8.0
6.0
HC,
ppm
1600
800
600
12-15
Effective
July 1, 1974
CO,
%
8.5
7.0
5.0
HC,
ppm
1400
700
500
25
Effective
July 1, 1975 ;
CO,
%
7.5
5.0
4.0
HC,
Ppm
1200
600
400
35
PROGRAM COSTS
The overall costs of putting an inspection and maintenance program
into operation will vary markedly from one situation to another. Some of
the specific costs, however, can be pinpointed with reasonable accuracy.
This section describes estimated costs on several bases to given an
appreciation of the nature of costs that will be faced.
Costs Per Vehicle Inspected
A useful view of overall costs that will have wide applicability
is to place them on a per-car-inspected basis. Annual emission inspec-
tion in State-operated lanes will cost about $2 per vehicle. Where the
tests can be incorporated into existing State safety inspection lanes,
costs can be still lower. In the case of licensed garages, costs have
been estimated in the range of $3 to $6 per vehicle for an idle emission
inspection. Performing an extensive engine parameter inspection in a
licensed garage will cost approximately $8 per vehicle.
Repair costs for an average car failing an emission or engine param-
eter inspection will be $20 to $30. An extensive mandatory maintenance
program could cost as much as $60 per vehicle.
2-19
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Costs of Instruments and Equipment for Emission Inspection I
As has been discussed, instrumentation and equipment for emission
inspection can vary widely from simple visual instrumentation to fully
automated systems. Table 2-6 shows the price range for systems that can
be used with idle- and loaded-mode inspection programs. The specific
systems shown do not cover all the possibilities. For example, on a State
lane there may be a desire to add a minicomputer for some added automation.
This could easily raise the price an additional $10,000.
Costs of State-operated Inspection Lane
Table 2-7 shows estimates of the investment and annual operating costs
of State-operated inspection lanes using the idle and key mode inspec-
tions. For both methods, it was assumed that processing of emission
data was semi automated. The equipment cost for the key mode is about
double that of the idle inspection when the automated data handling
is added. Without the addition of this feature, the cost is about
seven times greater for the key mode than for idle inspection. The
*
predominant operating cost is labor, which is the same for both methods.
Note, however, the distinctly higher capacity of the idle inspection
lane, which will lead to lower costs on a per-vehicle-tested basis.
Total Program Costs
Total costs for a State maintenance and inspection program would
also include costs for training, program planning, initial qualifica-
tion and certification of the inspection facilities, maintenance and
depreciation of the facilities, and the overall program administration
and enforcement requirements.
An analysis of cost has been performed for the State of California
and can serve as a general guide.4 The total program costs are summarized
2-20
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in Table 2-8. The testing capacity of the system is based on a yearly
inspection of a total population of 10 million vehicles.
Table 2-6. COST OF EQUIPMENT FOR EMISSION INSPECTION
Idle enission inspection
Infrared hydrocarbon/carbon monoxide instrument
(Simple meter readout with pass/fail lights)
$ 1,800
Loaded vehicle emission inspection
Loaded constant speed modes (Key Modes)
Simple instrumentation for HC/CO 3,000
Dynamometer with power absorption 5,000
Ventilation and exhaust disposal unit3 $ 4,000
$ 12,000
Constant speed acceleration and deceleration modes
Simple instrumentation 3,000
Dynamometer with power absorption and inertia 21,000
weights (direct drive)
Ventilation and exhaust disposal unita 4,000
$ 28,000
Fully automated system
Instrumentation
Automatic data treatment
CVS system
Dynamometer with power absorption and inertia weights
Ventilation and exhaust disposal unit3
$ 67,000
Repair garage instruments for carbon monoxide and $600 - $1,000
hydrocarbons
aThe ventilation and exhaust disposal unit is optional. However, because
this unit also protects inspectors and/or the general public from objects
that could be thrown by a dynamometer, the State may consider its use
desirable.
2-21
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Table 2-7. INSPECTION STATION COST ESTIMATES, 1971 VALUES3'5
Cost element
Investment Costs
Inspection equipment
Administration
Site acquisition,
($2/ft2)
Construction,
($8/ft2)
Total
Operating cost
(First year)
Personnel salaries
Supplies and
maintenance
Total
Station type
Idle mode
1 lane
$11,200
1,000
14,380
10,960
$37,540
$22,000
1,748
$23,748
2 lane
$22,400
1,700
20,000
16,320
$60,420
$44,000
3,186
$47,186
Key mode
1 lane
$20,000
1,000
21 ,800
16,320
$59,120
$22,000
2,216
$24,216
2 lane
$40,000
1,700
33,220
24,480
$99,400
$44,000
3,994
$47,994
aAnnual capacities of inspection lanes: idle mode-32,000 vehicles per lane,
key mode-25,000 vehicles per lane.
Inspection equipment costs have been updated from the original reference
to allow for higher cost of the absorption dynamometer ($6,000 increase).
STRATEGY SELECTION FACTORS
Three major alternative approaches to an inspection and maintenance
program have been considered. Variations of these programs and combinations
of them that have not been considered here are, of course, possible. The
EPA-and industry-sponsored APRAC CAPE-13 program explored a number of
programs experimentally and developed a cost/benefit analysis computer
program that could be helpful in deciding which program is most suited to
a given regional problem.
2-22
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Table 2-8. TOTAL PROGRAM COSTS, STATE OF CALIFORNIA6
($ x 103)
Cost element
Investment cost
Site acquisition and construction
Equipment and installation
Planning and training
Qualification and certification
Total
Operating cost (First year)
Salaries of inspection personnel
Salaries of administrative
personnel
Equipment maintenance and
depreciation
Facility maintenance and
depreciation
Program administrative costs
Total
Idle mode
7,117
4,090
112
745
12,064
6,635
631
1,214
256
1,243
9,979
Key mode
12,445
6,270
193
912
19,820
6,648
981
1,473
516
1,301
10,919
Estimated for California vehicle population (10 million).
It is clear, however, from the material presented in this chapter
that the emission inspection schemes are less costly than pure engine para-
meter inspection or mandatory maintenance programs and appear equally effec-
tive in reducing emissions from the vehicle population as a whole. The
emission inspection approach gives the added satisfaction of identifying
the high emitters and concentrating the maintenance action on them.
The chief problem with emission inspection procedures is that while
they identify the high emitters, they do not specifically identify the
2-23
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cause of the high emission values. This throws a substantial burden on the
repair mechanic who at present is not trained in identifying and correcting
the malfunctions or maladjustments leading to high emissions. In fact,
extensive studies have shown that mechanics are only about 50 percent effec-
tive in diagnosing and correcting emission problems. Furthermore, they
often over repair and over adjust in their efforts to assure that the
vehicle passes on retest. How severe this problem may be will not be
known with certainty until emission inspection is fully implemented in the
field. Clearly, where the emission inspection program is adopted, consider-
ation needs to be given to proper training of mechanics and to providing
them with diagnostic information where feasible.
Some States have been considering providing training for inspectors
and mechanics through community colleges. The automobile and oil companies
are aware of the problem and are beginning to provide training to dealer
garages and service stations.
The loaded-mode emission test does provide limited diagnostic infor-
mation. This benefit, however, needs to be balanced in a specific situa-
tion against the added complexity and cost over an idle inspection test. It
may also be true that vehicles failing a simple idle test may be brought
back into compliance more easily. Certainly the mechanic would be greatly
aided by the use of low-cost carbon monoxide/hydrocarbon instruments that
would allow him to directly verify the effect of his corrective actions on
the idle emissions.
Operational configuration is another major consideration. Will State
owned or franchised inspection lanes be used or will the inspection be done
in licensed, privately owned garages? The decision in many cases has al-
ready been made if the State has set up a safety inspection program. In this
2-24
-------
case it would be a simplification if the emission inspection could be in-
cluded in the sequence of safety tests. New Jersey, for example, has 38
State-owned safety inspection stations and has added its idfre emission test
at the beginning of the lane. Pennsylvania, on the other hand, employs
licensed, privately owned garages for its safety program. Should it decide
on an idle emission inspection it would appear reasonable to add the test
to the safety inspection test now performed in the licensed garages. How-
ever, should the State decide on a more elaborate loaded-mode test, it
would be necessary to construct State owned or franchised lane systems placed
strategically around the State.
REFERENCES FOR CHAPTER 2
1. Control Strategies for In-Use Vehicles. Environmental Protection
Agency, Research Triangle Park, N.C. Publication Number APTD-1469.
November 1972.
2. Elston, J.C., A.J. Andreatch, and L.J. Mislosk. Reduction of Ex-
haust Pollutants through Automotive Inspection Requirements -- The
New Jersey REPAIR Project. (Presented at International Clean Air
Conference on Air Pollution. Washington, D.C. February 1971).
3. TRW Systems Group. The Economic Effectiveness of Mandatory Engine
Maintenance for Reducing Vehicle Exhaust Emissions, Coordinating
Research Council, 30 Rockefeller Plaza, New York, N.Y. APRAC Project
Number CAPE-13. July 1972.
4. Title 40 - Protection of Environment. Part 51 - Requirements for
Preparation, Adoption, and Submittal of Implementation Plans, Appen-
dix N. Federal Register. 38 (110). June 8, 1973.
5. Mandatory Vehicle Emission Inspection and Maintenance. Vol III.
Northrop Corporation. Prepared for California Air Resources Board
under contract. May 1971.
2-25
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3. LEGAL CONSIDERATIONS
The 1970 amendments to the Clean Air Act give EPA the necessary legal
authority at the Federal level for carrying out pollution abatement efforts.
EPA has direct authority to set automobile emission standards and require
automobile manufacturers to meet those standards. Thus, Federal authority
preempts all State and local authority with regard to "new car" emission
levels. This preemptive authority, however, may be waived by the Administra-
tor, after notice and opportunity for public hearing, for any State that
has adopted emission standards (other than crankcase standards) for new
motor vehicles prior to March 30, 1966, unless the State does not require
emission standards more stringent than Federal standards. The Clean Air
Act intended that other transportation controls be implemented, monitored,
and enforced by State agencies. However, if a State fails to provide the
transportation controls that are considered necessary for achieving air
quality standards, EPA has the authority to require that State to provide
such transportation controls. Here again, the responsibility for imple-
menting, monitoring, and enforcing transportation controls would be placed
on the State, and the State must have or obtain the necessary legal author-
ity to conduct the programs.
For best results, the legal authority for an inspection and maintenance
program should be held by the State, especially if the program encompasses
a large number of vehicles spread over a wide geographical area. The
training requirements, the administrative and enforcement procedures, and the
financial requirements for facilities, equipment, and salaries are normally
such that in most cases local agencies may hesitate to implement an inspection
3-1
-------
and maintenance program unless a substantial number of vehicles would be
covered by the program. Some local agencies such as those in Chicago,
New York, and Washington, D. C. are planning inspection and maintenance
programs. In these cities, large numbers of vehicles in relatively small
geographical areas will be subject to inspection and maintenance.
Although the State agency may have the responsibility for carrying
out an inspection and maintenance program, the State may authorize local
agencies to carry out certain portions of the program such as testing,
compliance certification, performing maintenance, and enforcement. This,
however, does not relieve the State agency of the ultimate responsibility
for the program's operation. The State may also delegate authority for
certain portions of a program by licensing private businesses. The State
agency would, in all likelihood, want to establish certification, licensing,
and bonding of private repair facilities if they are involved in the in-
spection and maintenance program. This would ensure that sufficient equip-
ment, qualified personnel, and adequate facilities were available for
operating the program.
Effective control of an inspection and maintenance program requires
adequate legal authority under which enforcement actions can be taken.•
The legal authority may be divided into two major parts: the enabling
legislation of the State and the rules and regulations of the individual
air pollution control agencies within the State.
ENABLING LEGISLATION
Sound enabling legislation at the State level is an essential pre-
requisite in establishing the legal and administrative framework necessary
to organize, to staff and fund, to provide procedures for the passage of
rules and regulations, and to authorize enforcement actions. Imperfections
3-2
-------
in any enabling provision may cause delays and even failures in implement-
ing a control program. Enabling legislation that identifies specific
authority to be exercised by the agency responsible for the inspection
and maintenance program will be more likely to withstand challenges in
court. Some essential provisions include:
1. Adequate authority to adopt rules and regulations concerning:
a. Requirements for periodic inspection (should specify the
type of inspection such as emission, parameter, etc.).
b. Establishment of fees for providing the inspection service.
c. Withholding vehicle registration for those vehicles that do
not satisfactorily complete the inspection or do not comply
with an applicable variance.
d. Prohibition of tampering with control devices.
2. Adequate funds for implementing, monitoring, and enforcing the
inspection and maintenance program, if allowed by the State's
constitution.
3. Adequate authority to obtain pertinent data and information and to
require periodic reporting of emission information.
4. Authority to make emission reports and information available
for public inspection.
5. Authority to compel compliance with rules and regulations
supported by civil or criminal penalties.
6. Provisions for injunctive relief where deemed necessary.
RULES AND REGULATIONS
Regulations that specifically limit emissions of pollutants to
the atmosphere are of paramount concern in an inspection and maintenance
program. The nature and extent of emission control regulations are
3-3
-------
primarily determined by the air quality problem. The preparation and
application of emission regulations requires knowledge of the polluting
characteristics of motor vehicles and the type of program to be imple-
mented. This is especially important for enforcement personnel in docu-
menting violations for the purpose of legal actions. Inadequate under-
standing of concepts and applications can result in the loss of court
decisions, thus weakening the entire enforcement operation. Rules and
regulations are generally comprised of the following.
1. Test Procedures. These regulations specify the type of test to
be required (that is, idle, loaded, or parameter) and how often
vehicle owners must submit their vehicles for inspection. Additional
test procedure requirements are also desirable.
a. Idle procedures could include the type of measurement equip-
ment to be used and the engine revolutions per minute (rpm) at
which vehicles would be tested.
b. Loaded procedures are more complex than idle inspection methods
and thus, would require more information. An agency could
include such information as the modes through which vehicles
will be operated, the stabilization time for each mode if re-
quired, the appropriate equipment operation, and the emission
measurement procedures.
c. Parameter procedures could include the particular engine
parameters that «fould require testing and the criteria for
determining the need for maintenance or component replacement.
2. Emission Limitations. These regulations establish the rate of
emission above which a violation or test failure occurs. There may
be one emission limit applicable to all vehicles subject to the
program, or several limits based on vehicle age.
3-4
-------
3. Equipment Design Standards.. These regulations specify permissible
features, specifications, or standards relating to the design
of testing equipment or the prescribed use of such equipment.
The necessity for these type regulations is more prevalent for
a program in which private businesses participate in the in-
spection and/or maintenance operation.
4. Prohibition of Use or Operation. This type of regulation pro-
hibits the use of operation of motor vehicles that exhibit
emission rates in excess of the standards. Upon failure of a
vehicle to meet the standard, the owner or operator of the vehicle
is usually allowed some period of time in which to bring the
vehicle into compliance. There is usually a requirement for a
retest of failed vehicles or a certification to be produced by
the owner/operator that proper corrective maintenance has been
performed.
5. Vehicle Registration. This type of regulation prohibits the
registration of vehicles that fail to comply with applicable
emission limits or with a variance.
6. Inspection Fees. A State would normally desire to establish an
inspection fee that would cover the cost of performing inspections,
i whether the inspections are performed by the State or by
licensed private businesses.
7. Variance. Because of engine design or operating characteristics,
some motor vehicles may not be able to comply with emission
standards. In these cases, the air pollution control agency may
wish to exempt such vehicles from the compliance requirement.
An automatic exemption may be included for antique and/or classic
vehicles, for example.
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8. Tampering. To be effective, emission control devices must be
in good working order. A regulation to prevent intentional
tampering with or adjustment of devices or components required
by Federal or State law may be desirable. Appropriate penalties
should be included in the regulation for discouraging such tamper-
ing.
9. Powers. These supporting regulations are enacted to establish
right of entry, police powers, and requirements for submission
of information on pollutant emissions.
REFERENCES FOR CHAPTER 3
1. National Emission Standards Act. Part A-Motor Vehicle Emission
and Fuel Standards. Section 209 - State Standards. The Clean Air
Act. 42 U.S.C 1857 et seq. December 1970.
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4. PROGRAM IMPLEMENTATION
AGENCIES INVOLVED
The purpose of this section is to discuss the interagency relation-
ships in the implementation of an inspection and maintenance program.
Several types of agency relationships that already exist or are likely
to exist are presented and the benefits and problems of each type dis-
cussed.
Interagency relations are important because the development and
implementation of an inspection and maintenance program includes a
broad range of activities such as development of program procedures,
procurement of equipment, inspection of vehicles, enforcement of rules
and regulations, training of inspectors and mechanics, monitoring results,
and handling consumer complaints or problems. Usually one agency does not
have the resources or authority to carry out all these tasks without the
cooperation or assistance of other agencies. Therefore, it is important
to have good working relations among all the agencies involved.
The legislation authorizing the inspection and maintenance program
is an important factor in determining which agencies are involved. In
some cases, one agency is given total responsibility. That agency must
then obtain cooperation and assistance from other agencies as necessary
during development, implementation, and monitoring of the inspection and
maintenance program. In other cases, several agencies are charged with
a particular area of responsibility. The particular agencies specified
in the legislation are determined by factors such as the existence of a
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State vehicle safety inspection program, the current structure of govern-
mental agencies, and the legislator's ideas of the most workable arrange-
ment.
Several examples of existing inspection and maintenance programs are
available to illustrate which agencies can be involved and how these
agencies are interrelated. For example, the program in New Jersey involves
four agencies:
The Department of Environmental Protection
The Division of Motor Vehicles
The Department of Education
The Office of Consumer Affairs
New Jersey had an existing State vehicle safety inspection program ad-
ministered by the Division of Motor Vehicles to which the emission inspec-
tion program could easily be added. Therefore, the legislation authorizing
the inspection and maintenance program called for the Division of Motor
Vehicles to work with the Department of Environmental Protection. The
Department of Environmental Protection was responsible for developing the
inspection and maintenance program, providing the necessary technical
assistance, and monitoring the results. The Department of Motor Vehicles
performs the actual inspection and handles enforcement through the vehicle
registration procedure. Two other State agencies are becoming involved in
certain aspects of the inspection and maintenance program. The Department
of Environmental Protection is working with the Department of Education to
investigate ways to train auto service .industry mechanics in the repair
of vehicles that have failed the emission inspection. The Office of
Consumer Affairs has become involved in investigating cases where con-
sumers have problems getting their vehicles repaired properly.
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This type of interaction can present both problems and benefits.
One advantage is that the resources and experience of several agencies
can be brought to bear on the new program. This should allow the various
parts of the program to be carried out in an expeditious manner because
each part is being handled by the most experienced agency. On the other
hand, more coordination and cooperation is required by the primary agency
to see that all parts of the program are properly carried out.
Many of the States that will require inspection and maintenance pro-
grams have existing vehicle safety inspection programs. In most cases
the agency currently responsible for the safety inspection will also be
involved to some extent with the inspection and maintenance program. The
particular agency responsible for the safety inspection varies consid-
erably between States. Some examples include the Registrar of Motor
Vehicles in Massachusetts, the Secretary of Revenue in Pennsylvania, the
Administrator of the Vehicle Inspection Department in Indiana, and the
Superintendent of the State Highway Patrol in Ohio.
An example of a local inspection and maintenance program, in an area
which requires a safety inspection of commercial vehicles only, is the
City of Chicago. A City ordinance authorizes the Department of Environ-
mental Control to carry out the inspection and maintenance program. The
Department of Environmental Control handles the entire program including
technical development and vehicle inspection. In the future the Department
of Environmental Control may also become involved in garage certification.
In California the Bureau of Automotive Repair in the Department of
Consumer Affairs has the responsibility for regulating all auto repair
f
garages. Beginning in January 1974, the Bureau of Automotive Repair was
given the responsibility for developing an inspection and maintenance
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program for southern California including technical development, inspec-
tion, and certification of repair garages. An idle-mode test was incor-
porated into the random spot safety inspection conducted by the highway
patrol.
The primary advantage of having all responsibility in one agency is
that the overall program can be controlled by one agency. Presumably,
this would allow for tighter managerial control of the program. However,
one disadvantage is that expertise must be developed in several areas that
are somewhat unrelated to the primary objective of reducing emissions from
vehicles.
In all cases the agency with primary responsibility for the inspection
and maintenance program must see that all aspects of the program including
technical development, inspection, enforcement, monitoring, vehicle main-
tenance, inspector and mechanic training, public relations, and consumer
protection are developed. In addition, contact should be maintained with
the Environmental Protection Agency through the appropriate Regional Office
(see Appendix A).
IMPLEMENTATION SCHEDULE
In this section the factors leading to implementation and their timing
will be discussed. Generalized implementation schedules will be presented
as models and the assumptions explained. The models illustrate the re-
quired steps and their time dependence. The variables affecting the
implementation schedule and how these variables may differ between States
will be discussed. Examples from State agency experience will be used to
illustrate certain points.
The bar charts (Figures 4-1 and 4-2) show^fhe estimated time period
for implementation of inspection and maintenance programs. Figure 4-1
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STATE TASKS
STATE LEGAL AUTHORITY AND REGULA-
TIONS ESTABLISHED
PROGRAM PLANNING AND EVALUATION
ONGOING
14
FACILITIES AND EQUIPMENT ACQUISI-
TION
HIRING AND TRAINING OF INSPECTORS
IDLE MODE
LOADED MODE
PILOT STUDY
IDLE MODE
LOADED MODE
FIRST YEAR TEST CYCLE
IDLE MODE
LOADED MODE
SERVICE INDUSTRY TASKS
W//////////////////////h
9 14
9 17
W///////////A
10 13
10 16
1
14 26
W//////////////////A
17 A 2
W////////////M//A
14
TRAINING FOR REPAIRS
PROGRAM
FULLY
IMPLEMENTED
12 18
TIME, months
24
30
Figure 4-1. Estimated time required for implementation of state-owned inspection lanes
using idle- or loaded-mode tests. (Shaded bars represent critical path of tasks leading
to full implementation.)
shows a State-owned program with either an idle test or a loaded-mode
inspection. Figure 4-2 shows a time schedule for an idle inspection pro-
gram at licensed garages. The estimated time required for implementing a
State-owned program is 26 months for an idle test and 29 months for a loaded-
mode test. For a State-licensed idle test program the time required is about
26 months. These time estimates include the first year cycle necessary to
phase-in the program to cover the vehicle population.
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STATE TASKS
STATE LEGAL AUTHORITY AND REGULA- vm
TIONS ESTABLISHED W//
PROGRAM PLANNING AND EVALUATION W/J
LICENSING OF GARAGES
PILOT PROGRAM
SERVICE INDUSTRY TASKS
LICENSE PROCUREMENT
C
EQUIPMENT ACQUISITION
TRAINING FOR INSPECTION AND REPAIRS
FIRST YEAR TEST CYCLE
3
y////h ONGOING
3 9
1 1
10 13
n
3 9
1 1
14
W///////////////////I ™
2 14 IMPLEMENTED
1 1 1
1
14 26
W/////////////M
12 18
TIME, months
24
30
Figure 4-2. Estimated time required for impJementation of idle inspection at licensed
garages. (Shaded bars represent critical path of tasks leading to full implementation.)
Some of the assumptions made in constructing these model implementation
schedules should be pointed out. The first assumption, which can be seen
from the charts, is that the lead time begins at the point in time when
both legal authority and funding arrangements exist. The time required
to obtain legal authority and to make the necessary funding arrangements
can be a critical factor in the total time required for implementation.
In some cases, it may be possible to begin the planning, the pilot pro-
gram, and parts of the training program before legal authority has been
granted. (Legal authority and funding problems will be discussed later
in this chapter.)
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A second assumption is that no facilities or pilot programs are
available to build on. In some cases, however, inspection and maintenance
programs may be incorporated into procedures at existing safety inspection
stations, thus reducing the time required for the facilities acquisition
step. An existing pilot plant program could reduce the time required
to evaluate and select test equipment and procedures. In addition, the
staff would have some experience that would speed development of the
program.
Another assumption made in developing the model implementation
schedules is that only an idle test program would be considered for States
with State-licensed garages. It is unlikely that an adequate number of
private garages would invest in the more expensive testing equipment
necessary for a loaded-mode emission inspection under a State-licensed
program. If such a loaded-mode program is used, the time required for
implementation would be longer than that shown in the model.
The current status of a State safety program can also affect the
time required to implement an inspection and maintenance program. For
example, a planned State-owned inspection program could be implemented
faster in a State with an existing State-owned safety program because the
existing stations could be expanded to incorporate emission testing.
Likewise a State-licensed inspection and maintenance program could be
implemented faster in a State with an existing State-licensed safety pro-
gram.
The experience of State or local agencies that are operating inspec-
tion and maintenance programs supports the time estimates shown in Figures
4-1 and 4-2, although the exact timing of the various parts of the program
differ. Experienced agencies also observed that:
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1. Obtaining legal authority can be a long drawn out process and
thus a major time delay.
2. Locating sites for State-owned facilities can cause time delays
because of land procurement procedures.
3. In order to assure smooth implementation, considerable effort
must be made to maintain interagency cooperation in cases where
more than one agency has responsibility for parts of the
inspection and maintenance program.
FEDERAL ASSISTANCE
The EPA is committed to assisting air pollution control agencies in
various ways. Technical assistance in developing implementation plans
has been provided to many States in the past several years and will con-
tinue through EPA's Regional Offices. States have also received financial
assistance through the grants program. Technical and financial assistance
relating specifically to inspection and maintenance programs are discussed
in more detail in the following pages.
Technical Assistance
Federal technical assistance for inspection and maintenance programs
through the EPA Regional Offices will be available in several forms:
1. A periodic newsletter will be published to report on inspection
and maintenance developments in State or local agency experience,
EPA demonstration contracts, and other studies. Only the main
points of information will be discussed in the newsletter, but
references will be provided for those interested in a more detailed
discussion on the subject. The newsletter will serve as an outlet
for information on other vehicle-related subjects such as retrofit
devices, engine tampering, and fuel economy.
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2. The Emission Control Technology Division is evaluating objectives
for an inspection and maintenance evaluation program. By requir-
ing mandatory maintenance for those vehicles that have higher than
allowable emissions, inspection and maintenance effectiveness can
be determined, the service industry's capability to handle the
required maintenance can be evaluated, maintenance costs can be
determined, and public reaction to inspection and maintenance can
be sampled. Although these-data are important, the success of
the evaluation program will depend on the willingness of State
agencies to operate an inspection and maintenance program according
to the program requirements.
3. Planning is underway for a seminar sponsored by EPA for State and
local officials on the subject of inspection and maintenance pro-
grams. The seminar will provide a forum for EPA to dispense recent
information and for State and local officials to share their ex-
perience and information.
4. The document Control Strategies for In-Use Vehicles (APTD-1469)
will be reissued with more emphasis on aspects of implementation
and with recently developed information not contained in the first
edition. The new information will include a discussion of an
evaluation procedure for retrofit devices, a discussion of high
altitude emission inspection, and an examination of State agency
experience with specific problems encountered in implementing
inspection and maintenance programs.
5. EPA is considering establishing a team of experts that would be
available to handle requests for information or assistance on
technical matters relating to inspection and maintenance. The
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kind of assistance that this group could provide would include
technical review of State inspection and maintenance plans,
recommendations on instrumentation and other testing equipment,
assistance in mechanic training programs, testimony on technical
questions at public hearings, and on-site visits to evaluate
technical problems with the inspection ?nd maintenance program.
6. Several specific reports and studies related to inspection and
maintenance are discussed in Chapter 6.
Funding Assistance
Acquiring adequate funding is an important factor in the development
of an inspection and maintenance program. Funding an inspection and
maintenance program is basically the responsibility of the State and/or
local agencies.
In general, funds are required for two purposes: (1) to provide
capital to start up the program and (2) to operate and maintain the pro-
gram once it has been started. The amount of capital investment will
depend on three factors: (1) the type of program (State-owned lanes or
State-licensed garages), (2) the type of emissions test (idle or loaded-
mode), and (3) whether the emissions test is added to an existing safety
inspection or set up independently. The initial capital can be acquired
through several mechanisms, such as issuing bonds or borrowing from the
State's general fund. In any case, an inspection fee cein be charged to
cover both the operating and maintenance costs and to pay off the initial
investment. Oregon's system is an example of this method .of financing,
that is, borrowing the initial capital from the State's general fund and
setting the inspection fee at a level to cover the operating costs and to
pay back the initial capital.
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The additional cost an air pollution control agency will incur when
setting up an inspection and maintenance program may be included in the
agency's operating budget. As part of the agency budget, the inspection
and maintenance program costs would be eligible for matching funds through
EPA's grant program to support air pollution control agencies. However,
because EPA's agency grant funds are not expected to increase, this funding
mechanism will not be able to provide substantial support. Further infor-
mation concerning program grants can be obtained from an EPA Regional Office.
As mentioned in the following section on training, Federal funds can
be obtained for inspector and/or mechanic training. The EPA Regional Offices
have available some Manpower Development and Training Act (MDTA) funds for
training of technician-level people. Several State and local agencies in
Colorado, Oregon, and Texas have already used or propose to use this mech-
anism to obtain funds for training of inspectors and/or mechanics necessary
to carry out the inspection and maintenance programs. Interested agencies
should contact the manpower development officer in their EPA Regional Office.
TRAINING
An adequate supply of trained inspectors and maintenance mechanics is
necessary in order to successfully implement an inspection and maintenance
program. This section will examine the importance of inspector and mechanic
training, the steps that the primary inspection and maintenance agency
should take to assure a supply of trained personnel, and some examples of
what is being done in the area of inspector and mechanic training.
Trained inspectors must be available before the program can become
operational, and trained mechanics are required to properly repair the
rejected vehicles. The kind of training and magnitude of the training
program required would depend on whether the inspection and maintenance
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system is State-owned or State-licensed, and whether an idle test or a
loaded-mode inspection is used. In State-owned systems the inspection
function is separate from the maintenance function, which allows separate
training programs to be developed. Generally the professional staff
together with the instrument vendors can put together the necessary train-
ing program for inspectors. The training program for a loaded-mode test
would be more extensive than the training program for an idle test, but
both of the training programs for inspectors are relatively simple. The
main objective is to train the inspectors to operate and maintain the
instruments, perform the test, and make the proper record of the test
results.
The main factor determining the magnitude of the inspector training
program will be the size of the inspection and maintenance program. For
example, New Jersey has about 69 inspection lanes with one emission inspector
per lane. Other States with a larger number of lanes will require a sub-
stantial number of inspectors. For example, Arizona's proposed plan calls
for 511 employees most of whom will be inspectors.
In a State-licensed system, the personnel at each station should be
trained and capable of performing both the inspection and the maintenance
functions. The degree to which the inspection and maintenance agency can
become involved in training of mechanics under either type of inspection
and maintenance system will depend on several factors including legal au-
thority, personnel and funding capabilities, and the level of expertise and
initiative of the local auto service industry.
Early in the planning process, the agency responsible for the inspec-
tion and maintenance program should determine the role it will have in the
training program. In some States, an agency such as the Department of
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Education may be better equipped to handle inspector and mechanic
training. The particular legislation under which the agency operates,
however, may specify the agency's role in the training process. Another
factor to consider is the level of expertise in the local auto service
industry and the existence of private education programs. Several oil
companies have training courses for their dealers. Garage owners may
decide to prepare themselves for future inspection and maintenance
business by obtaining the necessary training for their employees. In
any case, the primary inspection and maintenance agency should assess
the need for mechanic training and take whatever measures are necessary
to prepare the auto service industry for handling emission repairs.
EPA is involved in two aspects of the mechanic training area that
can be useful to the State or local agencies responsible for inspection
and maintenance programs. One is in providing Manpower Development and
Training Act funds for inspector and for mechanic training. Several States
are using or plan to use these funds to set up training programs. The
Denver, Colorado, program is an example of this type of program. A contract
was awarded to Colorado State University to develop a training program and
to train 60 persons. This program is directed at training auto mechanic
instructors and teachers who will then go back to their technical institutes,
junior colleges, or other place of employment to teach the working level
mechanics. The multiplier effect of this method will help spread the know-
ledge faster than would training the working level mechanics directly. A
similar training grant for certified auto teachers has been awarded to
Colorado State University to expand the training program started under the
first contract. EPA expects to gain training materials and methods from
the work carried out under these contracts. These materials and methods
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can then be made available to others as training packages. Agencies
interested in using Manpower Development and Training Act funds for
mechanic training programs should contact the manpower officer in their
EPA Regional Office.
The Control Programs Development Division of EPA in Durham, N. C., is
currently working on projects to develop training programs for inspectors
and mechanics. One program that includes training materials has been
developed and will be tested in the Denver mechanics training program
mentioned above. Once the materials and methods are tested and approved,
the training package will be available for others. Further study is being
given to the need for developing other training packages for people in-
volved with inspection and maintenance at other levels, such as supervisors,
Because of the importance of having well-trained inspectors and
mechanics in the outcome of any inspection and maintenance program, the
primary agency should assess the training needs for its program and make
sure that the necessary training is provided. Who runs the training pro-
gram and how extensive it is will depend on the factors discussed above.
The primary agency will ultimately be responsible for the success of the
inspection and maintenance program, and therefore should make a special
effort to develop adequate training for inspectors and mechanics.
POTENTIAL PROBLEMS
A variety of approaches can be followed in implementing an inspection/
maintenance program. The program can be State owned and operated or
licensed to private garages; the inspection can be made while the vehicle
is at idle or under simulated driving conditions; annual or semiannual
inspections can be required, etc. With all of these approaches, implemen-
ting an automobile inspection/maintenance program may result in a number
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of problems that should be considered early in the planning process of
such a program. These problems fall into the following general areas:
1. Legislative or statutory requirements.
2. Organizational impediments.
3. Funding or budgetary restrictions.
4. Labor supply or skill shortages.
5. Lack of public support.
6. Lack of data.
7. Equipment and facility procurement.
8. Determination of rejection rate.
9. Certification of mechanics.
Legislative or Statutory Requirements
The implementation of an inspection/maintenance program requires
statutory authority for its development and operation. Acquiring this
authority necessitates formal approval by the State legislature for a
State-operated program. This is not necessarily true for a program
established by a local agency. In many instances this approval is given
in two phases--the first being a pilot or demonstration project, the
second the actual program to be implemented. As an example, in Colorado
the legal authority for a pilot program was already included as a part
of the Colorado Clean Air Act; once the results of the pilot are available,
the necessary legal authority for the implementation of mandatory inspec-
tion and maintenance will be acquired. In Arizona, the State legislature
approved the construction and operation of a prototype inspection facility
in 1972; a report containing emission test data, inspection station net-
work studies, and specific recommendations regarding how a statewide manda-
tory inspection system should be implemented has been completed and will
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go to the State legislature in 1974. In many cases the State legislative
body has only minimal technical knowledge and little understanding of the
actual requirements necessary for attaining the air quality standards.
The purpose of the transportation plan in helping attain these standards
and the necessity for implementing an inspection and maintenance program
must be appropriately presented to the legislators so that their approval
will be forthcoming. Adequate agency preparation may require many months
of work to construct a logical, understandable proposal.
Getting the necessary statutory authority can be a time consuming
task in implementing an inspection and maintenance program. This situation
necessitates early action on legislative approval. However, States may be
able to use an EPA-promulgated inspection and maintenance requirement as
the authority to act in implementing a program and thus, avoid time delays.
Organizational Impediments
As was discussed earlier, the implementation of an inspection and
maintenance program may involve several State or local agencies. Coopera-
tion between these agencies is essential if the program is to operate
successfully. Having specific agency responsibilities delineated in the
legislative authority will aid in avoiding controversy over assignment
of duties and enforcement of the program.
Funding or Budgetary Restraints
Once the legal authority for establishing a mandatory inspection and
maintenance program is acquired, adequate funding to operate the program
must be obtained. In many States, convincing the legislature to fund
such a program requires more effort and time than getting the legal au-
thority. State legislators may be reluctant to fund such a program in
one area of the State, or the legislator may not believe adequate funds are
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available for such a program. Time delays of a year or more may be ex-
perienced in getting necessary appropriations, which obviously would
extend the start-up date of the program. If funding provisions are in-
cluded in the enabling legislation, as is suggested in Chapter 3, sig-
nificant delays can be avoided.
Location of Federal sources of funding (discussed earlier) may ease
this problem somewhat. Although some Federal funding may be available,
it is the responsibility of the State to provide the funds necessary to
implement an inspection and maintenance program.
Labor Supply or Skill Shortages
The successful implementation of an inspection and maintenance pro-
gram requires sufficient qualified staff to operate all phases of the
program. Because of the hiring procedures used by many State and local
government agencies, the hiring of competent staff to aid in implementing
an inspection and maintenance program may pose problems. In many cases,
finding the qualified personnel is simple, but getting them on the job
may take 3 to 12 months because of local government hiring mechanisms.
In a State-operated inspection program, both inspectors to actually per-
form the inspection and qualified staff to calibrate the equipment and
verify the accuracy of the inspection results must be employed. For
example, approximately 500 people must be employed to operate the State
inspection and maintenance program being considered by Arizona.
In State-operated inspection programs, individuals with general
skills may be hired as inspectors and trained to perform the inspections.
Also under a State-operated inspection and maintenance program, the
mechanics in the individual garages who perform the required maintenance
will require some training in repairing or tuning engines to achieve
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emission reductions; the development of diagnostic skills in correcting
emission deficiencies is also essential for accurate, cost effective
repairs. Development of training programs for these mechanics and for
the inspectors should be considered an integral part of the inspection
and maintenance planning process and should be included as a necessary
step in implementation of the program.
In a State-licensed inspection and maintenance program, the training
of mechanics and inspectors to administer the inspection and perform
necessary maintenance is equally as important as in a State-operated system.
This training of mechanics may lead to a certification program for mechan-
ics who complete a specific amount of study in the correction of automotive
emission problems. Currently in Colorado, where a State-licensed system
is being considered, the EPA is funding a pilot program for the training
of mechanics in both diagnosing emission problems and making corrective
adjustments.
In some instances, getting legislative approval and funding for train-
ing mechanics and inspectors has posed problems. It becomes apparent,
however, that the lack of a trained staff could bring an inspection and
maintenance program to a standstill or lead to adverse public reaction.
The overall effectiveness of such a program hinges on the ability of
those operating the system to complete the inspections accurately and
to perform the maintenance adequately and efficiently. Therefore, train-
ing of mechanics and inspectors and timely hiring of personnel are es-
sential in getting the inspection program underway.
Lack of Public Support Problem
Gaining public support may be one of the more difficult problems
associated with implementing a motor vehicle inspection and maintenance
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program. In areas where the public is in favor of such a program, legis-
lative approval is much easier to acquire. For example, the Speaker of
the Arizona House of Representatives has been strongly in favor of the
inspection and maintenance program for Phoenix-Tucson; he has ellicited
great public support for this measure. As a result, the measure will in
all likelihood gain legislative approval this year.
One of the prime reasons for the public concern stems from the fact
that individuals fear being overcharged for mandatory maintenance or pay-
ing excessive fees for simple tuneup functions. To prevent these events
from occurring, some States are attempting to develop detailed diagnostic
techniques for use by mechanics in detecting deficiencies. For example,
in Arizona an innovative diagnostic tool may be employed. If an auto
fails the motor vehicle inspection, the driver may take the car to another
lane where an electronic device will identify where his problem lies; the
driver then goes to his garage and has the specific deficiency corrected.
Other States are setting up a detailed checklist of items that may cause
specific deficiencies so that diagnosis of problems can be handled more
efficiently. Proper training of mechanics will also aid in avoiding
unnecessary maintenance work.
As an added preventive measure, the public should have some simple
means to make complaints regarding the inspection or maintenance per-
formed at a garage. A "hot line" for making complaints or suggestions
or a return card to report problems would provide the individual with a
readily available means of making known to the proper agency officials
his specific grievance. The New Jersey Department of Environmental Pro-
tection is considering a similar means of monitoring complaints.
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Data Collection Problem
Another area of concern in establishing an inspection and maintenance
program is the gathering of adequate data upon which to base a decision
relative to the type of program to implement and the emission reduction
to be achieved. All of the data currently available on pilot projects or
research studies in this area were obtained from tests on automobiles.
These data are not directly applicable to medium-duty vehicles, heavy-duty
vehicles, diesels, turbines or light-duty trucks. Furthermore, most of the
vehicles used in the completed studies have been pre-1970 vehicles and none
have been equipped with the advanced control systems that will be a major
determinant in the total mobile source pollution levels at the time that
the inspection and maintenance programs are expected to be implemented.
Some areas are undertaking pilot or demonstration inspection and
maintenance programs on a small scale to provide actual data for decision
making relative to the type of inspection to utilize, the operation and
enforcement of the program, the kind of results to expect, and the costs.
Some States may be hesitant to undertake an inspection and maintenance
program without much more background information than is now available.
Nevertheless, States must gather what information is available and pro-
ceed with implementation in order to meet compliance dates.
One specific area where lack of data is posing a problem is in
determining the rate of deterioration of the vehicle to before-maintenance
emission levels. The emission reductions attributed to inspection and
maintenance are those recorded immediately after the vehicle maintenance
phase of such a program. If the vehicles are allowed to deteriorate to
their pretuned emissions level before they are reinspected and retuned,
the time-averaged emission reduction will be considerably less than those
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measured initially. Because definitive data on the shape and period of
the deterioration curve is not available, a straight line deterioration
to the pretuned condition in 1 year has been used for estimating purposes.
This approach was used in Appendix N of the Requirements for Preparation,
Adoption and Submittal of Implementation Plans. The result of this assump-
tion is that the time-averaged emissions reductions are half the initial
reductions achieved. Actual test data will be necessary to determine what
actual average deterioration rates will be.
Equipment and Facility Procurement
Procurement of emission inspection equipment may pose some problem in
implementing an inspection and maintenance program because of the purchas-
ing procedures and the lengthy procurement process employed in State and
local government agencies. For example, the State of Arizona estimates
it will require 12 months to procure the necessary equipment for the
inspection phase of the State-owned program. Much of this time is required
to process the orders for the equipment. At present, there appears to
be no problem regarding the availability of an adequate supply of the
necessary testing equipment from the various manufacturers.
In the case of testing facilities, a franchise inspection and
maintenance system presents no problem because individual garages will
be inspected and approved before being permitted to administer the in-
spection. No serious facility problems are anticipated in States where
the emission inspection is to be completed in parallel with a State-
operated inspection program. If new facilities must be purchased and
constructed for the inspection and maintenance program, considerable time
for acquiring sites, designing inspection stations, construction of
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stations, etc. must be allowed in the State's plan. This may pose a
serious time delay.
Vehicle Rejection Rate
The potential for initial emission reductions as a result of an
inspection and maintenance program will depend upon the accuracy of the
inspection procedure and the level at which emission standards are set.
The level of the emission standards determines what the inspection re-
jection rate will be. This rejection rate may pose problems if it is
so high that a large number of vehicles fail the test. This may lead to
adverse public reaction. Of course, the more stringent the emission
standards and the higher the rejection rate, the greater the emission
reduction allowed for this strategy will be.
One means of initially avoiding the problems of an extremely high
rejection rate is to set emission standards at a fairly high level for
the initial year and reduce the allowable emissions each year. In this
way, the more restrictive standards would be achieved over a period of
several years, but people would gradually become accustomed to the
corresponding higher rejection rates.
Certification of Mechanics
If training of mechanics to correct emission deficiencies is pro-
vided by a State or local agency as part of an inspection and maintenance
program, some consideration may also be given to their certification or
licensing. This would provide consumers with some assurance that the
mechanic has had adequate training to perform the maintenance required
to pass the vehicle inspection. In a State-operated program, the mechan-
ics doing the necessary maintenance might receive a certification or
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license if they either complete the training being provided or pass a
qualifying test.
In a State-licensed inspection and maintenance program, State certi-
fication of the garage as having the necessary facilities and equipment
to perform emission inspections and required maintenance is essential. In
addition, assurance that the garage has the qualified staff to complete
the inspections and perform the maintenance must be provided. Certification
of the individual mechanics as being capable of performing emission repairs
may be part of this assurance.
The certification or licensing of mechanics participating in inspection
and maintenance programs may pose potential problems with regard to imple-
mentation and monitoring of the certification program. This would require
additional work on the part of the agency operating the inspection and
maintenance program. The certification might create an adverse reaction
among mechanics unless training could be provided on an equal basis to all.
The certification does, however, serve as a consumer protection measure
and provide the operating agency with a lever to ensure that if quality
maintenance work is not done, certification will be revoked. The type
of certification or licensing procedure to be followed depends on the
specific inspection and maintenance program under consideration.
REFERENCES FOR CHAPTER 4
1. National Emission Standards Act. Part A-Motor Vehicle Emission
and Fuel Standards. Section 209-State Standards. The Clean Air
Act. 42 U.S.C. 1857 et seq. December 1970.
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5. MONITORING AND REPORTING REQUIREMENTS
MONITORING
Once an inspection and maintenance program has been implemented,
it is essential that the program be monitored and the information re-
ported to Federal, State, and local agencies, as appropriate. As noted
in Chapter 2, anission reductions achieved through an inspection and
maintenance program can range up to 15 percent for hydrocarbons and up
to 12 percent for carbon monoxide, depending on the initial rejection
rate and the type of program selected. It will not be possible to detect
these reductions through measurements in air quality. Therefore, to de-
termine the effectiveness of a program and the adequacy of operating and
maintenance procedures, data must be collected at the inspection station.
The data collected should be sufficient, at a minimum, to allow determina-
tion of the actual pass/reject rate and the amount by which emissions from
the vehicle population are being reduced.
Rejection Rate
The rejection rate can be easily determined. All that is required is
that the inspector be given a signal as to whether a vehicle's emissions
are above or below the established emission limitation. Such a signal is
normally designed into testing equipment, either through a dial indicator
that shows the actual pollutant concentration measured or through a simple
lighting system that is triggered when the measured concentration is either
above or below the standard. Usually both such signal methods are availa-
ble on testing equipment. It will be necessary to record pass/fail in-
formation for future analysis and reporting. This can easily be done at
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the time the inspection takes place by having the inspector (or other
appropriate person) record the desired information. Figures 5-1 and 5-2
provide an example of a format for recording pertinent vehicle information.
Of course, data collection forms can be designed for recording the type
and amount of data desired. In Figure 5-1, the third column under the
heading "Open Throttle" allows an additional emission measurement to be
recorded for an engine speed higher than normal idle. This measurement
provides additional data that can be used for diagnosing the cause for high
emissions and requires only a small amount of time for completion..
The rejection rate can provide very useful information. It can indi-
cate whether operating procedures at all inspection stations are consistent.
Too high or too low a rejection rate can mean that a station is not follow-
ing proper testing procedures, equipment is not functioning properly, vehi-
cles tested at a particular station are above or below average emitters, or
a combination of these causes. The first two causes can be corrected through
proper program management; the third cause is an additional indicator it-
self.
If proper procedures are being followed and if the equipment is
functioning as it should, then a high or low rejection rate may reflect
the quality of maintenance being performed on the vehicles. This is
especially true when vehicles are retested after being rejected. The
adequacy of maintenance can also be determined in other ways.
If rejected vehicles are required to undergo a retest before being
allowed to operate, the number of times a vehicle returns for retest will
indicate that corrective maintenance is either good or poor. A vehicle
owner who is required to have repeated maintenance on his Vehicle will
not undergo the cost and inconvenience long before complaining to the
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VEHICLE EMISSION INSPECTION - IDLE TEST
VEHICLE INFORMATION
Year:
Make:
Model:
No. of cylinders: Engine displacement: cubic inches
Serial No.:
(F. I. etc.)
Carburetor:
-barrel or other
Transmission: Automatic_
Date:
Manual
No. of shifts
Odometer reading:
EMISSION INFORMATION
Vehicle
year
All
1967
and
earlier
1968
and
later
Subject
Engine speed,
rpm
Carbon monoxide
Hydrocarbons
Carbon monoxide
Hydrocarbons
Idle
Max. Mfrs. Specs + 100
Max. 9.0%
Max. 1200 ppm
Max. 7.0%
Max. 600 ppm
Open throttle
2400 + 100
Max. 9.0%
Max. 1200 ppm
Max., 7.0%
Max. 600 ppm
Figure 5-1. Example of format for recording vehicle
emission information for idle test.
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VEHICLE EMISSION INSPECTION - LOADED TEST
VEHICLE INFORMATION
Year:
Make:
Model:
No. of cylinders:
Serial No.:
Carburetor:
Engine displacement^
cubic inches
-barrel or other
(F.I. etc.)
Transmission: Automatic_
Date:
Manual
No. of shifts
Odometer reading:
EMISSION INFORMATION
Vehicle
year
1967
and
earlier
1968
and
later
Pollutant
Carbon monoxide
Hydrocarbons
Carbon monoxide
Hydrocarbons
Idle
Max. 9.0%
Max. 1200 ppm
Max. 7.0%
Max. 600 ppm
Low cruise
Max. 5.5%
Max. 900 ppm
Max. 4.25 %
Max. 450 ppm
High cruise
Max. 4.5%
Max. 900 ppm
Max. 3.75%
Max. 450 ppm
Figure 5-2. Example of format for recording vehicle
emission information for loaded-mode test.
testing officials. If a high percentage of rejected vehicles pass on
the first retest, then this is an indication that corrective maintenance
is being properly diagnosed and performed. Regardless of whether the
indication is that maintenance is good or poor, the agency should in-
vestigate to determine the cause. If maintenance is good, the diagnosis
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and treatment methods used can be passed on to other maintenance facili-
ties, incorporated into a certification program, and/or used in mechanic
training programs. If the maintenance is poor, the agency will want to
correct the situation, for the maintenance function is critical to the
success of the inspection and maintenance program.
Emission Reduction
The emission reduction from a vehicle population is the key indicator
that an inspection and maintenance program is achieving the desired result
(see Figures 5-1 and 5-2 for an example method of data collection). The
most accurate method of quantifying emission reductions is through sur-
veillance using the Federal test procedure. However, adequate estimates
of emission reductions can be obtained by measuring pollutant concentrations
in exhaust gases using an idle-mode or loaded-mode test. An agency may
wish to record, summarize, and analyze pollutant concentrations from each
vehicle test. This procedure would provide the most accurate results.
However, if an agency lacks sufficient manpower or data processing facilities,
a portion of the vehicle population can be sampled at various intervals to
provide sufficiently accurate estimates of emission reductions. Of course,
the accuracy of these data will be affected by the size of the sample,
by how well the sample represents the vehicle population, and by the
type of emission test conducted (idle mode tests provide the least accu-
rate results). Proper statistical procedures should be used to deter-
mine the sample size and vehicle mix (age and weight class) of the sample.
New Jersey is instituting such a monitoring system for its idle inspec-
tion and maintenance program.
A surveillance team is maintained in the field to visit each inspec-
tion station once a month. During these visits, testing equipment is
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calibrated, and for a period of 2 hours, concentrations of carbon monoxide
and hydrocarbons from a sample of from 50 to 60 vehicles are recorded. The
vehicle year, make, and model, any test problems encountered* and whether
a vehicle is being retested are also recorded. Data on about 2,500
vehicles are obtained for each quarter of the year. A computer program
provides a distribution of pollutant concentration by vehicle age, by
weight class, and by make and model. Rejection rates are also computed.
Through study of these data, trends can be observed and the overall ef-
fectiveness of the program determined.
State-Operated Versus State-Licensed Programs
The above discussion of the surveillance team concept applies most
appropriately to a State-operated program in which a limited number of
inspection stations are located over a relatively small geographical
area and in which a large volume of vehicles are tested at each station.
The surveillance team concept would not be practical for a State-licensed
inspection and maintenance program because there would be a low rate of
inspection at a large number of stations spread over a wide geographical
area. Licensed stations must be required to report rejection rates and
emissions data either to the licensing agency or another appropriate
agency. This requirement could be part of the licensing agreement.
Licensed facilities would normally perform maintenance as well as
vehicle testing. Thus, it would be relatively easy for the "before" and
"after" emission data to be collected on rejected vehicles. Some problems
may be encountered in collecting these data if a majority of owners of
rejected vehicles elect to have maintenance and retesting done at facili-
ties other than where the initial test was conducted. This may occur if
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it becomes common knowledge that maintenance at a particular licensed
station is poor.
An additional step in the monitoring system can be included to survey
the testing and maintenance functions of licensed stations. This can be
accomplished through direct calibration of testing equipment at the station
by agency personnel at periodic intervals and through the testing of cali-
brated vehicles with known maladjustments as a quality check.
REPORTING
Operation of an inspection and maintenance program will involve report-
ing information to various levels of State and local agencies and to EPA.
Development of data collection and analysis procedures and design of the
information reporting mechanism should be carried out early in the program
development phase to ensure that information flow both vertically and hori-
zontally through the managing and/or participating agencies is smooth.
State and Local Agency Reporting Requirements
The State and local agency reporting requirements will vary in detail
and content between States and according to the type of inspection and
maintenance program implemented. As suggested by the discussion on
monitoring, reporting requirements for a State-owned and -operated
program would be somewhat more simplified than for a program operated
through State-licensed inspection and maintenance facilities. This
primarily results from the requirement to report information "internally"
between and through State and local agencies who, in all probability,
already have established lines of communication. In addition, there would
probably be more control over agency personnel as regards collecting and
analyzing data and submitting reports in a timely manner.
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For licensed facilities, reporting requirements must be levied on
private businesses. Thus, control over the accuracy of data collection
and timely submittal would be limited. Of course, the owner of a facility
whose success depended primarily on operating under a license in good
standing would probably be prudent in fulfilling reporting requirements.
Data reporting for inspection and maintenance programs that are incorporated
with existing safety inspection programs should be less complicated if some
form of reporting exists by which owners and operators are already in the .
habit of collecting and submitting information.
Federal Reporting Requirements
There are two separate cases in which a State and/or local agency may
be required to submit data to EPA. If a State has an approved implementa-
tion plan that contains an inspection and maintenance program, emission data
generated by the program, along with other emission and air quality data,
must be submitted to EPA through the appropriate Regional Office (see
Appendix A) in the semiannual report required by EPA regulations.
If a State is required to implement, operate, and enforce an inspec-
tion and maintenance program, the State must submit vehicle emission data
resulting from the program on a quarterly or semiannual basis in accordance
with the promulgated reporting requirements. These data must be submitted
in the format prescribed by EPA regulations,2 which is shown here as Table
5-1. The time periods in the first column represent the quarter or semi-
annual period for which the data are being reported. The subregion can
represent an inspection station at which data are collected, a county in
which data are collected, or any other geographical area that is specifically
defined. The choice of subregion selection belongs to the State or local
agency. Emission data collected through operation of the inspection and
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Table 5-1. INSPECTION AND MAINTENANCE EMISSION DATA
Time period 1
SubregionJ
Subregion 2
Subregion 3
Time period 2
Subregion 1
Subregion 2
Subregion 3
(Specify pollutant here)
WitF
control measure
Without
control measure
maintenance program are entered in the second column opposite the appropriate
time period and subregion. Vehicle emissions that would have occurred had
the program not been in operation are entered in a similar manner in the
third column.
States required to implement an inspection and maintenance program
must submit actual per-vehicle emission data to EPA. Analysis of these
data will indicate the effectiveness of the inspection and maintenance
program and will also assist EPA in handling the warranty and recall pro-
visions of the Clean Air Act.
Emission data are submitted quarterly or semiannually for that period
only. At the end of a calendar year, data are summarized for all quarters
or semiannual periods during which data were collected, and this summary
is also submitted to EPA. Thus, at the end of a calendar year, the re-
porting agency will submit two reports, one covering the last quarter or
semiannual period for the year, and one summary for the year.
PUBLIC ACCEPTANCE
In addition to the official reporting requirements to Federal, State
and local agencies, the implementing agency should seriously consider re-
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porting to and obtaining information from the general public. Public
acceptance directly affects the degree of emission reduction that can be
achieved from an inspection and maintenance program by a willingness of
the public to tolerate a certain stringency in vehicle emission limitations.
In addition, the life expectancy of the overall program depends on public
acceptance, or the lack of it. An agency would thus be wise to devote con-
siderable time and effort to public relations both prior to implementation
of a program and throughout its operation.
Prior to implementation of an inspection and maintenance program, the
news media can be used effectively to smooth the way for public participa-
tion. Points to emphasize include an explanation of why the program
is needed, what the benefits will be, how the program will operate, and how
much the cost to the average motorist is expected to be. Time permitting,
public participation in the program during the first year should be voluntary,
or at least the maintenance portion of the program should be voluntary.
In this approach, public reaction, both good and bad, could be tested,
and motorists prepared to some extent for mandatory participation. This
preparation is especially important if there is no existing safety inspec-
tion program that has gotten the motorist in the habit of taking his
vehicle in periodically to have it checked.
As mentioned previously, dissatisfaction with poor maintenance and
high costs can be expected to surface through motorists' complaints. An
effective procedure for soliciting and receiving such complaints, and
following up with solutions to legitimate problems can greatly enhance
the effectiveness of the entire program.
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REFERENCES FOR CHAPTER 5
Title 40-Protection of
Preparation, Adoption,
Section 51.7. Federal
Environment.
and Suhmittal
Register.
Part 51-Requirements for
of Implementation Plans.
Title 40-Protection of Environment. Part 51-Requirements for
Preparation, Adoption, and Submittal of Implementation Plans,
Appendix N. Federal Register. 38(110). June 8, 1973.
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6. FEDERAL AND STATE PROGRAMS
RELATED TO INSPECTION AND MAINTENANCE
Over the past 7 years, a variety of programs on inspection and main-
tenance have been sponsored by Federal and State governments, and a num-
ber of new programs have been started recently. This chapter will sum-
marize pertinent programs, past and present.
PROGRAMS SPONSORED BY FEDERAL GOVERNMENT
In order to collect information for use by the States in establishing
inspection and maintenance programs, several experimental studies have
been conducted over the past 4 years. The results of these studies have
been made available to the States and other interested agencies through
the Federal Register, a Control Strategies document^, the reports of the
Coordinating Research Council APRAC CAPE 13-68 committee, and various
contacts between EPA personnel and State and local pollution control
agencies.
Task 52 Program: The purpose of this program conducted at EPA in
Ypsilanti, Michigan, and Los Angeles, California, was to determine the
degree of correlation between the emissions during several of the common
inspection cycles and those during the 1975 Federal Test Procedure, which
is considered to be the only test that is capable of predicting air quality
effects from vehicle emissions. In addition, the study provided data on
the cost and effectiveness of mandatory programs.
Short Cycle Study: The purpose of the Short Cycle Study was to eval-
uate the costs and effectiveness of idle tests and the Clayton key mode
procedure. A full report of the study including a comparison of the ikey
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mode test, the idle test, and Federal Short Cycle test and the 7-mode
test will be available from EPA, Air Pollution Technical Information Center,
Research Triangle Park, N.C. 27711.
High Altitude Study: This study, sponsored by the EPA Region VIII
Office, compares the costs and effectiveness of idle and key mode testing
at high altitudes. The results of the testing, which was conducted in
Denver, Colorado, are in general agreement with those obtained in other
studies at low altitudes.
CAPE 13-68 Study: The primary purpose of this Coordinating Research
Council Inc. study was to develop a computer model that could be used to
predict the air quality effects of various inspection and maintenance
procedures. In support of the computer model, experimental studies were
conducted to quantify typical values of many of the parameters involved
in the computation. Among the parameters studied were:
1. Effect of parameter adjustment on emissions.
2. 'Inspection station costs.
3. Demographic data on Los Angeles and Detroit.
4. Emission baseline data on Los Angeles and Detroit.
5. Engine parameter data on Los Angeles and Detroit.
6. Typical repair costs.
7. Parameter and emission deterioration rates.
8. Service industry diagnostic and repair effectiveness.
9. Emission measuring instruments comparison.
The results of this 3-year study are now available in a multi-volume report
from CRC at Thirty Rockefeller Plaza, New York, New York 10020.
Evaluation of Post 1974 Prototypes: The purpose of this task is to
obtain information on the applicability of present short cycle (e.g. steady
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state, idle, and key mode) test to post-1974 light-duty vehicles. Proto-
type versions of post-1974 light-duty,vehicles will be subjected torthe
1975 Federal test procedure and additional short cycle tests. Particular
attention will be paid to the applicability of the cycles, instruments, and
procedures to these vehicles.
PROGRAMS SPONSORED BY STATE AND MUNICIPAL GOVERNMENTS
Arizona
Two pilot emission inspection stations capable of running loaded-mode
tests are being set up. One station will be in Phoenix and the other in
Tucson. The State is also experimenting with an instrument for diagnosing
malfunctions leading to high emissions. A State-wide inspection and main-
tenance program is planned.
California
The State Bureau of Automotive Repair is presently running an inten-
sive program to certify hydrocarbon-carbon monoxide instruments for repair
garages. These instruments were required for all Class A garages.
The California Highway Patrol presently spot-checks vehicles, using an
idle test, as part of their random sample safety inspection program.
Vehicles that fail are sent to Class A garages for correction. A new State
law requires a loaded-mode test and will result in an intensive develop-
ment program.
The Bureau of Automotive Repair is planning to establish a pilot
inspection station in Riverside County to run loaded-mode emission tests.
Vehicles would be tested once a year. If a vehicle fails the test, it will
be referred to a certified and licensed Class A garage for needed repair.
A vehicle will not have to return for a second inspection after the repair
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has been made. Idle emission tests will be performed randomly by the
highway patrol as part of its on-the-road safety inspection program. If
a vehicle fails this test at any time, it must go back to a Class A
garage for repair. California plans to first spread the program to the
counties of southern California after the completion of the pilot program
and then to the entire State.
Colorado
The state has conducted a program to determine the effect of altitude
on emissions and at what operating conditions vehicles should be set to
minimize emissions.
Illinois
The city of Chicago has set up low budget emission inspection stations
and is phasing in a complete inspection and maintenance program. Little
is being done as regards maintenance and repair. There is some interest
in spreading the program to all of Cook County.
New Jersey
All safety inspection facilities have been performing an idle test
for carbon monoxide and hydrocarbons since July 1973. Repair and retesting
of rejected vehicles was voluntary. Beginning in February 1974, rejected
vehicles must be repaired and retested until they pass inspection. The
State has a continuing program to certify instruments for measuring hydro-
carbons and carbon monoxide for use by garages and dealers. The present
standards fail about 10 percent of the tested vehicles. More stringent
standards will be adopted within a year. The State is developing a loaded-
mode CVS test for mass emission measurement to eventually replace the idle
test currently used. In the past, the State conducted extensive programs
on emissions from used vehicles, studying effectiveness of short cycles
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and effectiveness of repair in reducing emissions.
New York
The State is operating a pilot program for upstate cities employing
mobile inspection units. They collect emission data primarily in shop-
ping centers. Several thousand vehicles have been tested so far. New
York City has an active development program for trucks and buses. This
is the only research program now being run on inspection and maintenance
of heavy-duty vehicles.
Oregon
The State legislature appropriated $1 million for an inspection and
maintenance program that will be used to set up and operate prototype in-
spection stations.
Washington, D.C.
The District has inspection lanes with dynamometers and analyzers
for conducting loaded-mode tests. No maintenance program has as yet
been established.
REFERENCES FOR CHAPTER 6
*
1. Control Strategies for In-Use Vehicles. Environmental Protection
Agency, Research Triangle Park, N.C. Publication Number APTD-1469.
November 1972.
2. A Study of the Feasibility of Mandatory Vehicle Inspection and
Maintenance. TRW Systems Group/Scott Research Laboratories. Pre-
pared under APRAC Project Number CAPE 13-68.
3. Effectiveness of Short Emission Inspection Test in Reducing Emissions
through Maintenance. Olson Laboratories, Inc., Anaheim, California.
Prepared for Environmental Protection Agency, Ann Arbor, Michigan
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under Contract Number 68jjbl-0410. Publication tfumber EPA-460/3-73-009.
July 1973.
4. Vehicle Testing to Determine Feasibility of Emission Inspection at
High Altitudes. Automotive Testing Laboratories, Inc. Prepared for
Environmental Protection Agency under Contract Number 68-01-0439.
September 1972.
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APPENDIX A
ENVIRONMENTAL PROTECTION & AGENCY REGIONAL OFFICES
EPA REGION
STATES AND TERRITORIES
Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Region II
26 Federal Plaza
New York, New York
10007
19106
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania
Region IV
1421 Peachtree Street
Atlanta, Georgia 30304
Region V
1 North Wacker Drive
Chicago, Illinois 60606
Region VI
1600 Patterson Street
Dallas, Texas 75201
Region VII
1735 Baltimore Street
Kansas City, Missouri 64108
Region VIII
1860 Lincoln Street
Denver, Colorado 80203
Region IX
100 California Street
San Francisco, California 94111
Region X
1200 Sixth Avenue
Seattle, Washington 98108
Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, and
Vermont
New Jersey, New York, Puerto Rico,
and Virgin Islands
Delaware, Maryland, Pennsylvania,
Virginia, West Virginia, and
District of Columbia
Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Carolina, and Tennessee
Illinois, Indiana, Michigan, Minne-
sota, Ohio, and Wisconsin
Arkansas, Louisiana, New Mexico
Oklahoma, and Texas
Iowa, Kansas, Missouri, and
Nebraska
Colorado, Montana, North Dakota,
South Dakota, Utah, and Wyoming
American Samoa, Arizona, California,
Guam, Hawaii, and Nevada
Alaska, Idaho, Oregon, and Washington
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APPENDIX B
GLOSSARY
1. Chassis Dynamometer - A machine 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 loadings the en-
gine would experience when the vehicle is operated on the road. 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.
2. Emission Inspection Program - An inspection and maintenance program
in which each vehicle is subjected at specified intervals 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 has failed and must be adjusted or
repaired to bring its emissions into compliance with the standard.
3. Heavy-Duty Vehicle - Any motor vehicle designed for highway use that
has a gross vehicle weight of more than 10,000 pounds.
4. Idle Test - An emission inspection program that 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 gear
with brakes applied or in neutral gear.
5. Initial Failure Rate - The percentage of vehicles rejected because of
excessive emissions of a single pollutant during the first inspection cycle
of an inspection and maintenance program. (If inspection is conducted on
more than one pollutant, the total failure rate may be higher than the
failure rates of any single pollutant).
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6. Inspection and Maintenance Program - A program to reduce emissions
from in-use vehicles through identifying vehicles that needs emission-
control-related maintenance and requiring that such maintenance be per-
formed.
7. Key Mode Test - A loaded-mode test in which exhaust emissions are
measured at high and low cruise speeds and at idle. The cruise speeds
and dynamometer power absorption settings vary with the weight class of
the vehicle. The dynamometer loading in the high cruise range is higher
than normal load in order to more effectively expose malfunctions leading
to high emissions.
8. Light-Duty Vehicle - A motor vehicle of less than 6,000 pounds gross
vehicle weight designed for highway use. Further distinctions are some-
times made between light-duty automobiles and light-duty trucks such as
pickup trucks.
9. Loaded-Mode Test - An emission inspection program that measures the
exhaust emissions from a motor vehicle operating under simulated road
load on a chassis dynamometer.
10. Mandatory Maintenance Program - A special case of an inspection and
maintenance program that requires each vehicle, regardless of its emission
level or mechanical condition, to have specific maintenance operations
performed at specified intervals. There is no inspection phase to determine
what maintenance is necessary. The appropriate maintenance is explicitly
' specified for each type of vehicle.
11. Medium-Duty Vehicle - Any motor vehicle designed for highway use
that has a gross vehicle weight of more than 6,000 pounds and less than
10,000 pounds.
12. Parameter Inspection Program - An inspection and maintenance program
in which each vehicle is subjected to a sequence of diagnostic tests that
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evaluate the mechanical condition of various emission related systems or
components and determine if malfunctions or maladjustments are present.
Vehicles showing measurements outside acceptable tolerance ranges have
failed and are required to have corrective maintenance performed.
13. Positive Crankcase Ventilation - A system designed to return blow-
by gases from the crankcase of the engine to the intake manifofa so that
the gases are burned in the engine. Blow-by gas is an 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.
14. Rejection Rate - The percentage of total vehicles tested in an
inspection/maintenance program in a given time period that fail inspec-
tion and are required to have maintenance performed.
15. Transportation Control Measure - Any measure that is directed toward
reducing emissions of air pollutants from transportation sources. Examples
of measures include reducing vehicle use, changing traffic flow patterns,
decreasing emissions from individual vehicles through inspection and main-
tenance or retrofit, and altering existing modal split patterns (e.g. get-
ting people to use buses or carpools instead of individual cars)..
16. Transportation Control Strategy - The sum total of all transportation
control measures used in an area to reduce emissions of air pollutants from
transportation sources.
17. Vehicle Emissions Standard - A specific emission limit allowed for a
class of vehicles. The standard is normally expressed in terms of maxi-
mum allowable concentrations of pollutants (e.g. parts per million). How-
ever, a standard could also be expressed in terms of mass emissions per
unit of time or distance traveled (e.g. grams per mile).
B-3
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/2-74-005
2.
4. TITLE ANDSUBTITLE
Inspection and Maintenance of Light-Duty Gasoline-
Powered Motor Vehicles: A Guide for Implementation
7 AUTHOR(S)
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
August 1974
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Protection Agency
Office of Air and Haste Management
Office of Air Quality Planning and Standards
Research Triangle Park. N.C. 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document is intended to provide guidance to Federal, State, and local
agencies concerned with implementing and monitoring an emissions inspection and
maintenance program for motor vehicles. The guide provides a discussion of
major inspection and maintenance methods, legal considerations,implementation
factors, monitoring and reporting requirements, and Federal and State programs
in the field.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Motor vehicles
Emissions
Inspection and maintenance
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
90
20. SECURITY CLASS (Thispage)
llnclas s :Lf i ed
22. PRICE
EPA Form 2220-1 (9-73)
C-l
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