EPA/AA/83-3
Draft Report for Public Comment
Anti-Tampering And Anti-Misfueling
Programs To Reduce
In-CJse Emissions From Motor Vehicles
May 25, 1983
Technical, Support Stafx
Emission Control Technology Division
Office of Mobile Sources
Office of Air, Noise and Radiation
United States Environmental Protection Agency
Ann Arbor, Michigan
\Th\s document has not been peer and
Administratively reviewed within SPA
and is for internal Agency use/
distribution only.
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TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION 3
2.0 TAMPERING AND MISFUELING RATES 7
2.1 Current Rates 7
2.2 Future Rates 14
3.0 EFFECTS OF TAMPERING AND MISFUELING
AND COSTS OF REPAIRS 24
3.1 Air Pump 24
3.2 Catalyst 27
3.3 Habitual. Misfueling 29
3.4 Positive Crankcase 31
3.5 Evaporative Canister . 32
3.6 Light-Duty Trucks 34
4.0 CALCULATION OF EXCESS EMISSIONS DUE TO
TAMPERING AND MISFUELING 36
4.1 Discussion of Method 36
4.2 Example Calculation 37
4.3 Excess Emissions Due to Tampering and
Misfueling 39
5.0 BENEFITS OF ANTI-TAMPERING AND
ANTI-MISFUZLIMG PROGRAMS 43
5.1 I/M Programs 45
5.2 Periodic Inspection Programs 65
5.3 Other Anti-Tamper ing and Anti-
Misfueling Programs 77
6.0 ADJUSTMENTS TO LOCAL CONDITIONS 33
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1.0 INTRODUCTION
Since the 1960's when crankcase ventilation tubes on
automobile engines were rerouted to prevent the venting of
engine blowby gases directly into the atmosphere, automotive
designers have added to and redesigned various components of
the standard internal combustion engine to reduce its
emissions of hydrocarbons (HC), carbon monoxide (CO)/ and
nitrogen oxides (NOx). The success of their efforts is
evident in the fact that new passenger vehicles emit only a
small fraction of the HC, CO, and NOx emissions of
pre-controlled cars.
The full benefit of these modifications, however, is. not
being realized in the field. EPA studies have shown
repeatedly that maladjustments, disablements, and component
failures in the emission control systems of automobiles occur
frequently and that the result is often emission levels many
times the design (certification) standards. This means that
the vehicle owners, who have paid for these emission control
components when their cars were purchased, and the public, in
general, have not been receiving the emission benefits of
this investment. because of some form of tampering,
misfueling, malmaintenance or neglect. These emissions in
excess of design standards are a major source of HC, CO, and
NOx from mobile sources and a significant contributing factor
to air pollution in urban areas.
This report will specifically address the portion of excess
vehicle emissions due to . tampering and misfueling.
Tampering, in this report, will refer to any disablement of
any component of an emission control system whether it was
done deliberately, inadvertently, or through neglect.
Tampering can be as simple as losing (and not replacing) your
vehicle's gas cap to sawing off the catalytic converter.
This definition does not include maladjustments which would
increase emissions. Misfueling and fuel switching in this
report will mean any introduction of fuel using lead additive
into a vehicle originally equipped with .a catalytic
converter. This can be done deliberately by the vehicle
owner by enlarging the fuel inlet restrictor so that the
leaded fuel nozzle fits or by using a funnel so that damaging
the fuel inlet restrictor is not necessary. This can also be
done inadvertently if fuel supplies at a particular station
or at a wholesale supplier become contaminated or
deliberately switched, although EPA estimates that the
nationwide contamination violation rate at 'retail gasoline-
stations is less than one percent. There are many possible
reasons why people misfuel, but the primary reasons are
thought to be price and the perception of performance, since
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leaded fuel is both cheaper and higher in octane rating than
unleaded fuel.
EPA has in recent years begun to collect data on the
occurrence of tampering and misfueling to assess the
magnitude of the problem. Covert observation of vehicle
owners at fueling stations and direct inspection of
individual vehicles in roadside surveys have shown that
nationally nearly one in five in-use vehicles have at least
one emission control disablement and that a significant
number of vehicle owners misfuel. These figures are alarming
in light of the fact that it is a federal violation with
large civil fines for repair garages, dealerships or fleet
operators to remove or disable emission control components
and that many states have had laws which make such
disablements by individual vehicle owners illegal. Tampering
and misfueling are, therefore, significant problems which
current efforts have not adequately held in check.
Inspection and maintenance (I/M) programs are being
instituted in some areas to assure a better state of repair
for vehicles operated in large urban areas with air quality
SCoblems. The Clean Air Act Amendments of 1977 require I/M
programs in urban areas with populations over 200,000 which
cannot attain ozone or carbon monoxide air quality standards.
by 1982. Although these I/M programs will produce large
reductions in HC and CO emissions, most programs do not
explicitly require that all emission control components be in
good repair in order to pass the I/M inspection. The simple
idle test which is used in most I/M programs is not designed
to detect specific component disablements. Such I/M programs
alone, therefore, will not completely solve that portion of
the excess emissions problem. Additional emission reductions
from reducing the occurrence of tampering and misfueling are
possible in all areas in order to help meet or to maintain
ambient air quality goals.
Tampering and misfueling, and thus the excess emissions
caused by them, can be reduced in a variety of ways:
0 In areas with I/M programs, an anti-tampering and
anti-misfueling program could be added as part cf the
tailpipe emissions program.
0 In areas with an existing safety or other periodic
inspection requirement, an anti-tampering and
anti-misfueling program can be added to the inspection
program. In areas without an existing inspection
requirement, a new requirement can be implemented either
on a periodic; or change-of-ownershi? basis.
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0 Various field enforcement efforts can also be used in any
area to deter tampering and misfueling.
Each of these three approaches is examined separately in
Section 5.0/ which discusses the potential problems as well
as benefits.
In any approach, the potential benefits from anti-tampering
and anti-misfueling programs will be affected by: 1) how much
tampering and misfueling are occurring given existing
efforts, if any, to control them; 2) the effectiveness of the
program in reducing the observed rate of tampering and
misfuelng; and 3) the effects of tampering and misfueling on
the emissions from vehicles. There are two ways in which
anti-tampering and anti-misfueling programs reduce excess
emissions. First, a program may require repair and
replacement of damaged or missing emission control components
when they are discovered. Secondly, programs may take credit
for deterrence of tampering and misfueling which would have
occurred if the program had not been implemented. Any
program's benefits will be some mix of these two elements
although the design of the program may rely more on one than
the other for program benefits.
This report does not cover specific methods -of- detection for
disablements. The report briefly describes what each
inspection would be like and covers general methods that can
be used- - to detect disablements. A twenty hour tampering
detection training course is available fromColorado' State
University. This course provides hands-on experience in
identifying the location and general functions of emission
control devices. Colorado State University has also recently
published a book titled .-""1270-1981 Automotive Emission
Systems Application Guide". This book provides engine family
specific information on what emission control components a
passenger vehicle or truck should be equipped with. Also,
in-the-field training can be provided by EPA inspectors to
those jurisdictions interested in establishing tampering
and/or fuel switching enforcement programs that are aimed at
retail gasoline stations, fleet operations and repair
facilities.
Section 2.0 will discuss the current knowledge about
tampering and misfueling rates. Section 3.0 will examine the
effects of misfueling and disablement of individual emission
control components on vehicle emissions, discuss which
vehicles are equipped with each emission component, and
estimate the cost of repairs. Section 4.0 will-discuss the
calculation approach which was developed for this report to
estimate the excess emissions caused by tampering and
misfueling. Effectiveness will depend on the particular
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program approach and will therefore be discussed for
individual approaches in Section 5.0.
This report analyzes four specific types of tamperingPCV,
evaporative control system, air pump, and catalyst
removalplus misfueling. EPA has found that these are the
most important items in terms of HC and CO reductions,
practicality, and cost.
The potential benefits of a check for disabled closed-loop
sensors have not been analyzed because of the uncertainty
associated with identifying a tampering rate for these
relatively new components. Also, tailpipe I/M tests can
identify as much as 80% of the excess emissions associated
with oxygen sensor tampering. Thus in I/M areas an oxygen
sensor check would have reduced benefits even if a
significant tampering rate existed. Future tampering surveys
will attempt to identify the existing closed-loop sensor
tampering rate.
The most cost-effective portion of the emission reductions
possible from a program to control tampering and misfueling
is the portion that results from preventing new instances of
tampering and misfueling, since no repair cost is incurred.
Some jurisdictions may wish to forego the less cost-effective
replacement and repair of components which were damaged
before the program begins, by applying the program
requirements only to cars sold after the program begins.
This approach would also reduce public resistance to the
program and would avoid disputes with owners of cars that
were tampered before they bought them. Of course, the
benefits from such programs would also be reduced. For the
convenience of such jurisdictions, benefits are shown in all
tables for 1984 and later vehicles separately from those for
older vehicles. One possible compromise between the larger
benefits and costs of inspecting all model years and the
reduced, benefits of inspecting cnly newer vehicles is to
inspect all 1980 and later model year vehicles. The tables
have also separated the 1980 through 1983 model years for
this purpose.
Because 1987 is the deadline for attainment of the czcne and
carbon monoxide standards for areas which received extensions
beyond the 1982 deadline, benefits are calculated for
January 1, 1988.
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2.0 TAMPERING AND MISFUELING RATES
2.1 Current Rates
Since 1978, EPA has conducted surveys of in-use vehicles,
both passenger cars and trucks, in seventeen states and
collected data regarding emission component disablements arid
misfueling from over 8,000 vehicles. The latest of these
surveys [11* completed in 1982 collected data from nearly
3,000 cars in ten states. All of the surveys were conducted
either at a roadside check in conjunction with a random
police roadside pullover or as a special, temporary addition
to a safety or I/M inspection at state-run or private
inspection stations. Although the inspections were
voluntary, efforts were made to assure as complete
participation as possible. Once a city and specific site in
the city were chosen, vehicles were chosen completely at
random, although the surveys since 1980 inspected only 1975
and later model year vehicles. Table 1 presents a summary of
the sample sizes collected in the various states in the 1982
tampering survey. Notation has been added to indicate I/M
areas and the type of vehicle recruitment used in the survey
at that site.
The 1982 survey was chosen as the definitive data base with
which to calculate current and future tampering rates.
Comparing the 1982 survey with the previous survey shows that
tampering and misfueling behavior has changed with time, and
therefore the latest survey will more clearly match future
tampering and misfueling behavior. Also, the 1982 survey was
more successful than previous surveys in obtaining an
essentially non-voluntary and therefore unbiased sample.
Table 2 shows the tampering rates observed for 1975 and later
vehicles in the 1982 survey. Table 2 indicates that with the
exception of PCV and evaporative canister tampering,
tampering rates are on average lower in cities with I/M
programs. Not all instances in which there was evidence of
tampering are reflected in Table 2. Only those serious cases
in which the tampering was judged to be easily identifiable
and appeared to be sufficient to cause substantial increases
in EC and CO emissions are counted in Table 2. Consequently,
Table 2 may differ from other published summaries of the 1982
survey.
*Numbers in brackets refer to references at the end of the
report.
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8
The interpretation cf the 1982 survey data to determine which
instances of tampering were sufficient to cause substantial
increases in HC and CO emissions was straightforward except
for misfueling. The survey examined three vehicle parameters
relative to misfueling: whether the lead content of the fuel
in the tank was over the legal limit of 0.05 gram/gallon,
whether the fuel inlet restrictor had been enlarged enough to
allow a leaded fuel nozzle to be used, and whether lead
sensitive test paper[2] detected lead deposits in the
tailpipe. To result in deactivation of the catalyst and
substantial long term emission increases, misfueling must be
either repeated at least three or four times in succession,
or must occur with a fairly high frequency over a long period
of time if not consecutively. Such consecutive or frequent
misfueling is called habitual. The parameters examined in
the 1982 survey are not definitive indicators of this.
Table 1
EPA 1282 Tampering Survey
Sample Sizes
Sample . Type of
State Size Recruitment
FL 309 a
LA 183 b
MN 3-07 a
NV* 275 d
NJ* 290 a
OK 282 b
OR* 310 c
RI* 324 a
TX 293 b
WA* 312 c
Total 2885
*I/Marea(Seattle, Washington's program did not begin until
January 1982).
a: Random roadside pullover.
b: As part of a centralized or decentralized safety
inspection.
c: As part cf a centralised or decentralized I/M inspection.
d: Vehicles were recruited at a parking lot.
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9
Table 2
Current Tampering and Misfueling Rates*
From 1982 Tampering Survey
Emission Control I/M Areas - Non-I/M Areas
System LDV LPT LPV LPT
PCV 1.2% 2.8% 1.1% 4.4%
Evaporative 1.5% 2.8% 0.5% 6.1%
Air Pump 3.1% 2.9% 6.1% 13.8%
Catalyst 1.8% 4.2% 4.5% 20.7%
Habitual
Misfueling** 5.4% 11.7% 9.5% 26.1%
For Comparison
Only:
All
Misfueling*** 6.6% 11;.7% 11.7% 32.0%
*Grossly tampered cars only. See text.
**Pefined as an enlarged fuel inlet restrictor or leaded fuel
(lead content greater than 0.05 gm/gal) in tank. Catalyst
vehicles only. See text in Section 2.1 for discussion.
***Pefined as an enlarged fuel inlet restrictor/ leaded fuel
(lead content greater than 0.05 gm/gal) in tank, or lead
compounds detected in the tailpipe. Catalyst vehicles only.
The detection of lead deposits alone is not used as an
indication of habitual misfueling in this report for reasons
given in the text. A positive result an the test for lead
deposits is believed to be an accurate indication that at
least some leaded fuel has been used, however. The rates for
"all" misfueling shown in this table are for comparison only.
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10
Fiaure 1
Distribution of Lead Content in Misfueled Catalyst
Passenger Cars in 1982 Tampering Survey
\ . 0
O.S .
0.3 .
§0.7
io.s
0.3
0.2
0. 1
0. 0
0.05
0.10
0.20
0.50
1.00
2.00 3.00.
Lead Content (cm/gal)
(Locrichmic Scale)
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11
Checking the inlet restrictor does not detect vehicleswhose
owners have misfueled using funnels or illegally small
nozzles- or vehicles which are victims of fuel mislabeiing by
gas stations or distributors or have otherwise used
contaminated gasoline. Fuel samples drawn on a one-time
basis cannot detect vehicles which were misfueled regularly
in the past, but- for some reason, e.g., change of owners,
have not been misfueled recently. The lead sensitive test
paper may detect vehicles which' have only been misfueled a
couple of times at wide intervals and have catalysts which
are still active. The test paper can also fail to detect
vehicles which have had tailpipe replacements since the last
misfueling episode. Nothing can be done -to adjust the data
from the 1982 survey for false negative indications of
misfueling.
The inlet restrictor check can be assumed to have few false
positives, since an owner is extremely unlikely to have
tampered with the restrictor for no reason. The check on
fuel lead content also is a strong indicator that leaded fuel
has been used recently. Most of the vehicles with fuel over
the Jegal limit were well over it, so low level contamination
of unleaded fuel cannot possibly be the cause. Many of the
cars clearly had filled with leaded fuel at the last fillup.
Information on the observed lead concentrations of vehicles
over the legal limit is presented in Figure 1. Based on EPA
fuel inspections and other fuel surveys, it is far more
likely that leaded fuel was purchased knowingly than that the
gasoline retailer had sold leaded fuel from a pump labeled
unleaded. Given that the owner knowingly bought leaded fuel
recently, it is likely that the vehicle has been habitually
misfueled; evidence that owners who use leaded fuel once tend
to do so regularly is discussed in the last paragraph of this
section^
The only remaining issue, then, is v/hether a vehicle with the
test paper result indicating misfueling which does not also
have other indications of misfueling has actually been
misfueled enough to deactivate the catalyst. Since the fuel
in the tank is below the legal limit, it is certain that
unleaded fuel has been used for at least the last two or
three fillups. The most plausible scenario for earlier
habitual misfueling would be that a previous owner had
misfueled extensively using a" funnel or illegally small
nozzle but the present owner does not. This is clearly a
possibility, particularly for older cars, but is tempered by
the low rate of owner turnover. It is also possible that a
family car was or is misfueled habitually by one member of
the family but not by the member who filled the tank the last
few times. A single vehicle operator may also have
habitually misfueled only during the last gasoline crisis, in
1979, when unleaded fuel may. have been unavailable.
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12
Otherwise there is little reason to suppose that the same
owner would stop habitual misfueling once he or she started.
The other possibility, as mentioned, is that leaded fuel has
been used only a couple of times, for whatever reason and
perhaps unknowingly.
Because of the uncertainty as to how to handle the vehicles
which failed only the test paper results and a desire to
produce a realistic estimate of the benefits for programs to
reduce habitual misfueling, EPA has chosen for this report to
accept only the fuel lead content and inlet restrictor as
evidence for calculating habitual misfueling rates. As can
be seen in Figure 2, this decision reduces the number of
vehicles with any indication of misfueling that are
considered habitually misfueled by about 18% for the
passenger cars and 15% for the light-duty trucks. For the
reader's information, Table 2 shows the misfueling rate based
on these two indicators alone and on all three indicators.
EPA will be considering ways to reduce the uncertainty in
this area and may provide further information later.
There are two other sources of data on misfueling that can be
used as a qualitative comparison to the misfueling rates
calculated from the two indicators in the 1982 tampering
survey. As noted below, each has its own limitations.
First, EPA has in the past observed vehicles fueling at gas
stations and through a check of their license plate number
determined if each vehicle required unleaded gas. The last
such survey was completed in 1979. It showed an overall
misfueling rate then of about 8%. This survey approach
obviously does not detect all vehicles which have ever been
misfueled enough to cause catalyst deactivation and some
observations represent only casual misfueling.
Second, an analysis of fueling habits was recently performed
by a Department of Energy contractor using data from detailed
diaries kept by families of their gasoline purchasesf3 ] .
This analysis showed that among the families keeping diaries,
7.7% of the fuel purchased for catalyst-equipped vehicles was
leaded. More than 85% of the leaded fuel purchased was
purchased by vehicle owners who misfuel more than 30% of the
time. This suggests that a given owner rarely stops his or
her habitual misfueling once started, but says nothing about
previous owners. The diaries have not yet been analyzed to
determine exactly how many vehicles were affected by serious
misfueling during the diary period. Data used for the fuel
diary analysis is voluntary .and therefore suspected of
under-representing the true incidence of misfueling.
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. 13
Figure 2
Overlap Among Indicators
of Misfueling in the 1982 EPA
Tampering Survey*
Passenoer Cars:
\
All
Any
Tank
Inlet
Tailpipe
Number
of Vehicles
2209
190
119
103
113
Inlet
Tank
Tailpipe
Inlet
Light-Duty Trucks:
All
Any
Tank
Inlet
Tailpipe
Number
of Vehicles
353 .
79
51
49
62
Tank
Tailpipe
'All
content
All catalyst vehicles
All catalyst vehicles
following indications
All catalyst vehicles
a fuel lead
gallon.
All catalyst
allows entry
Tailpipe: All catalyst
indicate pas'
Anv;
Tank
Inlet
or more
in sample.
with any cm
of misfueling
whose fuel sample
greater than 0.05
of
the
indicates
grams per
vehicles whose fuel inlet restrictor
a leaded fuel nozzle.
vehicles' whose tailpipe lead deposits
use of leaded fuel.
of
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14
2.2 Future Rates
In order to estimate the excess emissions caused by tampering
and misfueling on a future date, January I, 1988 for example,
it will be necessary to predict the tampering and misfueling
rates when the average age of the vehicles will be older than
observed in the 1982 survey since it was restricted to 1975
and newer vehicles. Examination of the data from the 1982
survey shows a marked increase in the tampering rates of some
components, including catalysts, and in misfueling rates as
the average mileage of the sample increases. This increase
is illustrated in Figures 3-7. Consequently, the dependence
of tampering rates on mileage must be accounted for.
To examine this issue, a linear regression equation on
mileage was fitted to data from the 1982 EPA survey and
appears to reasonably explain the tampering and misfueling
rates observed in the surveys. Some of the regression lines
are also shown in Figures 3-7. Each linear equation is
defined by a zero mile rate and an increase in the rate for
every 10,000 miles of fleet average mileage. Other
non-linear equations did not seem to better explain the
increase. It was decided, therefore, to use the linear
equation to estimate the tampering and misfueling rates on
January 1, 1988 using standard EPA predictions of the average
age in miles of each model year on that date.
Least squares regression was used to estimate a line of the
form Y = bX+a, where Y is the proportion of tampered vehicles
at mileage X. The data used to generate estimates of the
regression coefficients, a and b, were the mileage and
whether the vehicle was tampered (Y=l) or not (Y=0) for each
vehicle in the 1982 tampering survey.
Least squares regression, as used in our case, requires
several assumptions concerning the distribution of Y for
fixed X in order to estimate the error variance of a and b.
Ordinarily, the Y values are assumed to be normally
distributed for each value of X. Further, it is assumed that
the variances for these Y distributions are equal at all
points along the line. Since the Y values in our data are
either zero or one, neither of these assumptions are met.
However, an investigation of the properties of the least
squares estimators has shown that they remain unbiased even
in the presence of a binary dependent variable. Since it is
unnecessary to obtain error estimates for the regression
coefficients for this application, it was determined that the
simple least squares regression approach is sufficient for
this application.
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15 -
In calculating equations to predict tampering and misfueling
rates several factors have been considered. The rate of
tampering and misfueling among passenger cars and among
trucks is significantly different. Therefore, each of these
vehicle types were treated separately. Also I/M areas tend
to have lower tampering and misfueling rates than areas
without I/M programs. Each of these two classifications are/
therefore/ also treated separately. Although local tampering
and misfueling rates can vary greatly, only one set of
tampering rate equations is used in this report. If a^
particular area has reason to believe, or has data which"
show, that tampering or misfueling rates are higher in its
area than in the nation as a whole, EPA is willing to
evaluate the evidence and estimate benefits specific to that
area.
Since there is no data in the 1982 survey from model years
before 1975 and since these vehicles should have little
effect on the overall benefits in 1987, it has been assumed
that tampering rates for pre-1975 cars are the same as for
1975 and later passenger cars at equal mileages. It is also
assumed that the tampering and misfueling behavior of 1981
and later model year passenger car owners will not be
significantly different in future years than the behavior of
pre-1981 passenger car owners, for those components treated
in this report. Both of these assumptions are unproven, but
the data available are not adequate to treat these groups
separately. In addition, truck sample sizes are inadequate
to estimate the rate, of increase of tampering and misfueling
for trucks, therefore, the rate of increase in tampering and
misfueling for passenger cars has been assumed for trucks
also, although the zero mile rates have been adjusted to
reflect the observed differences in the average tampering and
misfueling rates between trucks and passenger cars.
Table 3 presents the linear regression equation coefficients
calculated from the tampering survey data. The equations
describe the relationship of tampering and misfueling rates
to vehicle mileage in the non-I/M areas. The light-duty
truck zero mile rate value was calculated using the overall
truck tampering and misfueling rates and average mileage and
projecting backwards to zero miles assuming the same increase
in rate as for passenger cars.
Table 4 presents the same information but for I/M areas
without a formal tampering check. Since the Portland, Oregon
I/M program does a tampering check, the data from this site
were removed from the calculation of the equations in Table
4. Differences in the design and history of the other I/M
programs had to be overlooked in the interest of retaining a
meaningful sample size.
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16
Logically an ordinary I/M program should have little affect
on ?CV and evaporative canister tampering, since they have
little or no affect on idle exhaust emissions measured in I/M
programs. Consequently, the tampering rate for these
components has been calculated using both I/M and non-I/M
areas combined.
In both Table 3 and Table 4 some linear equations contain
negative zero mile rates. Since these negative levels are
small no effort has been made to force the equation through
zero. If, however/ a tampering or misfueling rate for a
particular model year is calculated to be less than zero in
the evaluation year, that rate for that model year is set to
zero.
In both Table 3 and Table 4, overlap among tampering types is
ignored, so one car can contribute to several of the
regression equations. The overall tampering rate at a given
mileage is therefore less than the sum of these equations.
In estimating excess emissions due to tampering and the
benefits of controlling tampering, it is necessary to
explicitly account for vehicles with more than one form of
tampering, since tampering effects are not always additive.
Following sections describe how this was done for each case.
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17
Figure 3
?CV Tampering Rate Versus Mileage*
100
25T
20
- 1
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18
Figure 4
Evaporative Control System Tampering Rate*
Versus Mileage
100
1982 TRHPERING SURVEY RESULTS
o
e
UJ
e_
UJ
CJ
UI
20
10
OfiTfi
REGRESSION
3 4 5 S 7
MILEflGE ( 10K MILES )
10
*3oth I/M and Non-I/M areas.
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19
Figure 5
Air Puinp Tampering Rate
Versus Mileage
198:2 TSHPERINGSURVEY RESULTS
100
25
20
£ IS
0.
e
10.
cc 5
_
X**
X
X
X
X
X
X
I/M RREflS
** NON-I/M
REGRESSION
REGRESSION
0-" " 1
3. 4 S 67
MILESGE ( 10K KILES )
3 .10
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20
Figure 6
Catalyst- Removal Tampering Rate
Versus^Mileace
1982 TflHPERING SURVEY RESULTS
100
25
T
- 20
I 15 .
UJ
10 L
I/H RREfiS
NON-I/M
REGRESSION
REGRESSION
3 4 5 S 7
KILEfiGE ( 10K MILES )
10
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2.1
Figure 7
Hab'itual Misfueling Rate*
Versus Mileage
1382. TflHPERING SURVEY RESULTS
100
- 20 .
o
z
_J
^ IS
u_
in
z
-i 10
S S
I/M
HON-I/M
REGRESSION
REGRESSION
3 14 S S 7
MILEfiGE ( 10K MILES )
10
*Defined as fuel inlet restrictor tampering or greater than
0.05 gin/gal lead in the tank fuel sample.
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22
Table 3
National Average
Tampering Rate Equations
for Non-I/M Areas
Tampering Rate =
(zero if mileage is less than Mo!
(A + E x (mileage) otherwise)
Emission
Control
Component
" M 1 1 J 1
l * O "
(miles) (%)
LDV LDT LDV LDT
"B"
Both
Rate at
50,000
Miles (%)
LDV LD1
Air Pump 10,218 0
Catalyst 11,905 0
PCV System* 354 0
Evaporative*
Canister
Habitual
Misfueling** 1,994 0
2.71 4.89
1.90 14.72
0.01 2.24
15,278 0 -0.55 2.85
-0.50 16.72
2.652 10.55 18.15
1.596 6.08 22.70
0.282 1.40 3.65
0.360 1.25 4.65
2.507 12.04 29.26
*PCV and evaporative canister tampering rates are assumed to
be the same in I/M and non-I/M areas.
**Defined as an enlarged' fuel inlet restrictor or leaded fuel
(lead content greater than 0.05 gm/gal) in tank. Catalyst
vehicles only. See text in Section 2.1 for discussion.
-------
Tampering Rate =
23
Table 4
National Average
Tampering Rate Factors
for I/M Areas
(zero if mileage is less than Mo)
(A + B x (mileage) otherwise)
Emission
Control
Component
"Mo" "A"
(miles) (%)
LDV LDT LDV LDT
"B"
Both
Rate at
50,000
Miles (%)
LDV
LDT
Air Pump
Catalyst**'.
PCV*
909 900 -1.01 -1.00
0 0 0.00 2.53
354
Evaporative*
Canister 15,278
Habitual
Misfueling** 0
0 -0.01 2.24
0 -0.55 2.85
0 1.98 8.64
1.111
0.460
0.282
0.360
0.849
4.55 4.56
2.30 4.83
1.40 3.65
1.25 4.65
6.23 12.89
*PCV and evaporative canister tampering rates are assumed to
be the same in I/M and non-I/M area"sx.
**Defined as an enlarged fuel inlet restrictor or leaded fuel
(lead content greater than 0.05 gm/gal) in tank. Catalyst
vehicles only. See text in Section 2.1 for discussion.
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24
3.0 EFFECTS OF TAMPERING AND MISFUSLING AND COSTS OF REPAIRS
The effect of a particular disablement of a specific emission
control component on vehicle emissions is not easy to
quantify. There are many different varieties of similar
emission, control devices which can differ from manufacturer
to manufacturer and from model year to model year. Different
varieties can also have a different effect on vehicle
emissions depending on the engine type and overall state of
tune as well as the condition of other emission control
components. A testing program which would evaluate every
possible combination of all of these factors would require
immense resources. There has been some testing performed
over the years by EPA to assess the impact of disablements.
FT? and other tests were performed with and without a
particular emission control component disconnected. Usually
all other emission control components were in operation and
the vehicles were in proper tune. The emission increases due
to disablement may vary for vehicles in less perfect
condition, however EPA believes that these tests provide the
best information available on the impact of in-the-field
tampering and misfueling on an individual vehicle's emissions.
In this report the individual vehicle benefits from repairs
of specific emission control component tampering is taken/
when possible, from these types of data. When practical, the
existing data are further divided into appropriate model year
technology groups to take into account changes in the design
and effectiveness of particular emission control components
in different model years. When adequate test data from
disablement testing are not available, estimates of the
benefits were made based on known controlled and uncontrolled
emission levels of vehicles of different model years. This
report does not address NOx emissions; therefore, the effect
of tampering and misfueling on NOx emissions has not been
included in the discussion. The few jurisdictions with N7Cx
attainment problems may want to consider including an SGR
check in an inspection program. In fact an under-the-hocd
tampering inspection which ignores the EGR system - the most
common tampering target - may lack public credibility after
its implementation even if NOx reductions are not needed
locally since public understanding of the differences between
pollutants may be limited.
3 .1 Air Pump
The purpose of the air pump is to supply air to the engine's
exhaust in order to promote the oxidation of HC and CO to
harmless by-products. The air pump performs this function on
both catalyst and non-catalyst vehicles. The air pump is
driven by means of a belt which transmits power from the
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25
crankshaft as it rotates. This method of powering the air
pump is the same as that used to run the alternator and air
conditioner compressor. The air pump can, therefore, be
found near or on the same plane as the alternator or air
conditioning compressor. Its plumbing distinguishes it.
Some vehicles are equipped with pulse-air systems which also
supply supplemental air to the exhaust stream but without a
belt driven pump. Disablement of these systems is less
frequent than for air pump systems and identification of
disabled pulse air systems is not always as easily
accomplished; therefore, this section will deal solely with
disabled air pump systems.
The percentage of vehicles, equipped with air pumps varies by
model year. An analysis of the occurrence of air pump
systems on passenger vehicles in the EPA Emission Factor data
base was used to establish estimates of the percentage of
vehicles in each model year group prior to 1984 equipped with
air pump systems. The percentage for 1984 and later vehicles
was chosen to be 50%, compared to the 75% observed for the
preceding three years: the expectation is that pulse air
.systems will be substituted for some air pump systems as
smaller vehicles become a larger part of the' fleet. The
percentages used are presented in Table 5.
Table 5
Passenger Car
Percent of Various Model Year Groupings Equipped.
With Air Pumps
Assumed Percentage
Model Year Grouping Equipped With Air Pumps
1968-1974 85%
1975-1979 35%
1980 55%
1981-1983 75%
1984 and later 50%
There are three main ways the air pump is normally disabled.
First, the belt which drives the pump can be removed.
Second, the entire unit pump, belt, flexible hoses, steel
piping, and even mounting brackets can be removed. Third,
the output hose from the air pump can be disconnected and/or
the air routing valve can be damaged. This last disablement
results in the air pump spinning freely and no air being
supplied to the exhaust. For purposes of this report, it is
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26
assumed that all three of these forms of disablement can be
readily identified by trained inspectors during an inspection.
The repairs necessary for these various forms of disablement
are self-evident. In most cases, repair can be accomplished
by simply installing a new belt or reconnecting a hose. An
average repair cost of $20 has been assumed for this
analysis. This estimate takes into account the few cases in
which an expensive repair or reinstallation of an air pump is
expected to be required.
The HC and CO emission increases which accompany air pump
disablement for 1975-1979 model year vehicles were quantified
by examining data from 11 vehicles (1275-1979 model years)
tested with and without their air pumps operational. Nine of
these vehicles came from the 300-car Restorative Maintenance
program[4]. The other - two vehicles came from a test program
which examined regulated,, and unregulated exhaust emissions
from catalyst vehicles [5]. These data indicate that upon
air pump disablement the average HC emission level increases
1.2 cm/mi and. the average CO emission level increases 28.0
gm/mi. (One source of uncertainty in the analysis has to do
with the fact that the 11 vehicles used to determine the
emission effects of air pump disablement were all in tuned-up
condition. The emission increases due to air pump
disablement for vehicles in less perfect condition may vary.)
There is some uncertainty as to the HC and CO effects of air
pump disablement for pre-1975 model year vehicles as no
similar data are available. However/ these vehicles
contribute only a very small share of the fleet's emissions
over the life of an I/M program. They are assumed to show
the same absolute effect due to air pump tampering as
1975-1979 vehicles. In absolute terms, the assumed effect is
an increase of 1.2 gm/mi HC and 23.0 gm/mi CO. This
assumption is reasonable and due to the small contribution
made by these vehicles, does not significantly affect the
analysis .
'For 1981 and later model year vehicles, the effects of air
pump disablement were quantified by examining the results of
EPA laboratory programs which took four vehicles
representative of 1981 and later technology and tested them
with and without their air pumps operational. In addition,
one representative 1980 Ford vehicle tested in an SPA
surveillance program in California was found to have its air
pump disabled due to having one of the vacuum control hoses
kinked closed. This vehicle was tested as-received (air pump
disaoled) as well as after having the air pump repaired
(vacuum hose unkinked). Data from these five vehicles
indicate that upon air pump disablement for 1981 and later
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27
vehicles the average EC emission level increases 0.5 gm/mi
and the average CO emission level increases 15.0 gm/mi.
No comparable test data are available for 1980 model year
vehicles. For purposes of this report, 1980 model year
vehicles were assumed to have the same emission effects for
air pump disablement as 1981 and later vehicles. This is
because the 1280 emission standards (0.41 gm/mi HC; 7.0 gm/mi
CO) are closer to the 1981 standards (0.41 gm/mi HC; 3.4
gm/mi CO) than to the. 1975-1979 standards (1.5 gm/mi EC; 15
gm/mi CO). All of the assumed benefits from repair of air
pumps are summarized in Table 6..- '
Table 6
Increase in HC and CO Emissions
Due to Air Pump Disablement
Increase in Increase in
Model KC Emissions CO Emissions
Years (gm/mi) (gm/mi)
Pre-1980 1.20 28.01
1980 and Later ' 0.48 14.98
3.2 Catalyst
Automotive catalytic converters lower HC and CO emissions in
the exhaust by catalytically promoting the oxidation of EC
and CO to harmless by-products. (Catalysts on most 1S81 and
later vehicles also help reduce MOx emissions.) Catalysts
are normally mounted on the underside of the vehicle, along
the exhaust pipe and before the muffler; however, a few
vehicles have catalysts mounted inside the engine
compartment. Tampering with the catalyst usually takes the
form of simple removal of the catalyst and replacement with
an exhaust pipe. Some automotive parts suppliers carry a
complete selection of catalytic converter "test pipes" which
can be bolted into the gap left in the exhaust pipe after the
converter is removed.'
Using carefully- placed mirrors or a mirror on an extension,
the underside of an inspected vehicle can be examined for the
presence of the converter. A catalytic converter is easily
distinguished from a muffler since it is made of stainless
steel and will not rust. If a catalyst is not observed by
checking underneath a 1975 or later model year vehicle, it
will be necessary co open the engine compartment hood and
either locate the catalyst there or confirm from the
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28
emissions label put on every vehicle or from reference
literature that the vehicle was not equipped with a catalyst
at the factory. Colorado State University has recently
published a book which contains this information.[6 ] For
this analysis all 1975 and later passenger cars are assumed
to have been equipped with some type of catalyst.
Obviously repair will require installation of a new catalyst
(or reinstallation of the old one if it was saved) . This
could be a relatively expensive repair. New catalysts now
cost between $172 and $320. Most of this cost is dealer and
distributor markup. However/ most vehicles do not require
the more expensive converters. A market for lower-priced
non-OEM catalysts may also appear, if new OEM catalysts are
not a requirement of the program. Lower-priced replacement
catalysts are possible if enough demand is created by a
catalyst check. An average cost of $200 per catalyst has
been assumed for this analysis.
The EC and CO emission increases which accompany catalyst
removal were determined by examining the engine-out (before
the catalyst) emissions cf a number of vehicles involved in
several test programs. These vehicles received both baseline
tests (all components functional) and tests with the catalyst
removed. By comparing the results -of the two tests the
percent increase in emissions which accompanies catalyst
removal can be calculated. Most catalysts are removed with
the intent of also using leaded fuel. There is evidence that
the use .of leaded fuel itself will cau.se an increase in HC
emissions due to lead deposits in the engine. This effect
has been ignored in this analysis. Nine vehicles with
oxidation catalysts and four vehicles with three-way
catalysts were tested.
1S80 model year vehicles were assumed to have the same
increase as 1975-1979 vehicles. This was done because the
catalysts used on 1980 vehicles are more like those used on
1975-79 vehicles than those used on 1981 and later vehicles.
These figures are presented in Table 7.
Insufficient testing has been conducted to determine how the
effect of catalyst removal varies with the average mileage of
a fleet. It is, therefore, assumed that the gram-per-rnile
increase in emissions from catalyst removal remains the same
throughout a vehicle's life, regardless of mileage. This
will mean that the percent change cue to catalyst removal
reduces with increased mileage. This makes sense since very
little of the deterioration of the fleetwide emission factor
is due to catalyst aging. Most is due to in-use
maladjustments and failures of ether emission components.
Removing the catalyst on a vehicle that has high engine-out
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29
emissions can be expected to have a smaller percentage effect
than removing a catalyst from a tuned vehicle, since there is
usually a relative shortage of oxygen in the exhaust of
maladjusted vehicles. This does mean that the estimates will
include some degree of uncertainty, especially when applied
to high mileage vehicles.
Table 7
Increase in HC and CO Emissions
Due to Catalytic Converter Removal
Increase in Increase in
Model HC Emissions CO Emissions
Years (gm/m i) (gm/m i)
1975-80 3.84 38.02
1981 and Later 1.68 " 17.47
3.3 Habitual Misfueling
The use of leaded gasoline in a vehicle equipped with a
catalytic converter, referred to as "misfueling" in this
report, will cause a steady contamination of the catalyst
material resulting in lower and lower catalytic efficiency.
The result of continued misfueling will., therefore, be higher
exhaust emission levels as the catalyst loses its ability to
convert pollutants into less harmful substances. It has been
estimated that after as few as three consecutive tankfuls of
leaded fuel, the majority of - the catalyst's ability to
convert pollutants will be permanently lost, even if the
vehicle owner resumes use of unleaded fuel.
Determining tfre effects of misfueling is more difficult than
for most other checks described in this report, since the
increase in emissions is heavily dependent on catalyst
efficiency and thus the intensity of the misfueling.
Misfueling performed sporadically or in temporary fuel
shortages, often refered to as "casual" misfueling, may not
permanently destroy the catalyst's function, although there
will be some lasting reduction in catalyst efficiency. This
section estimates only the effect of habitual misfueling,
based on tests of vehicles operated on leaded fuel for many
tankfuls. There is insufficient test data to estimate the
long term effects of casual, misfueling, therefore casual
misfueling is assumed to have a comparatively negligible long
term effect on fleet emissions.
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30
Even in cases of habitual misfueling, some very low level of
catalyst efficiency may still remain. For this reason the
effect of misfueling is not as great as removal of the
catalyst on an individual basis. Since the overall rate of
misfueling is larger than that of- catalyst removal, however/
the overall effect on emissions is more serious.
EPA has previously estimated the average effect on HC and CO
emissions of misfueling. These estimates were used in the
mobile source emission factors model (MOBILE2) to adjust the
emissions of EPA's essentially misfueling-free emission
factors test sample to reflect the extent of misfueling in
the fleet as a whole. These estimates were used in the form
of a percent increase over the average low-mileage emissions
of non-misfueled cars. In this analysis all data now
available were examined to recalculate a gram per mile
increase. This data included data from nine oxidation
catalyst vehicles and seven 1981 and later three-way catalyst
vehicles. The emission increases for 1981 and later model
year vehicles include any effect misfueling has on oxygen
sensor performance in the closed-loop vehicles in the
sample. Most vehicles were run on at least 10 tankfuls of
leaded fuel. Estimates for 1980 vehicles assume the same
emission increases as for 1975-79 vehicles since their
catalysts are similar. Table 8 presents the estimated effect
on emissions as a gram-per-mile increase. As with catalyst
removal, the increase expressed in grams per mile is assumed
not to change with mileage.
Table 8
Increase in HC and CO Emissions
Due to Misfueling
Increase in Increase in
HC Emissions CO Emissions
Model Years (gm/mi) (gm/mi)
1975-80 2.67 17.85
1981 and later 1.57 11.07
The average cost of replacing a misfueled catalyst will be
less than replacing a removed catalyst since in some
instances, only the catalytic material within the catalyst
need be replaced. Some manufacturers catalysts have a
removable plug for this purpose and provide ,
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31
replacement catalytic material. In this analysis, the
average cost for replacing misfueled catalysts will be $150.
If repair of the fuel inlet restrictor is required,
replacement cost of the restrictor will vary substantially.
Some vehicles filler neck can be easily replaced while others
would require replacement of the entire fuel tank. It is
possible, however, to repair the fuel inlet by simply glueing
in a metal washer using a gasoline resistant epoxy. It is
likely 'that the majority of vehicle owners will seek out
inexpensive repairs so that the average cost of repair will
be small. In this analysis the average repair cost for
tampered' fuel inlet restrictors will be $30.
3.4 Positive Crankcase Ventilation System
The positive crankcase ventilation (PCV) system in
automobiles provides a means to purge the crankcase of gases
escaping from the cylinders by the piston rings. These gases
are detrimental to engine life since they dilute and break
down engine oil and are corrosive. Originally these gases
were vented to the atmosphere, but with the advent of
pollution control, these gases have been diverted to the
vehicle's intake system for recombustion. The value of the
PCV system is well known and established; therefore, its
deliberate disablement is relatively rare. Only a small
percentage of the vehicles in EPA's surveys had their PCV
vacuum, hoses disconnected resulting in the. blowby gases being
released to the atmosphere. Other PCV problems, such as
disconnected "fresh air" hoses, also occur but are not
believed to cause a significant increase in emissions from
the automobile.
Disablement of the PCV system usually takes the form of a
disconnected vacuum line or missing components. These
disablements are easily identified either visually or by a
simple check for vacuum at the fresh air hose. Since all of
the components are relatively inexpensive, and since many
disablements are simply disconnections, repair costs are
assumed to be $10.
The primary effect of a disabled PCV system is the increase
in non-exhaust EC emissions. There is not enough data from
recent testing programs on the effects of PCV disablement on
current vehicles to determine with complete certainty how
much EC emissions would increase. However, it is estimated
in MOBILE2 that the average crankcase EC emissions from early
1960's vehicles without PCV systems were about 4.1 gm/mi[7j.
At the time, most engines had eight cylinders. It is
reasonable to assume that uncontrolled crankcase emissions
are proportional to the number of cylinders, so current and
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32
future vehicles, which will on average have fewer than eight
cylinders, will have proportionately less of an increase when
their PCV system is disabled. Based en this assumption,
6-cylinder engines should have a 3.08 gm/mi effect and
4-cylinder engines a 2.05 gm/rni effect.
To estimate the average effect of PCV disablements, the mix
of four, six, and eight cylinder engines in the various model
year groups must be determined. Using information on the
past and predicted production of vehicles produced in the
U.S.[8] and assuming that nearly all imported vehicles are
equipped with four cylinder engines, the percent mix of
engine sizes can be estimated for each model year group.
These values were used to combine the estimates for crankcase
HC emissions from each engine size to determine an overall
figure for each model year group. These overall figures are
presented in Table 9.
Table 9
Increase in HC Emissions
Due to PCV Disablement
Increase in HC Emissions
Model Years (gm/mi )
Pre-1968 3.80
1968-1970 3.74
1571-1974 3.51
1975-1977 3.44
1978-1979 3.29
1980 2.83
1981-1982 2.68
1983 and Later 2.49
3.5 Evaporative Emission Control System
The evaporative control system is intended to capture the
gasoline fumes which are naturally given off whenever
gasoline is stored and used. These fumes are made up of pure
hydrocarbon (HC) emissions and represent a significant
portion of a vehicle's total HC emissions. The evaporative
control system captures the fumes given off by both gasoline
in the fuel tank and the gasoline in the carburetor (early
systems dealt only with evaporative losses from the fuel
tank). These fumes are stored in a charcoal canister,
usually mounted in the engine compartment, and then routed to
the engine for burning at appropriate times.
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33
Disablement can take the forra >of disconnected or cut hoses,
missing canisters, or removal of the entire system. Once
again, these forms of disablement are identifiable by trained
inspectors. A quick visual check can usually .determine
whether the canister is still intact and if all the hoses are
attached to it. An average repair cost of $10 has been
assumed since most repairs will involve simply reconnection
of hoses.
The emission increases assigned to each grouping to represent
a tampered system come from MOBILE2. The passenger car model
year groupings used in MOBILE2 are: pre-1970, 1970-1971,
1972-1974, 1975-1977, 1978-1980, 1981 and later. The
assumption used to determine the increase in emissions due to
evaporative system disablement for pre-1977 vehicles was that
any disablement would return the vehicle to uncontrolled
levels (pre-1970) of evaporative HC. This assumption is
necessary since there has been no disablement testing done
for evaporative control systems on these older vehicles.
These vehicles are similar, however, in size and design to
the pre-controlled vehicles so that the error should be.
small. Newer vehicles have smaller carburetors and gas tanks
and therefore should emit less evaporative emissions even if
tampered. Two 1981 model year vehicles have been tested with
and withput disabled evaporative canisters. As expected the
average evaporative emissions with the evaporative canister
disconnected were less than for pre-controlled vehicles.
Since downsizing for passenger cars began with the 1977 model
year and leveled off after the 1980 model year the
uncontrolled emission levels for those model years were
interpolated between the evaporative emission levels of
pre-1970 vehicles and the test results from the 1981
vehicles. The resultant increases in evaporative HC
emissions due to disablement, of the evaporative control
system are tabulated in Table 10.
Because of different assumptions for average mileage traveled
for light-duty trucks below 6000 pounds, the increases in
evaporative emissions for these vehicles are somewhat
higher. Light-duty trucks over 6000 pounds built before the
1979 model year were not equipped with evaporative control
systems other than the PCV system. The increase in
evaporative emissions for light-duty trucks also reflect the
differences in mileage assumptions and assume no downsizing,.
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34
Table 10
Increase in KC Emissions Due To
Evaporative System Disablement
Increase in Evaporative HC Emissions (gm/mi)
Model
Years
1971
1972 -1976
1977
1978
1979
1980
1981 and Later
Passenger
Cars
0.69
Light-Duty Trucks
1.
1
1.
1
18
01
70
53
1.36
1.50
(0-6000 Ibs)
0.81
1.39
1.39
2.41
2.41
2.41
(6000-8500
^
-
-
-
1.88
1.88
Ibs)
2.58
2.01
3 . 6 Light-Duty Truck
In HOEILE2 light-duty vehicles (passenger cars) are treated
separately from light-duty trucks. In fact/ MOBILE2 divides
light-duty trucks into two groups, those less than 6,000 Ibs
gross vehicle weight (LDT1) and those . between 6,000 and 8,500
Ibs (LDT2), Since light-duty trucks make up a significantly
smaller portion of the vehicle fleet than passenger cars,
less is known about the occurrence and effects of tampering
on these vehicles than on passenger cars.
Since the emission standards applicable to light-duty trucks
(LDTs) in a given calendar year are often quite different
from passenger cars, it can be expected that emission control
devices used on LDTs, such as air pumps and catalysts, will
differ in a given calendar year from those on passenger
cars. However, as the emission and fuel economy standards
for light-duty trucks become more and more stringent, these
vehicles will closely resemble passenger cars with similar
emission standards. Table 11 presents the assumptions used
in this report regarding the number of light-duty trucks
equipped with various emission control components. These
estimates were taken from EPA's emission factor samples where
adequate samples were available. Otherwise the percentages
were assumed to be- equal to equivalent passenger car
percentages .
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35
Table 11
LDT Emission Control Equipment Assumptions
Percent of Vehicles Equipped With Components
LDT Model Year
Type Grouping
Air Pumps Catalyst PCV
Evaporative
Canister
LDT1 1968-1970 85%
1971-1974 - . 85%
1975-1978 "-, 35%
1979-1983 '"42%
1984 and Later 75%--
LDT2 - 1968-1970
1971-1974
1975-1978
1979-1983 50%
1984 and Later 75%
70%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
In general, the per-vehicle emission benefits estimated for
passenger cars have been used for light-duty trucks using the
same emission control components. The primary differences
will be in the model years using a particular estimated
benefit. For example, only the 1979 and later LDT2s are
assumed to have been equipped with catalysts and therefore
would receive emission benefits from a catalyst inspection
program.
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36
4.0 CALCULATION OF EXCESS EMISSIONS DUE TO TAMPERING AND
MISFUELING
This section calculates the additional, or excess/ emissions
caused by all four types of tampering and habitual misfueling
combined. The purpose of doing so is to illustrate the size
of the problem to be addressed by an anti-tampering or
anti-raisfueling program. This section also illustrates the
relative importance of different forms of tampering. Section
5.0 presents estimates of how much emission reduction is
possible from different types of programs.
4.1 Discussion of Method
The approach used in this report to estimate the effects on
composite emissions of vehicles due to tampering and
raisfueling is similar to MOBILE2, in that a separate benefit
is calculated for each model year of each vehicle type, and
then the results are weighted by the distribution of.
vehicle-miles-traveled (VMT) for the model years on the
evaluation date of interest. MOBILE2, however, is much more
sophisticated in that It can adjust for differing scenarios.
of speeds, temperature, and mixture of. vehicle types and
vehicle miles traveled. For simplicity, all calculations in
this report assume standard MOBILS2 operating conditions and
default values. The results should be adjusted as described
in Section 5.0 to reflect local non-standard FTP conditions.
To calculate the excess emissions due to tampering and
misfueling for a given model year, first the appropriate
emission level increase due to that particular form of
tampering or misfueling on individual vehicles of that model
year should be selected from Section 3.0 along with the
fraction of vehicles equipped with that emission control
component. Next the tampering or misfueling rate for that
model year in the evaluation year must be calculated using
the appropriate equation presented in Section 2.0. I/M areas
and non-I/M areas will have different rate equations.
When the tampering rate and the individual vehicle repair
benefit in grams-per-miie are all multiplied together, the
result is gram-oer-mile excess emissions from the average
vehicle- of that model year. Once excess emissions are
calculated for all model years covered, the excess emissions
are weighted- by their appropriate VMT ratio and added to give
composite fleet excess emissions in grams-per-mile. These
estimates can then be converted to tons by multiplying by the
average mileage accumulation of the fleet in the last
calendar year prior to the evaluation date.
It should be noted that some of the excess emissions
calculated in this way are already reflected in the total
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37
fleet inventory as calculated by MOBIL£2, since MOBXL22
emission factors incorporate the effect of some tampering,
primarily misfueling. Of the tampering types, MQBIL£2 least
accounts for catalyst removal, which appeared to be less
frequent when MOBILZ2 was developed than it now appears.
Future revisions, of MOBIL22 will attempt to correctly account
for; all- relevant forms- of tampering* . Until such revisions
are completed, the benefits- from - ant i-tamper ing and
anti-misfueling programs can be subtracted directly from, the
198.7 inventory as calculated by MOBIL22.
4.2 Sxample Calculation
As, an example of how excess emissions from tampering and
misfueling are estimated, the calculation of the EC emissions
from disabled air pump systems on passenger cars will be
described in detail in this section* For simplicity, it is
assumed for this example only that all cars with air pump
tampering have no other form, of tampering. Actual overlap is
accounted for in the next subsection.- All benefits
calculated in this report use this basic, methodology to
compute the excess- emissions caused, by tampering and
misfueiing, with modifications described in Section 5..Q-.
Table 12 presents the- basic calculation of the milligram-,
ai-la increase in SC emissions of all passenger cars caused by-
air pump disablements. It is assumed that, this is a. non-T/k
area and the evaluation date is January. 1, 1988. For each
model year a rate of tampering is calculated using the
coefficients presented in. Section 2»0 for non-I/M areas and
22A's standard estimates of the. average: mileage of. each- model
year on January I/. 1938. The fraction of vehicles, equipped
with air pumps and the per vehicle increase in SC emissions
(in graras-per-miie) due to disablement of the air pump in
each model year is taken from the discussion in Section 3.1.
The vehicie-miies-iraveied (VMT) fraction on the evaluation
cats is taken from M03IL£2 for the evaluation date. when the
factors are multiplied together and summed, the total
(expressed here in miiiigrams-per-miie) represents the
average increase in EC emissions of every passenger car due
to those cars with disabled air pumps..
In. 1983 the average mileage accumulation for passenger cars
is about 11,460 miles per year. The sstimata of increase in
EC emissions in miiligrams-per-mila can be easily converted
to tons by estimating the number of vehicles in the area of
interest and multiplying the milligrams-pec-mile increase
'times the average annual, mileage accumulation per vehicle
times the number of vehicles and converting the result into
tons. For example, in this case for 100,000 passenger cars
using the result in Table 12:
57.33 mg/ai * 11,460 mi * 100 ,-QOO/(9 . 072 x 10s nig/ton)
=73.1 tons
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38
Table 12
Example Calculation of
Excess Emissions From Tampered Air Pumps
Model
Year
Pre-1970
1970
1271
1972
1373
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
Evaluation
Year
Air Pump
Tampering
Rate
45
44
42
41
39
37
35
33
31
28
26
23
20
17
14
10
7
3
0
0
.5
.2
.7
.1
.4
. 5
.5
.3
.0
.6
.0
.3
. 4
.4
.2
.9
C
* -/
.9
.1
.0
Fraction of
Vehicles With
Air Pumps
Increase in
HC Emissions
- Due to
Disablement
(gm/mi
.00*
.85
.85
.85
.85
.85
.35
.35
.35
.35
.35
.55
.75
.75
.75
.50
.50
.50
.50
.50
1.20
1.20
1.20
1.20
1.20
1.20
1.20
1.20
1.20
1.20
1.20
0.48
0.48.
0.48
0.48
0.48
0.48
0.48
0.48
0.48
Evaluation
Year
VMT
Fraction
(1/1/88)
.007
.001
.001
.003
.007
.011
.018
.025
.031
.045
.057
.067
.075
.095
.113
.104
.083
.109
.120
.028
Resulting
Excess
(mg/mi)
0.00
0.40
0.63
1
2
44
.71
4.21
2.68
3.52
4.04
5.36
6.27
4.11
5.48
5.95
5.79
2.74
1.48
1.01
0 .04
0.00
Total
1.000
57.83
mg/mi
*A1though some
equipped with air
of the VMT fraction for the
increase the accuracy of
calculations, the additional
1963 and 1969 model
pumps, they represent
year vehicles were
only a small portion
pre-1970 vehicles. Therefore to
the estimate in this and all
amiss ion contribution from these
two model years has been ignored.
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39
In order to estimate the benefits of anti-tampering and
anti-misfueling programs the result would be multiplied by an
effectiveness factor for the proposed program. Different
types of programs will have different effectiveness factors
and they may depend on model year. These factors for
inspection programs are discussed in Section 5.1 for I/M
areas and in Section 5.2 for non-I/M areas. Inspection
programs which are not periodic and other non-inspection
programs are discussed in Section 5.3.
4.3 Emissions Due to Tampering and Misfueling: All Types
Tables 13 and 14 present the estimates of excess emissions on
January 1, 1988 due to all forms of tampering and habitual
misfueling using the estimates of tampering and misfueling
rates as discussed in Section 2.0 and the increases in
emissions due to tampering and misfueling from Section 3.0.
As discussed earlier these results have not been adjusted for
non-standard conditions. Section 6.0 discusses a way to
adjust these figures to local conditions. Table 13 assumes
that there is no I/K program in the area of interest, while
Table 14 assumes the existence of an I/M program. For
comparison, MOBILE2 predicts that without I/M on January 1,
1988 the total composite emissions from these vehicles to be:
0 Passenger Cars
0 Light-Duty Trucks:
( £000 Ibs) 2.59 gm/mi 24.30 gin/mi
(6000-8500 Ibs)* 1.57 gm/mi 14.11 gm/mi
These MOBILE2 emission levels, however, assume only an 8%
rate of misfueling and contain much smaller rates of
tampering than observed in the tampering surveys.
Section '5.0 will discuss how anti-tampering and anti-
misf ueling programs can reduce the excess emissions and
estimate the benefits of these programs.
*These heavier trucks emit more HC and CO emissions than
passenger cars or the lighter trucks of the same model year,
however, MOBILE2 assumes that the majority of the VMT
accumulated by these trucks is accumulated by the new (and
cleaner) model years so that this composite number shows a
lower contribution than would occur if the distribution of
VMT were similar to the passenger cars.
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40
In the data used to generate Tables 13 and 14, there is an
overlap in the incidence of tampering and misfueiing. To
account for this overlap assumptions were made in order that
the excess emission levels wees not double counted. In the
1382 survey data, about 20% of the passenger cars and 70% of
the light-duty trucks with disabled air pumps also either had
the catalyst removed or had been misfueled. Therefore, it
has been assumed that the catalyst removal or misfueiing 'is
the primary problem causing excess emissions and no
additional excess emissions is caused by the disablement of
the air pump. The excess emissions from such vehicles is
included in the catalyst or misfueiing category in Tables 13
and 14. There is also overlap between misfueiing and
catalyst removal. It is assumed that a vehicle which has had
the catalyst removed will emit the same regardless of whether
it is misfueled or not. Only vehicles with intact catalysts
which are also misfueled fall inco the misfueled category.
.In the 1982 survey, 31% of the passenger cars and 55% of the
light-duty trucks which were habitually misfueled had the
catalyst removed.
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41
Table 13
Per Vehicle Excess Emissions Due
to Tampering and Misfueling
in Non-I/M Areas
(January 1, 1988)
Composite Per Vehicle
Emission Increase in Emissions (mg/mi)
Control Passenger Car Light-Duty Truck
Component ( 6000 Ibs) (6000-8500 Ibs)
HC_ CO HC CO HC CO
Air Pump* 44.27 1183.92, 57.25 1336.31 27.48 641.47
Catalyst 221.44 2226.25 818.53 8104.31 714.52 7074.43
Misfueling** 214.00 1462.49 325.04 2173.04 271.67 1816.21
PCV System 53.19 0.0 112.47 0.0 84.21 0.0
Evaporative
Canister 26.17 0.0 116.44 . 0.0 75.05 0.0
Totals(mg/mi) 559.07 4872.65 1429.74 11613.66 1172.93 9532.11
Totals(gm/mi) 0.56 4.87 1.43 11.61 1.17 9.53
Tons*** 506.37 4413.33 113.22 919.70 72.72 590.97
*Because some of the vehicles with disabled air pumps also had
catalysts removed or had been misfueled, the excess emissions due
to the overlap has been removed from the air pump category to
avoid double counting.
**Because of the overlap between catalyst removal and misfueling,
the excess emissions due to the overlap have been removed from
the misfueling category to avoid double counting.
***Annualized tons calculated assuming a fleet of. 100,000
vehicles of all types and using MCBILE2 estimates of passenger
car and light-duty truck vehicle miles traveled.
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42
Table 14
Per Vehicle Excess Emissions Due
to Tampering and Misfueling
in I/M Areas
(January 1, 1988)
Composite Per Vehicle
Increase in Emissions (mg/mi)
Emission
Control
Component
Air Pump*
Catalyst
Misfueling**
PCV System
Evaporative
Canister
Totals(mg/mi) 272.50 1941.63 563.76 3085.25 432.68 2368.93
Totals(gm/mi) 0.27 1.94 0.56 3.09 0.43 2.37
Tons*** 246,81 1758.60 44.65 244,33 26.82 146.87
Passenger
Car
Ligh
t-Duty Truck
( 6000 Ibs)
EC
18
75
99
53
26
.84
.29
.01
.19
.17
CO
504
758
678
0
0
.41
.27
.85
.0
.0
EC
16
176
141
112
116
.82
.18
.85
.47
.44
CO
392
1744
948
0
. 0
(60
00-8500 Ibs)
EC
.52
.38
.34
.0
.0
4
143
125
84
75
.83
.24
.35'
.21
.05
CO
112
1418
838
0
0
.66
.23
.03
.0
.0
*3ecause some of the vehicles with disabled air pumps also
had catalysts removed or had been misfueled, the excess
emissions due to the overlap has been removed from the air
pump category to avoid double counting.
**3ecause of the overlap between catalyst removal and
raisfueling/ the excess emissions due to the overlap have been
removed from the misfueling category to avoid double counting.
***Annualized tons calculated assuming a fleet of 100,000
vehicles of all types and using MOEILE2 estimates of
passenger car and light-duty truck vehicle miles traveled.
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5.0 BENEFITS OF ANTI-TAMPERING AND ANTI-MISFUELING PROGRAMS
This section estimates the benefits of anti-tampering and
anti-misfueling programs using the data and method described
in previous sections. As discussed in the previous sections,
the benefits of anti-tampering and anti-misfueling program
will depend on three major factors..
These are:
0 The rate of tampering and misfueling in the area.
0 The amount, of excess emissions caused by tampering and
misfueling.
0 The effectiveness of the program in eliminating tampering
and misfueling.
The rate of tampering and misfueling was addressed in Section
2.0. 'The amount of excess emissions caused by tampering was
discussed in Sections 3.0 and 4.0. This section will discuss
the effectiveness of specific anti-tampering and
anti-misfueling programs and estimate their benefits in both
I/M and non-I/M areas.
There are. several factors which influence the effectiveness
of anti-tampering and anti-misfueling programs;
0 The perceived incentives for tampering and. mi-s'fueling.
0 The ability of the program to detect tampering and
misfueling
0 The size of the penalty for tampering and misfueling.
0 Enforcement action to assure that the program operates as
designed.
0 The number of vehicle owners who continue to tamper or
misfuel after the program begins.
0 The rate of inadvertent disablements.
Each of the following sections will address these issues and
decide on an appropriate level of effectiveness for each type
of disablement and each program design in both I/M and
non-I/M areas.
In order to claim- the full benefits estimated in the tables
in this section the program would require the following
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44
elements to assure operation as designed. Programs lacking
some of these elements are feasible but would require
individual evaluation.
0 Inspector training.
0 A method to assure vehicle owner compliance with the
program requirements.
0 A method to determine ' which vehicles require which
emission control components.
0 Data collection to monitor the- program and identify bad
actors among" inspectors, inspection stations/ and repair
facilities. '---.._
0 Periodic audits of inspection stations in decentralised
programs to verify inspector proficiency and compliance.
with other program requirements.
0 Enforcement actions such as using an "unmarked* test car
in decentralized programs to assure inspector compliance
with program rules.
0 A referee system for decentralized programs to resolve
disputes.
0 A public awareness program.
Public acceptance of a vehicle inspection program which
requires catalyst replacement where misfueling is indicated
will be improved if there is a visible program to require
compliance with fuel regulations on the part of retail
gasoline outlets. The Plumbtesmo test may fail a vehicle
whose only use of leaded fuel was inadvertent due to
contamination or mislabeling at the pump. It is important
that these occurrences be minimized for equity reasons.
Therefore if a State or local area intends to use the
Plumbtesmo test to detect misfueling, there should also be a
program of unscheduled periodic inspections of retail
gasoline outlets. This program should inspect the diameter
of fuel pump nozzles, determine that the pumps are properly
labeled, and analyze the lead content of the fuel being sold.
Benefits from anti-tampering and anti-misfueling programs are
obtained by addressing two problems, existing tampering and
misfueling and the tampering and misfueling which has not yet
occurred. Existing tampering and misfueling can only be
addressed by identifying tampered and misfueled vehicles and
requiring their repair. Tampering and misfueling that has
not yet occurred can be detected when it does occur or can be
prevented from occurring by the assurance of detection and
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45
penalty in the program. Tampering and misfueling which has
already occurred is calculated as the rate of occurrence at
the start date of the tampering inspection program, assumed
to be January 1, 1984 for the benefits presented here. The
tampering and misfueling which will occur between the program
start date and the evaluation year without the intervention
of the inspection program is the difference in the rates
calculated for the start date of the program and the
evaluation date assuming no program.
5.1 I/M Programs
I/M programs offer a unique opportunity to address the
tampering issue. Although I/M programs will reduce the
incidence of tampering and misfueling to some extent without
any special activity, the fact that large segments of the
fleet are periodically inspected provides an opportunity to
specifically check for tampering and misfueling. Some I/M
programs have seen the advantages in expanding the inspection
and already include a check for tampering.
Section 2.0 discussed the effect of I/M on tampering rates.
The I/M rates discussed in that Section are the rates used
for all .calculations in this section, except that overlap
among tampering types is accounted for. The individual
.vehicle benefits and costs of repairs of tampering and
misfueling .are those discussed in Section 3.0. The
methodology explained in Section 4.0 was used to calculate
excess emissions due to tampering and misfueling and program
costs. Only annual and biennial programs are considered in
this section.
5.1.1 Program Effectiveness
For periodic inspection programs, such as I/M programs, it is
assumed that the program will require repair or replacement
of the disabled emission control components once they are
discovered, followed by reinspection of the vehicle and/or
the repair receipts to verify compliance.
fn
The assumptions used to calculate benefits for inspection of
individual components and combinations of components are
explained and justified below. Section 5.1.2 then presents
the results of the calculation of benefits. The details of
the calculation are not presented. For all components,
benefits are shown for 1984 and later vehicles separately
from those for older vehicles, for the convenience of
jurisdictions which plan to inspect only 1980 and later or
1984 and later vehicles.
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46
The only site in the 1382 EPA tampering survey which has an
anti-tampering inspection is the ?ortland/ Oregon site.
Portland has also had an I/M program since 1974. The fact
that Portland has an anti-tampering program presumably
explains largely why Portland has a lower tampering rate than
any of the other I/M sites in the 1932 survey. Other
factors/ such as local behavior/ the stringency and age of
the I/M program, and the age of the anti-tamper ing program
itself probably all contribute to the effectiveness observed
in Portland. Also, the survey in Portland was conducted at
the I/M inspection site. Vehicle owners presenting their
vehicles for inspection knew beforehand that their vehicle
would be inspected for tampering and that they would be
required to repair any tampering be-fore they could register
their vehicle. It is likely/ therefore, that a few vehicle-
owners repaired their vehicles' tampering just before
presenting their vehicle for inspection. This would cause
the survey to underestimate the actual rate of tampering and
misfueiing in Portland. Comparison to Portland is therefore
used only as a guide to estimate the effectiveness of
anti-tampering programs in other areas.
In comparing Portland tampering rates to other areas, only
passenger car results were used. Only 44 trucks were
inspected in Portland which provides too few -vehicles for a
separate analysis' for trucks. Trucks and cars were not
combined because the tampering rates for trucks are clearly
different jihan those for cars. The effectiveness of the
anti-tampering inspection for trucks was therefore assumed to
be equal to the effectiveness- estimated for passenger cars.
PC/ and Svapcrative Systems - The inspection for the PC/
system is quite simple. The inspector need only assure that
the PC/ valve and connecting hose to the carburetor are both
present and connected. -The evaporative control system^ is
more complicated. The canis-er may be located somewhere
other than, in the engine compartment, misleading an inspector
into thinking it has been removed or encouraging the
Inspector not to check hose connections at the canister.
Often there are spaces for extra connections on --he canister
which are unused even when it is properly connected. A false
failure can be avoided by checking the hose routing diagram
.attached underneath the hood. It is advisable for programs
which check the evaporative canister to also require a gas
cap to be present. Although the rate of missing gas caps is
small, che"evaporative concrol system does not work properly
without it.
In Portland, the rate of disabled PC7 systems is 27% less
than in the other nine sites in the survey. The rate of
evaporative canister tampering is 20% less. This difference
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47
is assumed to be entirely due to the tampering1 check
performed in Portland as part of the biennial: I/M program.
An annual inspection is expected to reduce the number of
disablements even more, so an annual PCV check is assumed to
be 40% effective and an annual evaporative canister check is
assumed to be 30% effective.
The rather low effectiveness values (27% for PCV and 20% for
evaporative) observed in Portland are somewhat surprising but
can be explained. In the case of. the evaporative canister
and the PCV system it can be speculated that many
disablements are inadvertent since there is virtually no
incentive for vehicle owners to deliberately disconnect these
devices. Moreover, the penalty, reconnection or replacement,
is so inexpensive that there is little incentive to repair
the systems between inspections even if the owner is aware of
the disablements. Consequently, deterrence of these two
forms of tampering is probably low. The Portland inspectors
may not be 100% accurate in the inspections for PCV and
evaporative systems.
Benefits from a PCV or evaporative canister inspection can be
added to any of the other inspections. This means that the.
benefits from these inspections are unaffected by the
presence or absence of the other inspections discussed below.
Catalyst - Inadvertent removal of catalysts does not occur.
Therefore, if the public is well informed that failure of the
catalyst check will require catalyst replacement, one. can
expect that there will be few new instances of catalyst
removal. Such public awareness should be nearly automatic in
an annual program. The exception, if any, will be a small
group of owners convinced beyond persuasion that their
catalysts should be removed. Such owners may reinstall the
catalyst each year or two in order to pass the inspection, or
may remove the active material from the catalyst container
making visual detection at the disabled catalyst nearly
impossible.
In addition to some catalysts being successfully removed or
disabled in a way that escapes detection, inadvertent
inspector errors may result in failure to replace all
catalysts missing at the start of the program. Not all
1975-79 cars and light-duty trucks were originally equipped
with catalysts. When a 1975-79 vehicle is presented for
inspection, it will be up to the inspector to determine
whether a catalyst is required or not. This decision may be
more error-prone than the determination of whether a catalyst
is present on the vehicle or not. Some inspectors may give
vehicle owners the benefit of the doubt and decide that the
vehicles does not require a catalyst as long as there is no
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43
readily available evidence, such as the emission co.ntrol
sticker, to convince him otherwise. Materials are available
which list the emission control equipment required on
vehicles.[6] If this material is available there will be
fewer such cases. Inspectors will also be more willing to
fail vehicles in questionable cases if both they and the
vehicle owners are aware that an offical second opinion is
available through the referee system.
It is true that in the 1982 tampering survey, no catalyst
removals were observed at the Portland .site. Since the
Portland program has been in operation since the advent, of.
catalyst "equipped cars, this indicates that the catalyst
inspection can effectively prevent vehicle owners from
removing catalysts, except perhaps for a few owners who
reinstall the catalyst each time to pass inspection or remove
the active material. This deterrence can be achieved with a
program which provides a reasonably high probability of
detection. The Portland observation is not inconsistent with
an assumption that inspections will not be quite 100%
accurate.
For the reasons discussed above, an inspection for- removal of
the catalyst will be assumed to be 90% effective in detecting
and forcing replacement of catalystson 1975-79 model year
passenger cars and 1975-79 light-duty trucks less than"5000
ibs. These are the groups for which some vehicles were not
equipped with catalysts. The 90% value allows for some
inspection errors and some concealed tampering and
retampering by owners. The inspection is assumed to be 95%
effective for all ether raodei years, allowing for a small
number of adamant owners. A biennial inspection program is
assumed to be as effective as an annual inspection.
Misfueiing, if it resumes after catalyst replacement, will
negate nearly ail the benefits associated with replacing the
catalyst. Some owners who have removed their catalysts have
probably done so thinking it would harm their vehicles to
misfuei while the catalyst was still present. It is assumed,
however, that essentially all vehicle owners who remove their
catalysts and also raisfuei, will misfuei even if prevented
from removing the catalyst by the program. This assumption
is supported by the fact that in the latest tampering survey
69% of the habitually misfuelsd passenger vehicles had not
removed the catalyst, Indicating that £cst misfuelers believe
it is safe to nis-fuel even if the catalyst is left on the
vehicle. Given the real or perceived incentives for
uiisfueilng, owners who were forced to replace catalysts will
probably come to believe the same, or will find a way to
defeat the catalyut check entirely. Benefits of a catalyst
check alone are calculated on the ocrtion of vehicles with
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49
catalyst removed which have not also been misfueled.
Misfueling checks are discussed below.
In addition some vehicles with the catalyst removed also have
disabled air pumps. The air pump system is often critical to
efficient catalytic action and therefore a catalyst check
alone is assumed to produce no benefits from vehicles with
disabled air, pumps. Combining the, catalyst check with an air
pump inspection ;will recover some of these lost benefits.
This combination is discussed below.
Air Pumps - With air pumps, removal or failure of the drive
belt is the most likely disablement. Since this disablement
is relatively easy and replacement is inexpensive, some
deliberate tampering with the air pump can be expected to
occur even with a vigorous anti-tampering program. Many
vehicle owners would be willing to risk detection and the
subsequent penalty/ replacement of the belt, in order to
achieve perceived benefits in fuel economy and performance.
Some ve'hicle owners may even replace and remove their air
pump belt before and after their periodic inspection to avoid
detection by the program. Also, air pump belts may
eventually break if they are not periodically replaced. This
may account for some portion of observed disablements.
In Portland the rate of air pump disablement is about
two-thirds less than in the other. 1/M sites. However/ since
the survey was performed at-an. I/M. station where a, tampering
check is. performed/ some vehicle owners nay have reconnected
the air. pump for. the inspection with- the intention of"
disabling it immediately" after meeting the legal
requirements. It may be speculated, that, the number of
vehicle owners who do this is only a small portion of the
fleet. However/ we will assume that an annual inspection
program will have a 70% effectiveness and a biennial program
will have a 60% effectiveness. This applies to both existing
and subsequent tampering.
Benefits of an air pump check alone are calculated en the
portion of vehicles with the air pump removed, whi-ch do not
suffer from removed catalysts or misfueiing since these other
problems would eliminate most of the benefit from repairs to
the air pump system. Benefits of combining the air pump
check with other inspections are discussed below.
Fuel Inlet Rest riot or - It is assumed that any fuel inlet
restrictor which allows entry of a legal size leaded fuel
nozsle is an indication of habitual misfueiing and therefore
the catalyst has been rendered inoperative. Therefore, if
the fuel inlet restrictcr has been enlarged the vehicle 'owner
must be required to replace the catalyst. In addition, the
&
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50
vehicle owner v/ill also have to repair or replace the
restrictor so that a leaded fuel nozzle will not fit. Since
the owner of a vehicle with a tampered restrictor could avoid
the catalyst replacement cost by restoring the restrictor
after failing once and then reporting for another inspection
as though it were the first inspection, the inspection
program should have some method of preventing this by
punching the vehicle registration at first inspection or
keeping a computerized list of tampered vehicles alreaded
inspected once.
The benefits also assume that - all instances of fuel inlet
tampering which have already occurred or will occur in the
future can be detected. The important issue insofar as
benefits are concerned is what impact fuel inlet inspections
will have on the overall misfueling rate, since continued
misfueling after repair of the inlet and replacement of the
catalyst negates the benefit of the repair.
Since catalyst removal is a more flagrant form of tampering
and since there is no point in terms of excess emissions in
preventing misfueling among vehicle owners who have removed
their vehicle's catalyst, it is strongly recommended that the
fuel inlet check be combined with a catalyst presence check.
However/ if only the fuel inlet check is performed, it is
assumed that of the vehicle owners who would have removed the
catalyst and misfueled after the program start date without
the program, half of the vehicle owners who do not misfuel as
a result of the fuel inlet check will also refrain from
removing the catalyst. It is assumed that these vehicle
owners would have removed the catalyst only because they
wished to misfuel. This will provide some additional benefit
since removal of the catalyst would otherwise negate any
benefit from the fuel inlet restrictor check.
A possible way to estimate the effect of the fuel inlet
restrictor check is to assume that misfuelers who do so
without having tampered with the fuel inlet restrictor will
continue to misfuel even if the inspection is begun. In
addition, it is safe to assume that among vehicle owners who
tamper with the fuel inlet restrictcr, some of them will
continue to misfuel using other means even if. they are
prevented from enlarging the fuel inlet restrictor on their
vehicles as a result of the inspection. In the 1982 survey,
66% of the passenger cars which are defined as being
habitually misfueled, had tampered fuel inlet restrictors.
If it is assumed that a check of the fuel inlet restrictor
will deter a certain percentage of these vehicle owners from
misfueling, then the net effectiveness of the fuel inlet
restrictor check can be calculated easily.
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51
It can be effectively argued that a check of the fuel inlet
restrictor is no more than an inconvenience to motorists who
wish to misfuel since other methods to funnel leaded fuel
through the fuel inlet restrictor are readily available. The
check will be most effective in detering only those vehicle
owners who are not highly motivated to misfuel to begin.
with. The data from the Portland site in the 1382 survey
does not provide a good estimate of how effective the fuel
inlet check would be in other areas. Given the inconclusive
evidence", limiting the effectiveness to one half the
potential benefits from those vehicles already misfueled with
tampered fuel inlet restrictors appears reasonable. Although
the choice of half the percentage appears arbitrary, it
reflects the judgment of EPA that a large percentage of these
practicing misfuelers will not be deterred by such an
inspection alone. One contributor to lowered effectiveness
is the likelihood that some owners of misfueled vehicles will
repair their inlet restrictors once they know the inspection
requirement will begin soon, thereby depriving the program of
the benefit, of a catalyst replacement. Therefore, EPA
assumes 33% of all previous misfuelers (50% of misfuelers who
enlarge the fuel inlet restrictor) will stop misfueling with
the fuel inlet restrictor check. EPA assumes that the
deterrence value of the fuel inlet check will be greater for
vehicle owners who have not yet misfueled than for owners who
have misfueled in the past, and has selected a 70%
effectiveness for subsequent misfueling via inlet tampering.
The net. effectiveness for subsequent misfueling is therefore
46% after allowing for owners who misfuel by other means.
The rate of misfueling in Portland is about 63% less than the
average for the other I/M areas. (The comparison with other
individual I/M areas ranges from. 35% to 74%, indicating a
wide variation among other I/M areas.) However, Portland not
only inspects for fuel inlet restrictor tampering, but also
by law does not allow self-service gas stations. In
addition, Portland's I/M program has very stringent idle test
standards and has been in effect since before the
introduction of catalyst vehicles so that misfueling behavior
may be quite different than in other areas. Conversation
with. Oregon inspection officials indicate that there is a
general feeling that it is not the inlet restrictor check
alone which deters misfueling in their area, but a.
combination of regional behavior, the idle test part of the
I/M program, and the lack of self-service gasoline stations.
These other factors do not allow a direct comparison of the
misfueling rates observed in Portland to other I/M areas to
estimate the effect on the misfueling rate of Portland's
check of the fuel inlet restrictor. Therefore, the Portland
data do not contradict the assumptions stated above.
-------
52.
Plumbtesino - As was pointed out in Section 2.0 EPA has been
using a lead-sensitive chemical coated paper/ whose trade
name is Plumfatesrao, to detect tell-tale lead depcsits in the
tailpipes of vehicles in the latest tampering surveys as an
indication of misfueling, [ 2] This test is a powerful tool in
detecting previous use of leaded fuel when there is no leaded
fuel in the tank or damage to the fuel inlet restrictor. Its
primary fault lies in its inability to determine the extent
of catalyst damage due to misfueling. A single tankful of
leaded fuel used during an emergency - or bought from an
unscrupulous gasoline dealer as unleaded may cause a
Plumbtesmo test failure months later even though unleaded
fuel has been used at all other fuelings. If only one-half
of one percent of all unleaded fuel- sold in an area were
contaminated with lead additives, as many as 500 of every
100,000 vehicles might fail the Plumbtesmo test every year
even if deliberate misfueling ceased altogether. If some
simple, reliable test to determine the extent of damage to
the catalyst by lead deposits can be developed, then such a
test cojld be used to allow vehicle owners whose vehicles
fail the Plumbtesmo test to prove that their catalyst was
still active and. did not need to be replaced. without such a
test, the Plumbtesmo test will allow persons who deliberately
misfuel to actively seek to avoid detection (by, for example,
cleaning or replacing tailpipes) while persons who do not
deliberately inisfuei but accidentally buy leaded gas will
likely be caught by the Plumbtesmo test. Although EPA is
currently assessing the feasibility of such a catalyst
diagnostic test, no test is as yet available. Inequities
will be reduced by an aggressive program of sampling fuel
from retail gas stations. Since the required catalyst
replacement cost would be expensive, some vehicle owner
dissatisfaction with the test might result.
A less serious, but equally complicating factor is the fact
that in SPA tests some vehicles which have obviously been
inisfueled pass the Plumbtesmc test. As yet no full
explanation has been determined for those cases.* As a
result, some grossly misfueled vehicles may escape detection
by a Plumbtesmo test.
*0ne possible explanation is that the unstable lead-detecting
compounds in -he test paper became inadvertently deactivated
or a defective lot was used during testing. An inspection
program forwarned of these problems could easily avoid using
inactive test paper.
-------
53
The main attractiveness of the Plumbtesmo test is its
potential effectiveness in detering misfueling. With a
Plumbtesmo inspection, vehicle owners could never be sure
that they could avoid detection if they misfuel. Some
extreme measures, such as replacing the tailpipe before each
inspection, might work, but would make the act of misfueling
much less attractive. A program, which would require
replacement of the catalyst whenever a vehicle fails the
Plumbtesmo test is assumed to cause 80% of misfueling which
would otherwise have occurred to stop. As with the fuel
inlet check, half of the misfuelers who stop misfueling would
also refrain from removing the catalyst. Since the tailpipe
would be contaminated with lead', replacement of the tailpipe
or some other action as well as replacement of the catalyst
would be required to avoid a Plumbtesmo test failure at the
next inspection. " - ..
In order to increase the emissions benefit from vehicles
which had been habitually misfueled before the start of the
program, the Plumbtesmo test can be used in combination with
a check of the fuel inlet restrictor. Some vehicles may have
been habitually misfueled in the past, but the previous owner
may have reverted to the .use of unleaded fuel. If the
exhaust tailpipe had been replaced, the Plurabtesmo test would
be unable to detect the vehicle, even though the vehicle's
catalyst had been deactivated by 'the previous habitual
misfueling. A check of the fuel inlet restrictor would help
identify much of this past misfueling.. In the EPA survey
only about half of the passenger vehicles identified as
habitual misfuelers are detected by the Plumbtesmo test.
Combining the Plumbtesmo test with a fuel inlet check
identifies about 75% of the habitual misfuelers. Therefore,
it will be assumed in this analysis that a Plumbtesmo test
alone will only detect 50% of the existing habitual
misfueling damage to catalysts. A Plumbtesmo test combined
with a fuel inlet restrictor check will be assumed to detect
75% of the existing habitual misfueling damage.
Although a check of the fuel inlet would not be a necessity
for vehicles sold after the program began, such a check would
further complicate efforts by some vehicle owners to continue
to misfuel- and avoid detection. For this reason and for
equity concerns a check of the fuel inlet restrictor should
always be performed in conjunction with a Plumbtesmo test on
vehicles sold after the program begins whenever a fuel inlet
check is combined with the Plumbtesmo test for the older
veh-icles. This combination should increase the deterrence
value of the inspection. An 85% deterrence effectiveness
will be assumed for the combined inspection.
-------
54
Because a Plumbtesmo test may fail a vehicle whose only use
of leaded fuel was inadvertent due to contamination or
mislabeling at the pump, it is important that these
occurrences be minimized. This can be done establishing the
program of fuel pump inspections described at the beginning
of Section 5.0.
Catalyst and Misfueling - If the catalyst presence check is
combined with either the fuel inlet restrictor check or the
Plumbtesmo test, additional benefits from vehicles vith
removed catalysts can be obtained. With either the
Plumbtesmo test or fuel inlet check alone it is assumed that
only half of vehicle owners who would have removed their
catalyst and misfueled after the program begins would be
deterred from removing their catalysts. If 'either of these
programs are combined with the catalyst check, more benefits
will result from these vehicles since most catalyst removal
will be deterred by ,the catalyst inspection.
Catalyst and Air Pump - Combining the catalyst and air pump
inspection allows vehicles with disabled air pumps and
removed catalysts, but which have not been misfueled, to
obtain the higher catalyst replacement benefits in addition
to the benefits of catalyst and air pump inspections
calculated separately above. The percentage of vehicles
which will receive both repairs depends on the effectiveness
of the two inspections which in turn depends on whether the
program is annual or biennial.
Combined Inspection - Obviously, if all four inspections (air
pump, catalyst, 'fuel inlet restrictor and Plumbtesmo test)
are performed benefits must be calculated correctly for
overlapping cases. For overlap vehicles, the assumption used
is that the effectiveness of a combined inspection program in
detecting, repairing, and deterring all of the misfuelers,
catalyst removed, and air pump tampering present on one
vehicle is equal to the lowest of the individual
effectiveness. Catalyst removed vehicles, if detected, will
obtain full benefits from catalyst replacement once all
tampering is corrected. Misfueled vehicles will also obtain
benefits from catalyst replacement. The remaining vehicles
had tampered air pumps only and will therefore receive air
pump repair benefits. Benefits for PCV and evaporative
checks are additive to all other benefits.
Caution - A potential source of further loss of effectiveness
in any inspection is deliberate cheating by inspectors.
Since some repairs such as catalyst replacements may cost
vehicle owners hundreds of dollars, inspectors may
deliberately overlook tampering or fail to verify that a
-------
55
vehicle does not require an air pump or catalyst. Obviously,
if such behavior were allowed to persist, the effectiveness
of the program would be greatly reduced. The design
requirements discussed earlier (e.g., training, audits,
undercover enforcement actions, etc.) are intended to prevent
deliberate cheating. Centralized programs, by their design,
should be able to prevent cheating more cheaply than
decentralized programs. The credits calculated in this
report assume that there will be no significant amount of
cheating in the inspections. EPA will evaluate
anti-tampering programs for their ability to prevent cheating
before agreeing to allow credits for the program. If EPA
review of the program design suggested that significant
cheating could still occur, no credits would be given.
5.1.2 Results; Benefits for I/M Programs
Table 15 presents the benefits of inclusion of a tampering
inspection with an annual I/M program. There are separate
results for pre-1980, 1280 through 1982 and 1984 and later
vehicles so that programs which exempt pre-1980 or pre-1984
vehicles can be estimated. Table 16 presents a biennial
version for each of the benefits in Table 15.
-------
56
Table 15
Benefit of Annual Tampering Inspections
in I/M Areas
(January 1, 1988)
Per Vehicle Reduction
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
ScFuel Inlet
Air Pump &
Catalyst
Air Pump &
Fuel Inlet
Air Pump &
Plumbtesmc
Fuel Inlet
& Catalyst
Plumbtesmc
& Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+-
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984-+-
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
in
Em
issions (
mg/rn
i)
Light-Duty Trucks
Passenger
7
4
1
8
6
2
15
16
9
25
27
15
32
33
18
16
11
3
21
22
11
34
33
11
31
28
13
48
42
20
41
34
15
HC
.43
.58
.17
.51
.59
.31
.76
.58
.40
.42
.45
.67
.89
.25
.65
.74
.75
.69
.44
.25
.19
.78
.97
.19
.66
.11
.19
.34
.09
.55
.59
.81
.32
Car
(6000 Ibs)
CO
173
142
36
84
67
23
111
123
71
180
204
118
231
245
140
265
215
62
227
274
112
368
362
164
269
240
110
445
354
169
464
402
155
.54
.89
.66
.29
.16
.99
.61
.29
.13
.83
.89
.95
.45
.90
.46
.69
.98
.77
.85
.53
.61
.25
.57
.03
.10
.76
.55
.08
.08
.70
.59
.50
.56
7
2
1
~
10
11
9
20
24
15
33
28
21
42
51
14
14
15
12
25
28
25
40
45
22
43
49
38
62
71
34
53
59
HC
.88
.11
.78
.77
.68
.69
.91
.51
.14
.75
.23
.53
.10
.51
.14
.70
.64
.50
.81
.30
.91
.94
.29
.98
.84
.14
.20
.85
.83
.22
.95
.06
.66
CO
183
49
41
57
105
115
70
148
171
112
242
276
148
305
361
251
173
177
118
219
236
313
330
360
198
372
420
424
535
599
421
494
540
.88
.27
.61
.11
.73
.71
.24
.76
.97
.30
.44
.02
.51
.76
.49
.45
.34
.38
.99
.17
.45
.53
.37
.56
.34
.82
.08
.06
.50
.65
.32
.00
.93
(6000-8500 Ibs)
HC
0.21
1.23
1..94
0.71
5.26
17.12
1.28
10.12
35.06
2.05
16.40
55.53
2.71
20.97
75.11
1.05
7.40
22.03
1.65
12.68
41.21
2.56
20 .08
65.57
2.87
21.26
72.11
4.12
30.97
103.76
3.61
26.34
86.70
CO
4.89
28.78
45 .19
7.05
52.06
169.54
9.14
73.42
247.42
14.70
119.69
393.91
19.16
150.87
526.20
13.23
89.87
244.13
15.25
112.65
324.34
21.87
167.56
499.52
24 .85
183.70
614.30
35.26
' 263 .94
371.44
34 .62
247.91
774 .72
(continued!
-------
57
Table 15 (continued)
Inspection
Program..
Plumbtesmo
&. Catalyst
& Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Affected
Model
Years
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983'
1984+
Plumbtesmo Pre-1980
s Fuel In- 1980-1983
let & Air 1984+
Pump
Plumbstesmo
& Fuel In-
let &
Catalyst &
Air Pump
PCV*
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Per
in
Vehicle Reduction
Emissions (ing/mi)
Light-Duty
Passenger
57
49
23
60
49
23
39
39
20
68
57
26
9
8
3
3
3
1
81
69
30
HC
.00
.96
.19
.14
.99
.71
.50
.79
.92
.81.
.86
.35
.56
.23
.49
.18
.59
.09
.55
.67
.92
Car
CO
588.31
525.47
218.75
538.62
416.37
193.10
354.32
403.83
185.69
681.84
587.75
242.16
0.0
0.0
0.0
0.0
0.0
0.0
681
587
242
.84
.75
.16
(6
47
77
87
48
78
91
25
49
58
57
93
108
16
13
14
7.
12.
14.
82
119
138
000
HC
.80
.88
.73
.82
.81
.83
t
,41
.68
..69
.77
.86
34
.82.
.20
.96
91
21
81
.50
.28
.11
Ibs)
Trucks
(6000-8500 Ibs)
CO
529.94
702.54
773.95
506.02
665.15
754.27
205.79
394.77
446.99
611.90
832.19
938.57
0.0
0.0
0.0
0.0
0.0
0.0
611.
832.
938.
90
19
57
HC
5.23
38.58
127.46
5.33
38.83
135.81
3.22
24.70
85.27
6.44
46.43
159.50
4.86
6.49
22.33
0.61
4.69
17.21
11
57
199
.92
.62
.04
CO
48.37
358.72
1112.23
45.12
327.68
1127.18
26.39
199.27
633.01
58.23
414.46
1367.98
0.0
0.0
0.0
0.0
0.0
0.0
58
414
1367
.23
.46
.98
'Evaporative*Pre-L980
Canister 1980-1983
1984+
All Items** Pre-1980
1980-1983
1984 +
All Items** All Yrs. 182.15 1511.75 339'.89 2382.67 268.57 1840.66
(in gm/mi) 0.18 1.51 0.34 2.38 0.27 1.84
Percent***
5.2%
3.9%
1.0%
0.6%
0.5%
0.3%
*PCV or evaporative canister benefits can be added directly to any
of the above programs.
**Plumfatesmo, fuel inlet, catalyst, air pump, PCV and evaporative
canister checks.
***Percent of composite mobile source emissions using KOBILE2
estimates of passenger car and light-duty truck vehicle miles
traveled.
-------
58
Benefit of
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel
Only
Inlet
Plumbtesmo
Only
Plumbtesmo
&Fuel Inlet
Air Pump
Catalyst
Air Pump &
Fuel Inlet
Air Pump &
Plumbtesmo
Fuel Inlet
& Catalyst
Plumbtesmo
& Catalyst
Fuel Inlet
*. Catalyst
& Air Pump
Table 16
Biennial Tampering Inspections
in I/M Areas
(January 1, 1988)
Per Vehicle Reduction
in Emissions
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+-
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
! '
Passenger
EC
6.37
3.92
1.01
8.51
6.59
2.31
15 .76
16.58
9.40
25.42
27.45
15.67
32.89
3J.25
28.65
15.57
11.01
3.49
20.78
21.60
11.03
33.49
33.10
17.64
31.66
28.11
13.19
47.94
42.09
20.55
40.41
34.08
15.13
Car
(
CO
148
122
31
84
67
23
111
123
71
180
204
118
231
245
140
239
194
57
212
254
107
341
340
157
269
240
110
435
354
169
438
381
150
.74
.48
.42
.29
.16
.99
.61
.29
.13
.83
.89
.95
.45
.90
.46
.78
.72
.23
.30
.12
.38
.91
.63
.93
.10
.76
.55
.83
.08
.70
.67
.24
.01
6
1
1
5
10
11
9
20
24
15
33
38
21
42
51
13
14
14
12
25
28
24
39
45
22
43
49
37
62
71
33
52
59
6000
EC
.75
.81
.53
.77
.68
.69
.91
.51
.14
.75
.23
.53
.10
.51
.14
.43
.08
.95
.57
.00
.65
.57
.53
. 14
.84
.14
.20
.96
.83
.22
.68
. 49
.12
Ligh
Ibs)
(mg/mi)
t-Du
tv T
(60
CO
157
42
35
57
105
115
70
148
171
112
242
276
148
305
361
223
163
168
113
212
230
285
320
350
198
372
420
403
535
599
393
484
532
.61
.24
.67
.11
.73
.71
.24
.76
.97
.30
.44
.02
.51
.76
.49
.68
.68
.57
.33
.13
.51
.62
.26
.70
.34
.82
.08
.44
.50
.65
.56
.34
.12
0
I
1
0
5
17
1
10
35
2
16
55
2
20
75
1
7
21
1
12
40
2
19
64
2
21
72
4
30
103
3
26
85
rucks
00-8500 Ibs)
HC
.18
.06
.66
.71
.26
.12
.28
.12
.06
.05
.40
.53
.71
.97
.11
.00
.10
.33
.62
.50
.93
.50
.67
.42
.87
.26
.11
.12
.97
.76
.56
.03
.99
CO
4
24
38
7
52
169
9
73
247
14
119
393
19
150
526-
12
84
Z33
14
108
317
20
161
487
24
183
614
35
263
871
33
242
764
.19
.67
.74
.05
.06
.54
.14
.42
.42
.70
.69
.91
.16
.87
.20
.35
.47
.47
.55
.53
.89
.97
.93
.17
.85
.70
,30
.26
.94
.44
.74
.51
.07
-------
59
Table 16 (continued)
Per Vehicle Reduction
in Emiss
Inspection
Program
Plumbtesmo
& Catalyst
& Air Pump
Plumbtesmo
&. Fuel in-
let's ..
Catalyst
Plumbtesmo
& Fuel In-
let & Air
Pump
Plumbstesmo
& Fuel In-
let &
Catalyst
& Air Pump
PCV*
Evaporative
Canister
All Items**
All Items**
Percent***
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980i
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
*Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
All Yrs.
(in gm/ni
Passenger
EC
55.37
48.84
22.82
59.75
49,99
23.71
38.60
38.92
20.63
67.18
56.74
25.97
6.46
5.55
2.35
2.12
2.39
0.72
75.75
64.68
29.05
169.48
0.17
4.8%
Car
ions
Ligh
(mg/mi)
t-Duty Trucks
(6000 Ibs)
CO
558
500
211
529
416
193
337
381
179
652
536
235
0
0
0
0
0
0
652
563
235
1450
1
3
.60
.99
.75
.37
.37
.10
.23
.89
.59
.13
.27
.15
.0
.0
.0
.0
.0
.0
.13
.27
.15
.55
.45
.7%
45
75
85
48
78
91
24
48
57
55
91
105
11
8
10
5
8
9
72
108
125
306
0
0
HC
.63
.73
.37
.56
.81
.83
.66
.92
.85
.61
.71
.98
.35
.91
.10
.28
.14
.87
.24
.77
.95
.95
.31
.9%
CO
494
678
749
500
665
764
198
384
437
576
808
913
0
0
0
0'
0
0
576
808
913
2298
2
0
.20
.68
.05
.05
.15
.27
.50
.65
.14
.16
.33
.67
.0
.0
.0
.0
.0
.0
.16
.33
.67
.16
.30
.6%
(6000-8500 Ibs)
HC
5.08
37.49
124.07
5.33
38.83
135.81
3.16
24.30
84.11
6.28
45.35
156.12
3.28
4.38
15.07
.. 0.41
3.13
11.47
9.97
52.86
182.66
245.49
0.25
0.4%
CO
46
338
1077
45
327
1127
25
193
620
56
402
1333
0
0
0
0
0
0
56
402
1333
1792
1
0
.50
.32
.83
.12
,68
.18
.49
.64
.65
.36
.06
.58
.0
.0
.0
.0
.0
.0
.36
.06
.58
.00
.79
.3%
*PCV or evaporative canister benefits can be added directly to any
of the above programs.
**Plumbtesmo, fuel inlet, catalyst, air pump, PCV and evaporative
canister checks.
***Percent of composite mobile source emissions using MOBILE2
estimates of passenger car and light-duty truck vehicle miles
traveled.
-------
60
5.1.3 Program Costs
This subse.ction states assumptions necessary to calculate the
cost of a tampering inspection program when added to an
existing I/M program. Costs are calculated over the
four-year period 1984-1987, so that cost-effectiveness can be
calculated and presented in the following subsection.
Repairs - The obvious cost qf anti-tampering and
anti-misfueling programs is the cost to vehicle owners for
repairs of disablements, whether they were deliberate or
inadvertent. In terms of all cars being inspected, the per
vehicle cost for repairs will be relatively small, since
usually only some small - fraction of vehicles will require
repairs. Also, if the program continues to operate beyond
December 31, 1987, the cost-effectiveness of the repairs will
improve until essentially the only costs incurred by the
program will be the cost of inspection. Section 3.0
discusses the repair costs which we have assumed for this
analysis.
Using the rate of tampering at the start of the program, the
number of vehicles which require repairs at the start of the
program can be estimated. By assuming an average repair
cost, the initial year repair cost can be estimated.
After the program begins, some tampering will continue to
occur and subsequently be detected and repaired. The number
of vehicles tampered after the program begins will depend on
the effectiveness of the program in detering tampering. The
effectiveness will depend on the emission control component.
For air pump, catalyst and fuel inlet restrictor tampering it
is assumed that only those vehicles identified in the first
year of the program will require repairs. Vehicles not
identified are assumed to continue to avoid detection in
subsequent years. Also, no significant amount of new
tampering is expected to be discovered in subsequent years
since vehicle owners will be aware of the program and its
penalties. PCV and evaporative canister disablements occur
at a high rate even in an inspection program which checks for
such disablements. In these cases all disablements are
assumed to be repaired in the first year and in each
subsequent year repairs will be done on all disablements
which reappear.
Inspections - In addition to the cost vehicle owners must pay
in repairs, a tampering inspection program will incur
additional expenses from the added tampering inspections at
individual inspection stations and additional administrative
costs related to adding the tampering inspection to the I/M
-------
61
requirements. A rough estimate of the additional costs can
be made by estimating the increase in personnel time, both
inspector and administrative, necessary to include the
tampering check.
In' decentralised programs, only the additional time an
inspector will need to perform the tampering check should be
attributed to the anti-tarapering program. As with
centralized programs, administrative costs can probably be
estimated by the need to hire additional personnel.
Tt is expected that most of the duties required by the
addition of a tampering inspection can be integrated into the
operation of the I/M program without any substantial increase
in program costs. Although this cost will likely vary
substantially from program to program depending on many
factors, we have assumed an overall increase in program
administrative and inspection costs to be 34 cents in
centralized and $1.00 in decentralized inspection programs
per inspection as an example. This added cost would include
not only additional costs to perform the inspections, but
also include additional administrative duties to oversee the
additional program elements.
The cost has been estimated by assuming that a single
inspector in a centralized program could complete the
necessary inspection and additional paperwork for a check of
all the components in about one minute. If the inspector is
a mechanic costing £20 per hour including fringe benefits and
overhead, this works out to be about 34 cents per
inspection. In a decentralized program, the inspector will
be less specialized and will likely take longer to
satisfactorily complete the inspection. We have assumed the
decentralized program inspector will take three minutes to
complete the inspection, which at $20 per hour, will be $1.00
per inspection. These estimates are for an inspection of all
items discussed in this report. An inspection of fewer items
would be shorter and therefore cheaper.
5.1.4 Cost-Effectiveness
Tables 17 and 18 present cost-effectiveness values calculated
for the benefits presented in Tables 15 and 16 in Section
5.1.2. These cost-effectiveness values assume the following
average repair costs:
- $20 per disabled air pump
- $200 per removed catalyst
-------
62
- $10 per disabled PCV system
- $10 per disabled evaporative canister
- $150 per rnisfueled catalyst
- $30 per tampered fuel inlet restrictor
These repair costs are discussed in Section 3.0. i As
mentioned there, the costs of replacing removed or misfueled
catalysts may be less if aftermarket catalysts are
introduced. The additional inspection and administrative
costs are assumed to be 34 cents for centralized and $1.00
for decentralized programs per inspected vehicle per
inspection. Local estimates will likely vary substantially
from this assumption depending on program type and local
conditions. The inspection cost has been distributed equally
between all of the inspected emission control components and
divided equally between the two pollutants when both HC and
CO emissions are affected. Emission benefits have been
calculated for each year of the programs beginning on January
1, 1984 through the evaluation data of January I/ 1988. The
total inspection, administrative/ and repair costs are summed
for those years and divided by the sum total emission
reductions and converted to cost per ton. The choice of
these four years is somewhat arbitrary, and tends to raise
the calculated cost per ton since these years included all
the repair costs for tampering which occurred before the
program started. The cost per ton would be less if a longer
period is used for the calculation.
-------
65
5.2 Periodic Inspection Programs
Non-I/M periodic inspection programs offer another
opportunity to address the tampering issue. A tampering
program can be added to a periodic safety inspection, or an
entirely new inspection requirement can be established.
Costs will obviously be higher in the latter approach...
Section 2.0 discussed tampering rates in non-I/M areas. The
rates discussed in that Section are the rates used for all
calculations In this section, except that overlap among
tampering types is accounted for. The individual vehicle
benefits and costs of repairs of tampering and mis-fueling are
those discussed in Section 3.0. The methodology explained in
Section 4.0 was used to calculate excess emissions due to
tampering and misfueling and program costs. Only annual and
biennial programs are considered in this section.
5 . 2 .. 1 Program Effectiveness
For periodic inspection programs as in I/M programs, it is
assumed that the program will require repair or replacement
of the disabled emission control components once they are
discovered followed by reinspection of the vehicle and/or the
repair receipts to verify compliance. In addition, to claim
the benefits estimated in this section the inspection program
would have the same requirements as anti-tampering and
anti-misfueling programs in I/M programs described at the
beginning of Section 5.0. .All of the effectiveness
assumptions used for I/M programs will be assumed to apply to
periodic inspections which are not part of I/M programs. The
reader should refer to Section 5.1.1 for the discussion of
inspection effectiveness.
As pointed out in Section 2.0, areas without I/M programs
tend to have higher tampering and misfueling rates than I/M
areas. In this section, all benefits are calculated using
tampering and misfueling rates predicted for non-I/M areas.
5.2.2 Results: Benefits for Non-I/M Periodic Inspection
Programs
Table 19 presents the benefits of an annual tampering
inspection program. There are separate results for pre-1980,
1980 through 1983 and 1984 and later vehicles so that
programs which exempt pre-1980 or pre-1984 vehicles can be
estimated. Table 20 presents a biennial version for each of
the benefits in Table 19.
-------
66
Benefit of
Table 19
Annual Tampering Inspections
in Non-I/M Areas
(January 1, 1988)
Per Vehicle Reduction
in Emiss
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumb tesmo
&Fuel Inlet
Air Pump &
Catalyst
Air Pump &
Fuel Inlet
Air Pump s
Plumbtesmo
Fuel Inlet
s Catalyst
Affected
ions (mg/mi)
Light
Model Passenger Car
Years
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
HC
17.58
10.75
2.65
26.65
19.56"
4.91
41.14
41.73
16.89
67.11.
70.40
29.38
84.43
81.23
31.22
46.72
3.2.04
8.00
54.88
55.30
20.68
89.71
85.97
33.82
90.63
75.42
24.94
CO
410
335
82
263
199
51
296
318
129
486
538
225
604
616
239
698
552
138
574
675
221
933
911
322
786
661
213
.46
.46
.82
.83
.21
.04
.78
.03
.61
.49
.16
.42
.65
.01
.50
.91
.29
.37
.11
.69
.37
.95
.62
.48
.85
.04
.27
-Duty Trucks
(6000 Ibs)
22
7
10
24
47
59
26
53
57
41
88
93
55
108
118
51
62
79
34
68
75
70
108
117
80
155
186
HC
.44
.08
.55
.22
.53
.10
.16
.62
.37
.98
.03
.10
.03
.97
.70
.09
,85
.90
.56
.25
.65
.75
.76
.88
.88
.88
.39
CO
523
165
246
239
470
585
188
398
420
304
658
686
393
803
861
807
717
932
332
625
728
877
934
1045
730
1411
1697
.81
.33
.28
.78
.58
.18
.86
.93
.311
.91
.93
.29
.63
.29
.45
.47
.50
.92
.39
.87
.33
.70
.77
. 11
.61
.48
.66
(6000-8500 Ibs)
HC
0.64
4.15
14.45
3.04
23.42
88.77
3.37
26.45
80.93
5.45
43.44
130.21
7.02
53.74
169.54
4.23
31.63
118.61
4.46
34.33
105.93
6.91
54.32
164.36
10.20
76.84
276.05
CO
14
96
337
30
231
878
24
196
586
39
325
949
50
396
1216
50
368
1368
42
324
1006
61
476
1439
92
695
2518
.89
.77
.36
.06
.90
.92
.56
.89
.27
.23
.29
.14
.68
.30
.97
.45
.87
.66
.99
.10
.51
.32
.65
.78
.12
.74
.12
Plumbtesmo
& Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Pre-1980 136.46
1980-1983 113.33
1984+ 39.74
Pre-1980 115.51
1980-1983 92.01
1984+ 29.44
1261.48
975.28
333.18
130.80 1418.49
221.32 1978.59
260.68 2345.54
14.36 128.19
109.11 975.48
383.26 3454.61
1262.73 119.49 1407.47
1049.38 193.77 1368.61
312.51 234.08 2296 .92
12.87
?6 .17
126.33
936.35
345 .59 3379 .46
(continued!
-------
67
Table 19 (continued)
Per Vehicle Reduction
Inspection
Program
Plumbtesmo
& Catalyst
"& Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Plumbtesmo
& Fuel In-
let .& Air .
Pump
Plumfastesmo
& Fuel In-
let &
Catalyst
& Air Pump
PCV*
Evaporative
Canister
All Items**
All Items**"
(
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
*Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
All Yrs.
in gm/mi)
in
Emissions (mg/mi)
Light-Duty Trucks
Passenger Car
HC
158.88
132.71
. 44,99
166.70.
129.20
41.92
100.53
96.89
35.68
189.12
148,58
47,16
9.56
8.23
3 ,49
3.18
3.59
1.09
201.87
161.94
52.23
414.00
0 .4.1
CO
1618
1387
438
1507
1104
350
899
990
336
1864
1516
456
0
0
0
0
0
0
1864
1516
456
3837
3
(6000
HC
.85
.45
.63
.55
.02
.82
.40
.36
.89
.91
.19
,26
.0
.0
0
.0
,0
.0
.91
.19
.26
.36
.84
163.
279.
333.
164.
275.
331.
66.
130.
143.
196.
333.
404.
16.
13..
14.
7,
12,
14.
221.
358.
434.
1015
1.
35
.30
81
14
55
83
51
07
83
69
54
96
82
20
96
91
21
81
43
95
73
.11
02
Ibs)
CO
1794
2623
3183.
1708
2452
2971
561
1082
1223
2084
3097
3809
0
0
0
0
0
0
2084
3097
3809
8990
8
(6000-8500 Ibs)
.54
.33
,17
.13
.67
.67
.05
.85
.75
.17
.40
.29
,0
.0
.0
.0
.0
.0
.17
,40
.29
.86
.99
HC
18.45
138.34
491,51
.18.40
135.79
494.03
8.51
64.81
204.11
22.48
165.02
602.28
4.86
6.49
22,33
0.61
4.69
17.21
27.96
176.20
641.81
845.97
0.85
CO
175
1308
4678
163
1208
4429
72
549
1711
210
1541
5654
0
0
0
0
0
0
210
1541
5654
7406
7
.50
.48
.86
.31
.68
.78
.26
.50
.76
.62
.68
,02
.0
.0
.0
.0
,0
.0
.62
.68
.02
.32
.41
Percent
***
11.7%
9.9% 3VO%
2.4%
1,5%
1.2%
*PCV or evaporative canister benefits can be added directly to .any
of the above programs.
**Plumbtesmo, fuel inlet/ catalyst, air pump, PCV and evaporative
canister checks.
***Percent of composite mobile source, emissions using MOBILE2
estimates of passenger car and light-duty truck vehicle miles
traveled.
-------
68
Table 20
Benefit of Biennial Tampering Inspections
in Non-I/M Areas
(January 1, 1988)
Per Vehicle Reduction
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
&Fuel Inlet
Air Pump &
Catalyst
Air Pump & .
Fuel Inlet
Air Pump &
Plumbtesmo
Fuel Inlet
& Catalyst
Plumbtesmo
& Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Affected
in
Emissions (
mg/mi)
Light-Duty
Model Passenge
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
HC
15
9
2
26
19
4
41
41
16
67
70
29
84
81
31
43
30
7
53
53
20
86
83
33
90
75
24
135
113
39
112
90
29
,07
.21.
.27
.65
.56
.91
.14
.73
.89
.11
.40
.38
.43
.23
.22
.85
.25
.55
.31
.77
.30
.63
.95
.25
.63
.42
.94
.52
.33
.74
.64
.23
.00
r Car
CO
351
287
70
263
199
51
296
318
129
486
538
225
604
616
239
636
501
125
537
627
209
871
860
309
786
661
213
1239
975
333
1200
S98
300
(6000 Ibs)
.83
.53
.99
.83
.21
.04
.78
.03
.61
.49
.16
.42
.65
.01
.50
.76
.85
.90
.38
.76
.54
.54
.29
.35
.85
.04
.27
.57
.28
.18
.58
.94
.03
HC
19.24
6.07
9.04
24.22
47.53
59.10
26.16
53.62
57.37
41.98
88.03
93.10
55,03
108 .97
118.70
47,25
60.66
76,93
33.84
67.24
74.15
66.94
106.65
115 .12
80.88
155.88
186.39
128.31
221.32
260.68
115.65
191.58
231.11
CO
448
141
211
239
470
585
188
398
420
304
658
686.
393
803
861
726
682
883
315
602
693
798
903
1001
730
1411
1697
1360
1978
2345
1326
1833
2247
.98
.71
.10
.78
.58
.18
.86
.93
.31
.91
.93
29
.63
.29
,45
.37
.22
.24
.651
.25
.15
.79
.85
.65
.61
.48
.66
.40
.59
.54
.37
.34
.24
Trucks
(6000-8500 Ibs)
HC
0.55
3.55
12.39
3.04
23.42
88.77
3.37
26.45
80.93
5.45
43 .44
130.21
7.02
53.74
169.54
4.06
30.46
114.35
4.37
33.74
103.86
6.75
53 .19
160.44
10.20
76.84
276.05
14.36
109.11
383.26
12.70
94.99
341.33
CO
12
82
289
30
231
878
24
196
588
39
325
949
50
396
1216
47
349
1298
40
310
958
58
459
1379
92
695
2518
128
975
3454
123
916
3309
,76
.95
.17
.06
.90
.92
.56
.89
.27
.93
.29
.14
.68
,30
.97
.54
.30
.70
.87
.28
.31
.69
.23
.17
.12
.74
.12
.19
.48
.61
.41
.78
.49
-------
69
Table 20 (continued)
Per Vehicle Reduction
in Emissions (mg/mi)
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Light-Duty
Passenger Car
EC
154
129
44
165
129
41
98
94
35
184
145
46
6
5
2
2
2
0
.74
.94
.24
.76
.20
.92
.39
.87
.12
.98
.82
.41
.46
.55
.35
,12
.39
.7Z
CO
1545
1328
423
1485
1104
350
858
939
323
1791
1457
441
0
0
0
0
0
0
.89
.57
.56
.64
.02
.82
.91
.03
.76
.95
.30
.20
.0
.0
.0
.0
.0
.0
(6000 Ibs)
HC
156.22
271.02
323.36
161.65
275.55
331.83
65.18
127.96
.141.06
189.55
325.25
394.51
11.35
8.91
10.10
5.28
8.14
9.87
CO
1682
2531
3063
1650
2452
2971
540
1051
1180
1972
3005
3689
0
0
0
0
0
0
Trucks
(6000-8500
EC
.72
. 22
.51
.03
.67
.67
.24
.94
.18
.36
.29
.63
.0
.0
.0
.0
.0
.0
17
134
476
18
135
494
8
63
200
21
160
586
3
4
15
0
3
11
.86
.16
.04
.40
.79
.03
.34
.68
.19
.90
.84
.81
.28
.38
.07
.41
.13
.47
Ibs)
CO
168
1260
4503
163
1208
4429
69
532
1651
203
1494
5479
0
0
0
0
0
0
.74
.91
.96
.31
.68
..78
.62
.08
.16
.86
.11
.13
.0
.0
.0
.0
.0
.0
Inspection
Program
Plumbtesmo
& Catalyst
Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Plumbtesmo
& Fuel In-
let & Air
Pump
Plumbstesmo
& Fuel In-
let &
Catalyst
& Air Pump.
PCV*
Evaporative*
Canister
All Items** Pre-1980 193.56 1791.95 206.18 1972.36 25.59 203.86
1980-1983 153.76 1457.30 342.31 3005.29 168.35 1494.11
1984+ 49.49 441.20 414.48 3689.63 613.36 5479.13
All Items** All Yrs.
(in gm/mi)
396.81 3690.45 962.97 8667.28 807.30 7177.10
0.40 3.69 0.96 8.67 0.81 7.18
Percent
***
11.2%
9.5% 2.9%
2.3%
1.5%
1.2%
*PCV or evaporative canister benefits can be added directly to any of
the above programs.
**Plumbtesmo, fuel inlet, catalyst, air pump, PCV and evaporative
canister checks.
***Percent of composite mobile source emissions using MOEILE2
estimates of passenger car and light-duty truck vehicle miles
traveled.
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70
5.2.3 Program Coses
This suDsection scates assumptions necessary to calculate the
cost of a tampering inspection program wnen added to an
existing safety inspection program and when initiated
independently. Costs are calculated over the four-year
period 1984-1987, so chat cost-effectiveness can be
calculated and presentee in the following subsection.
Repairs - The obvious cost of anti-tamper ing ana
anti-misfueling programs is the cost to vehicle owners for
repairs of disablements, whether they were deliDerate or
inadvertent. In terms of all cars being inspected, the per
vehicle cost for repairs will be relatively small, since
usually only some small fraction of vehicles will require
repairs. Also, if che program continues to operate beyond
December 31, 1987, the -cost-effectiveness of the repairs will
improve until essentially the only costs incurred by the
program will be the cost of inspection. Section 3.0
discusses the repair costs which we have assumed .cor this
analysis.
Using the rate of tampering at the start of the program, the
number of vehicles which require repairs at the start of the
program can ue estimated. By assuming an average repair
cost, the initial year repair cost can be estimated.
After the program begins, some tampering will continue to
occur and subsequently be detected and repaired. The number
of vehicles tampered after the program begins will depend on
the effectiveness of the program in deter ing tampering. The
effectiveness will depend on the emission control component.
For air pump, catalyst ana fuel inlet restrictor tampering it
is assumed that only cnose vehicles identified in che first
year of the program will require repairs. .Vehicles not
identified are assumed to continue to avoid detection in
subsequent years. Also, no significant amount of new
tampering is expected to be discovered in subsequent years
since vehicle owners will be aware of the .program and ics
penalties. ?CV and evaporative canister disablements occur
at a nigh rate even -in an inspection program which checks for
such disablements. In these cases all disablements are
assumed to oe repaired in the first year and in each
subsequent year repairs will be done on all disablements
which reappear.
Tampering Inspections Added to Safety - In addition to the
cost vehicle owners must pay in repairs, a safety inspection
program which adds a tampering check will incur additional
expenses from the added tampering inspections at individual
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71
inspection stations and additional administrative costs
related to adding the tampering inspection to the I/M
requirements. A rough estimate of tne additional costs can
oe macie by estimating the increase in personnel time, both
inspector and administrative, necessary to include the
tampering check.
In centralized inspection programs the tampering inspection
might be added to the inspection procedure without any needed
increase in personnel. This would be the case if personnel
'and operating hours did not require expansion; better
scheduling.of inspections or simply tolerating longer waiting
lines could be used to allow tampering inspections with the
existing facility and personnel time. It is more likely tnat
additional inspectors, administrative personnel, or possibly
inspection stations would be required. In such cases the
added .salaries of cne additional personnel and other costs
would be attributed to the tampering inspection.
In decentralized programs, only the additional time an
inspector will need to perform the tampering check should be
attributed. to the anti-tamper ing_ program. As with
centralized programs, administrative costs can probaoly be
estimated by the need to hire additional personnel.
It is expected that most of the duties required by the
addition of a tampering inspection can be integrated into the
operation of the safety program without any substantial
increase in program costs. Although this cost will likely
vary substantially from program to program depending on many
factors, we have assumed an overall increase in program
administrative and inspection costs to oe 34 cents for
centralized and $1.00 for decentralized programs per
inspection as an example. This added cost would include not
only additional costs to perform the inspections, but also
include additional administrative auties to oversee the
additional program elements. Section 5.1.3 discusses how
these costs were estimated.
Tampering Inspections without Safety - In cais case, tne
tampering check is responsible for tne full cost of the
inspection program, including the cost of facilities and
personnel that in existing safety programs can be attributed
to the safety element. Costs in such a program would
probably range from $5 to $10. An assumption of $7 will be
used nere, which is thought to be representative, of an
average decentralized program.
5.2-4 Cost-Effectiveness
Tables 21-24 present cost-effectiveness values calculated for
the benefits presented in Tables 19 and 20 in Section 5.2.2...
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72
These cost-effectiveness values assume the following average
repair costs:
- $20 per disabled air pump
- $200 per removed catalyst
- $10 per disabled PCV system
- $10 per disabled evaporative canister
- $150 per misfueled catalyst
- $30 per tampered fuel inlet restnctor
These repair coses are discussed in Section 3.0. Tne"
additional inspection ana administrative costs are assuinea to
be 34 cents for centralized and $1.00 for decentralized
programs per inspected vehicle per inspection for
safety/tampering programs ana $7.00 for tampering only
programs. Local estimates will likely vary substantially
from this assumption depending on program type and local
conditions. The inspection cost has been aistriouted equally
oetween all of the inspected emission control components ana
divided equally becween the two pollutants when both HC ana
CO emissions' are affected. Emission benefits have been
calculated for each year of the programs beginning on January
1, 1984 through the evaluation data of January 1, 1988. The
total inspection, administrative, and repair costs are summed
for those years and cividea by the sum total emission
reductions and converted to cost per ton.
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77
5.3 Other Anti-Tampering and: Anti-Misf.ueling Programs
The anti-tamper ing ana anti-raisfueling programs in this
subsection do not involve periodic inspection of vehicles and
therefore must rely more heavily on the possibility of
detection to deter misfueling and tampering. Correction of
tampering already present at the start of the program will be
less complete than in a periodic inspection program, since
only a fraction of the fleet is ever directly affected by the
enforcement actions. (Owners of already tampered vehicles
will wait until caught before repairing them since it is
assumed that there is no fine in addition to repairs.) As a
result, the uncertainty inherent in the benefits from these
programs is larger than' in programs where every vehicle is
inspected periodically.
Althougn there are numerous ways in which tampering and
misfueling might be reduced without periodic inspection, this
report will focus only on a few approaches which seem to
proviae the best probability of large emission benefits and
low uncertainty. Other approaches not considered in this
report may provide similar benefits. . If an area wishes to
claim credit for such programs, the EPA Regional Office
should be contacted for an evaluation of the potential of the
specific approach proposed.
To claim all of the benefits estimated in the tables in this
section, the anti-tamper ing and anti-misfueling- program must
meet all of the requirements outlined at the beginning of
Section 5.0, These include such design features as referee
stations and inspector training.
5.3.1 Change-of-Ownership Inspection Programs
A change-of-owner ship anti-tamper ing inspection program would
require an inspection of .the vehicle to assure proper
connection of the emission 'control devices every time the
vehicle changed ownership or moved into the area for the
first time. Title and registration in the new owner's name
would oe withheld until the vehicle was in compliance. This
section assumes that no I/M program is in effect.
Although, nearly all vehicles change hands at least once in
their lives, the time between sales can vary ana will often
be many years. This time period would allow vehicle owners
an opportunity to operate tampered vehicles for long .periods
of time before any penalty, in terms of the replacement and
repair costs that would be paid. Some vehicle owners could
avoid even this penalty t>y selling the vehicle outside the
area covered oy the program or simply retaining or 3unking
the car. Also, within-family transfers are often exempted
since any requirements could be easily circumvented 'by simply
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78
leaving che ticle in the original owner's name. States may
also be reluctant to intrude into family transactions. These
proolems will cause the effectiveness of such programs to be
less than for periodic inspection programs.
Vehicle owners who own cars with tne catalyst removed or
misfueled will probably not replace the catalyst until forced
to in order to complete the sale. Therefore, tne number of
catalysts that are replaced will depend on the fraction of
vehicles which cnange ownersnip each year. The same will oe
true of vehicle owners who have removed or disabled their air
pump. Since evaporative and PCV tampering is assumed to be
inadvertant and undeterrable, and to recur after repair, no
significant oenefit for them can be expected in a
change-of-ownership program. No benefits for PCV or
evaporative system inspections have therefore been estimated.
Benefits from a change-of-ownership inspection program assume
tnat ownership will change in a random fashion, that is older
cars will change owners with the same probability as. newer
cars. For tnis analysis, it is assumed that 15% of the fleet
changes owners each year. This is considered a normal rate.
Some areas may differ. Over the initial four years of the
program (1984 through 1987) aoout 4-8% of the fleet will have
changed owners. The benefits therefore assume that 43% of
tampering which occurred before the program began will be
affected by the program. The effectiveness of the inspection
for this 48% will be assumed to be the same as for biennial
inspections. This assumes that the efficiency of the
inspection will not be significantly less in a
cnange-of-ownersnip program than in a biennial program. The
biennial effectiveness values will also be appliea to all of
the excess emissions due to campering tnat would nave
occurred after the program began. This assumes that few
vehicle owners will tamper knowing that the tampering must be
fixed before selling the vehicle.
Table 25 snows the benefits of a change-of-ownership
inspection program. Benefits would be larger if the
inspection included a tailpipe emissions check, but such a
combined program is outside the scope of this report.
5.3.2 Roadside Pullover Inspection
A roadside pullover anti-camper ing inspection program would
commit to inspecting some percentage of the areawice fleet
each year randomly chosen from traffic on a variety of road
types. Steps would of course have to be taken by the program
to assure that vehicle owners cannot avoid inspection. Each
vehicle stopped would be checked for tampering and issued a
ticket if tampering were discovered. The vehicle owner would
then repair or replace the tampered emission control
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79
component and resubmit his vehicle for inspection at a
designated location. If such repairs were not performed in a
reasonable tine period then a fine (higher than the cost of
repair) would be added as a ' penalty, a hold put on the
vehicle's license renewal, and court proceedings would begin
to collect the fine.
The effectiveness of a roadside pullover program will depend
on the number of vehicles actually inspected and the risk
perceived by vehicle owners that their vehicle will be
inspected. Obviously, a program that stops only a small
percentage of the fleet will present only a small risk, to
vehicle owners who tamper.
As with change-of-ownership programs, vehicle owners cannot
be expected to repair previous tampering until they are
inspected. The following is an estimate of the percentage of
the vehicles in the fleet which would have been inspected at
least once in the initial four years of the program depending
on the- pullover rate. Vehicles tampered before the program
begins have a higher probability of being inspected than
those tampered later, since they will be exposed to the
program more years. The following table presents the percent
of tampered vehicles expected to. be inspected by January 1,
1988. Pullover rates greater than .5%. are not considered
-feasible.
Percent of Tampering Detected by January 1, 1988
Pullover Year in Which Tampering
Rate Occurred
~"~Before 1984 1984 1985 1986 1987
1% 4% 3% 2% 1% 0%
2% 8% 6% 4% 2% 0%
5% 19% 14% 10% 5% 0%
For the vehicles which are inspected, we will assume the same
inspection effectiveness as for a biennial inspection. In
addition, it is assumed that some percentage of vehicle
owners will not tamper after the program begins. The number
of vehicle owners who do not tamper will depend on the
visibility of the random inspection program, since it
determines the perceived risk of detection. Visibility in
turn will depend on the percentage of vehicles inspected each
year. In this analysis we will assume that if 5% of the
fleet, is inspected each year, the program will be 50'% as
effective as a biennial periodic inspection in deterring new
tampering and misfueling. A 2% pullover program is assumed
to be 35% as effective and a 1% program is assumed to be 25%
as effective. Some of the-new tampering that does occur will
be detected and corrected, as with tampering that occurred
prior to the start of the program.
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80
Tables 26 through 28 show the benefits of a random roadside
inspection program for these pullover rates. The benefits
are smaller than any of the programs presented earlier/ due
to less complete coverage and less effective deterrence.
Although cost-effectiveness has net been calcuated for this
program, the cost of a roadside inspection including owner
inconvenience is likely to be higher than an inspection at a
licensed garage or state-run inspection station. Tending to
counteract this is the fact that fewer inspections are
performed.
5.3.3 Fueling Station Enforcement Program
In this program plain-clothes enforcement officers would
visit each fuel station unannounced, at least twice a year,
and observe the fuelings that occur during at least one half
the day. If a- vehicle which required the use of unleaded
fuel was observed fueling with leaded fuel, the officer would
ticket the offender. The penalty would be mandatory
replacement of the catalyst en that vehicle. New license
plates for that vehicle would be denied until the catalyst
had been replaced and an additional penalty (fine) would be
added if within a reasonable period (i.e., one month) after
the ticket had been issued the catalyst had not been
replaced. Court action to collect the fine would be started
after a certain period. In addition where appropriate, the
operators of self-service stations would be charged with
having allowed the raisfuelings that lead to individuals being
cited. The -penalty would be the existing federal' fine of
$10,000 for such actions. Full-service fueling stations
would also be observed during the surveillance and
misfuelings performed by station personnel would be
prosecuted. The effect of prosecuting fuel station operators
would be to make them wary of misfueling vehicles themselves
or allowing misfueling to occur at their stations, adding to
the effectiveness of the program. Extensive press coverage
of the program and its successful detections and prosecutions
would be sought. This approach is assumed to prevent and
deter 80% of misfueling which would have otherwise occurred
after the prcgrara begins.
The benefits provided in this paper for programs to reduce
misfueling assume that unleaded fuel dispensed at service
stations is indeed unleaded fuel. It is therefore important
that occurrences of contamination and mislabeling at "the pump
be minimized. This can be dene by establishing the program
of fuel pump inspections described at the beginning of
Section 5.0.
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81
Tables 29-35 present the benefits of this anti-misfueling
program in I/M and npn-I/M areas without any inspection
program or with periodic inspection programs and in non-I/M
areas with change-of-ownership and random roadside programs.
Enforcement at fuel stations can only prevent misfueling not
already prevented by a periodic, change of ownership, or
random roadside inspection program. Hence, the benefits of
this approach depend on what type of inspection program is in
place. The benefits in Tables 29-35 should be added to those
for the specific inspection program of interest to get the
total benefit from inspections and fuel station enforcement.
Only misfueling which would have occurred- since the program
start is considered in calculating benefits.
5.3.4 Price Equalization ' - -.
Most studies of misfueling behavior suggest that price is a.
primary motivation to misfuel. Programs such as the covert
observation approach explained above attempt to make the
potential penalty for misfueling greater than the motivations
to misfuel. Another approach would be to remove the price
incentive to misfuel. This could be done by eliminating the
difference in price between regular leaded and regular
unleaded.gasoline now observed at retail fueling stations.
There are several possible approaches 'to equalizing the price
of leaded and unleaded fuel. -The state or local government
could equalize the price by law or ordinance. This would
require gas stations to raise the price of leaded fuel and/or
lower the price of unleaded . fuel. The state or local
government could tax leaded fuel instead. This would
equalize the cost to gas stations of leaded and unleaded
fuel, which would tend to equalize the price paid by
consumers. It would also be a revenue source.
Of-course this approach is not without problems. The effect
of price equalization would be to raise the price of leaded
fuel. Older vehicles designed for use of leaded fuel tend to
be owned by poorer motorists, raising issues of regressive .
taxation. As time goes on, however, the number of vehicles
designed for leaded fuel will decrease anyway as the older
vehicles are scrapped so that the effect on total fuel costs
will decrease with- time. Also, this approach will moderate
the- way gas stations now sell leaded fuel at or near cost and
prominently posting the low price while making up the profit
in raising the price of unleaded fuel.
There is some uncertainty, however, about the effectiveness
of price equalization on detering misfueling. Since
perceptions of performance are still an incentive to misfuel,
the price of unleaded versus leaded fuel will not matter to
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82
some vehicle owners. Some studies suggest that performance
is claimed by car owners to be of more importance in
explaining misfueling than price. However, none of these
studies conclusively identify what the misfueling rate would
be in the long run in the absence of -a price incentive.
Conclusive evidence may not be available to address this
complex issue until a state or local government begins such a
program. In this report we have assumed that elimination of
the economic incentives for misfueling will deter 80% of new
misfueling which would have, otherwise occurred.
With the assumption of 80% effectiveness, the benefits of
price equalization are the same for the previously described
program of fuel station enforcement. Therefore, Tables 29-25
may be used for both.
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83
6.0 ADJUSTMENT TO LOCAL CONDITIONS
Since the results in Section 4.3. and in Section 5.0 all
assume standard MOBILE2 operating conditions and default
values, the results must be adjusted to reflect local
conditions if non-standard MOBILE2 conditions are used to
calculate the base emission levels. The simplist method to
accomplish this task is to compare standard MOBILE2 results
with MOBILE2 results modified to reflect local conditions.
The percentage, difference between the two results for each
vehicle type would be applied to the results in this report
to adjust them to local conditions.
This approach assumes that the emissions from grossly
tampered vehicles will be affected by the change in ambient
conditions proportionally to the MOBILE2 emission factors.
This has not been verified by disablement testing at non-FTP
conditions, however it is not an unreasonable assumption that
the emission effects will be similar. It is unlikely that
sufficient disablement testing at non-FTP conditions will be
available soon, if ever. Emission benefits from PCV and
evaporative canister inspections do not require the
adjustment, since MOBILE2 does not adjust non-exhaust
emissions for non-standard conditions.
For example, standard MOBILE2 predicts 2.42' gm/mi HC on
January 1, 1288 for passenger cars. After adjusting MOBILE2
for local temperature/ speed,. VMT, and model year
distribution, a local area may predict 2.02 gm/mi HC for
passenger cars, or 83% of the standard MOBILE2 prediction.
This local, area would therefore only expect 83% of the EC
benefits (in tons or grams per mile) from air pump, catalyst,
and misfueling inspections calculated in Section 5.0 for
their program. A factor for CO" and for' HC and CO from
light-duty trucks would be calculated in the same manner.
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84
Table 25
Benefit of Tampering Inspections
At Change cf Ownership
in Non-I/M Areas*
(January 1, 1988)
Per Vehicle Reduction
in Emissions (ing/mi)
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmc
Only
Plumbtesmo
&Fuel Inlet
Air Pump &.
Catalyst
Air Pump &
Fuel Inlet
Air Pump &
Pluitibtesiao
Fuel Inlet
& Catalyst
Plumbtesmo
S Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Affected
Model
Years
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
? r e-198 4
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Pre-1984
1984 +
Light-Duty
Pas
senger Ca
HC
Q
8
2
17
16
4
30
36
16
51
62
29
60
69
31
29
25
7
39
47
20
64
74
33
63
64
24
96
98
39
77
77
29
.67
.01
.27
.97
.49
.91
.80
.66
.89
.44
.72
.38
.93
.71
.22
.08
.75
«; =;
w W
.23
.19
.30
.41
.50
.25
.23
.47
.94
.16
.32
.74
.74
.27
.00
r
CO
225
250
70
177
168
51
227
283
129
381
285
226
447
536
239
417
431
126
391
553
209
632
766
309
548
566
213
869
848
33
817
860
300
.60
.11
.99
.97
.29
.04
.67
.21
.61
.78
,40
.42
.59
.87
.60
.81
.15
.90
.65
.37
.54
.88
.21
.35
.77
.93
.27
.23
.62
.18
.60
.34
.03
(6000 Ibs)
HC
11.18
4.59
7.06
14.00
30.16
35.01
17.96
41.46
41.79
29.55
69.61
69.49
36.38
81.34
83.29
27.38
39.23
47.27
23.22
52.39
55.02
44.96
84.55
86.69
48.80
104.36
116.18
78.51
155.20
166.72
69 .35
128.75
1 4 5 4, 1
CO
260
107
164
138
298
346
134
317
316
221
535
528
268
618
624
421
450
572
218
478
532
517
731
778
439
940
1052
820
1353
1491
788
1234
1427
.93
.15
.78
.65
.63
.59
.00
.67
.15
.89
.81
.47
.96
.62
.72
. 3 3
.16
.88
.08
.30
.25
.66
.40
.57
.41
.43
.65
.45
.46
.16
.69
. 31
.16
Trucks
(6000-8500 Ibs)
HC
0.36
2.69
9.29
1.80
14.88
59.74
2.40
20.48
56.37
3.98
34,40
93.00
4.31
40.17
113 .72
2,45
19.79
57.58
3.11
26.31
73.75
4 .91
42.20
115.67
6.34
51.50
165 .29
9.16
75 .13
235.02
7.92
63.97
206.16
8
62
216
17
147
502
18
156
422
3C
264
700
35
305
843
29
232
793
29
246
705
43
371
1028
57
464
1500
81
668
2106
77
C19
2016
CO
.44
.88
.83
.34
.33
.43
.07
.98
.07
.09
.83
, ^
.71
.60
.79
.08
.10
. 9 3
.39
.31
.36
.34
.44
.20
.07
. 13
.f-7
.38
.12
.6"
.00
. 17
5 a
* ' \j
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85
Table 25 (continued)
Per Vehicle Reduction
Inspection
Program
Plumbtesmo
& Catalyst
& Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Plumbtesmo
& Fuel In-
let & Air
Pump.
in Emissions (mg/mi)
Affegted
Model
Years
Light-Duty Trucks
Passencer Car
HC CO
Pre-1380 109.05
1980-1983-112.47
1984+ 44.24
Pre-1280 112.21
1980-1983 108.22
1984+ 41.92
Pre-1980 70.64
1980-1983 81.59
1984+ 36.12
Plumbstesmo Pre-1980 125.09
& Fuel In- 1980-1983 122.37
let & 1284+ 46.41
Catalyst
& Air Pump
All Items** All Yrs. 297.87
(in gin/mi) 0.30
(6000 Ibs)
EC CO'
1074.84 94.92 1012.29
1153.44 184.66 1722.59
423.56 205.79 1957.73
999.-98 95.22 266.08
929.49 180.56 1600.93
350.82 202.24 1809.39
621.75 43.44 368.36
818.57 96.65 817.93
323.76 100.83 878.20
1205.59 111.69 1157.93
1234.42' 211.02' 1270.07
441.20 242.02 2275.96
2831.21 566.72 5403.96
2.88 0.57 5.40
(6000-8500 Ibs)
HC
CO
11.28 106.37
21.57 860.25
290.59 2760.10
11.21 99.21
89,09 789.93
220.70 2596.10
5.77 49.35
48.16 414.05
136.80 1175.79
13.33 123.20
105.53 282T05
346.25 3242-54
465.11 4355-72
0.47 4.36
Percent
***
8.4%
7.4% 1.7%
1.5%
0.8%
0.7%
*Assumes a random 15% changeover of the fleet each year with program
beginning January 1, 1984.
**Plumbtesmc, fuel inlet, catalyst, air pump, PCV and evaporative
canister checks.
***Percent of composite mobile source emissions using MOBILE2
estimates of passenger car and light-duty truck vehicle miles
traveled.
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86
Table 26
Benefit of Anti-Tampering I
During 5% Random Roadside
in Non-I/M Areas
Per Veh
in Em is
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
&?uel Inlet
Air Pump &
Catalyst
Air Pump &
Fuel Inlet
Air Pump a
Plumbtesmo
Fuel Inlet
a Catalyst
Plumbtesmo
& Catalyst
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980 '
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
nspections
Pullover
icle Reduction
sicn
s (mg/mi)
Light-DutyTr
Passenger Car (
4
4
i
8
8
2
15
19
8
25
32
15
29
25
16
13
13
2
19
24
10
3 1
38
J. /
30
33
12
46
50
20
HC
.46
.14
.18
.48
.44
.54
.15
.01
.80
.52
.66
.31
.55
.90
.27
.61
.22
.90
.17
.46
.57
.59
. 75
.32
,25
.15
.96
.32
.79
.67
CO
104
129
36
83
86
26
112
147
67
190
253
117
219
277
124
194
222
£5
190
237
108
307
298
160
262
291
110
416
438
173
.04
.32
.73
.94
.20
.36
.97
. 46
.51
.96
.67
.41
.18
,73
.74
.69
.05
.09
.65
.26
.89
.65
.96
.86
.49
.81
.72
. 71
. 75
.07
4
2
3
6
13
15
8
20
19
14
3'4
32
17
39
39
12
18
21
11
16
26
21
42
41
21
49
52
35
72
75
6000
HC
.91
.26
.45
.12
.84
.33
.53
.62
.93
.19
.90
.41
.01
.94
.17
.00
.16
.05
.03
. 13
.41
.17
.42
.81
.85
.04
.07
.40
.25
. 5 7
Ibs
uck
) (6000-8
CO
114
52
80
60
136
151
64
159
152
107
271
256
127
207
297
184
210
254
103
240
258
239
369
379
196
441
470
367
641
674
.58
.87
.43
.70
.99
.76
.55
.64
.42
.89
.16
.79
.55
.25
.38
.80
.21
.73
.90
.14
.39
.88
.54
.49
.39
.04
.72
.24
.96
.14
nc
0.
^ ,
4.
0.
6.
21.
1 .
10.'
26.
1 _
IT".
43.
2 .
19.
51.
1.
9.
29.
1.
1 ^
34.
« 2.
21.
54 .
2.
24.
72 .
4 .
35.
104.
17
3 "5
W *
44
80
83
76
16
19
28
94
25
75
29
74
27
09
17
44
50
13
62
3 9
IS
59
88
22
44
21
73
11
s
500 Ibs)
CO
3.
5 1
103 '.
7.
67.
215.
8.
78.
199.
14.
134.
333.
17.
151.
392.
13.
108.
251.
14.
123.
335 .
21.
187.
490 .
25.
217 .
656.
2 7 .
317.
930.
94
05
72
92
62
47
82
92
10
83
08
20
28
86
70
11
72
21
23
64
30
20
64
87
89
78
18
>_ c
07
90
-------
87
Table 26 (continued)
Inspection
Program
Fuel Inlet
& Catalyst
& Air Pump
Plumbtesmo
& Catalyst
& Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Plumbtesmo
& Fuel In-
let & Air
Pump
Plumbstesmo
& Fuel Inlet
& Catalyst
& Air Pump
Total all Years*
(in gin/mi)
Percent**
Affected
Model
Years
Pre-1980
1280-1583
1984 +
Pre-1980
1980-1283
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
irs*
in
Emissions (
Light
Passenger Car
HC
37
39
15
52
58
23
53
55
21
34
42
18
59
62
24
145
0
.02
.76
.07
.38
.06
.00
.01
.25
.80
.18
.03
.30
.06
.56
.13
.75
.15
CO
387.
443.
155.
513.
596.
219.
471.
475.
182.
301.
423.
168.
567.
632.
229.
1429.
1.
mg/mi )
-Duty Trucks
(6000 Ibs)
HC
21
43
63
47
03
86
21
67
24
85
49
37
98
95
03
96
43
30
60
65
42
87
93
42
84
90
20
47
47
49
99
107
145
0
.95
.61
.44
.64
.44
.07
.15
.05
.19
.38
.67
.75
.39
.14
.70
.94
.15
CO
350
581
644
452
815
887
425
743
802
174
407
421
511
217
1015
1432
1
.47
.49
.91
.52
.27
.03
.82
.98
.52
.54
.63
.83
.10
.29
.41
.01
.43
(6000-8500 Ibs)
HC
3.50
30.14
90.71
5.16
43.39
128.46
5.04
41.50
126.39
2.75
23.77
63.33
5.25
49.16
150.74
114.08.
0,11
CO
35.
222.
890.
48.
407.
1222.
44.
367.
1126.
.23.
206.
552.
55.
457.
1418.
1082.
i
x .
04-
09
64
65
57
28
56
22
64
75
41
52.
86
80
02
22
08
4.1%
3.7%
0.4%
0.4% 0.2%
0.2%
fue:
inlet, catalyst, air pump, ?CV and. evaporati^
*Plumbtesmo,
canister checks.
**Percent of composite mobile source emissions using MOBIL22
of passenger car and-light-duty truck vehicle .miles traveled.
estimate
-------
38
Table 27
Benefit of Anti-Tampering Inspections
During 2% Random Roadside Pullover
in Non-I/M Areas-
Per Vehicle Reduction
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
&Fuei Inlet
Air Pump «
Catalyst
Air Pump &
Tn a 1 Tn 1 a U
Air - Pump &
Plumbtesmo
Fuel Inlet
& Catalyst
Plumbtesmo
S Catalyst
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980 '
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-198J
1984 +
Pre-1980
1980-1983
1984 +
Pre-1930
i a a n- i o a ?
^ - O U j.www
1984+.
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
in
Em
Passenger Car (
HC .
2
2
0
c
5
-
9
12
6
16
21
10
18
23
11
7
8
2
11
i s
U» >J
19
25
12
18
21
8
28
33
14
.55
.74
.82
.00
.51
.76
.43
. 60
.10
.06
.74
.61
.08
.60
.27
.95
.67
. 71
.84
. 2 1
.33-
.61
. 7 6
.01
.19
.76
.99
.10
.51
3 3
CO
59
85
25
49
56
18
71
98
46
121
169
81
135
183
86
112
146
45
117
i o n
.» w W
75
188
265
111
157
191
76
251
289
120
.49
. 41
.49
.53
.36
2 i
.11
.14
.79
.37
.52
.37
.77
.55
.46
.99
.04
. 19
.23
S f-
-J
163
138
237
241
107
258
263
200
331
333
.82
.07
.18
.08
.79
.86
.16
.07
.41
.28
.31
.46
.83
7 Z
.88
.94
.43
. 21
. 15
3 8
cj \^
. 27
i >
'.73
.07
.24
.37
.18
. 9 7
.88
.65
£
500
HC
0
0
2
0
3
i i
0
6
15
1
11
26
1
12
30
0
5
15
0
P
. 29
.46
.68
.76
.21
. 7 5
.07
-------
Inspection
Program
Fuel Inlet
& Catalyst
& Air Pump
Plumbtesir.o
& Catalyst
& Air Pump
Plumbtesmo
& Fuel In-
let &
Catalyst
Plumbtesmo
& Fu.el In-
let & Air
Pump
Plumbstesmc
& Fuel In-
let &
Catalyst
& Air Pump
Total All Years*
(in gin/mi)
Table
Affected
Model
Years
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
89
27 I
[continued)
Per Vehicle
Reduction
in Emissions (mg/mi;
Light-Duty
Passenger Car
HC
22
26
10
31
38
15
31
36
15
20
27
12
34
40
16
,13
.12
,45
,66
.28
.94
.34
.04
.11
.86
.66
.68
.91
.81
,73
CO
229
291
107
308
393
15-2
277
310
126
184
27'9
116
334
414
158
.75
.89
.96
.20
.42
.50
.72
.63
,38
.99
.90
.73
.66
.2.4-
.85
(6000
HC
16.86
35.69
36.98
23.47
51.90
53.01
22.64
48.74
49.91
11.94
29.80
29.15
26.53
57.47
59,73
Ibs
) I
i
Trucks
[600
CO
189
342
366
247
483
506
227
430
442
103
258
262
273
532
565
.64
.77
.75
.15
.57
.60
.48
.38
.58
.64
.10
.72
.66
.06
,53
2
17
49
2
25
70
2
24
67
1
- J.
14
37
2
28
81
0-85
EC
.02
.77
.72
.92
.78
.99
.78
.08
.81
.65
.87
.74
,30
,53
.06
00 Ibs)
CO
19
172
491
27
242
677
24
212
602
14
130
336
30
265
765
.67
.49
.50
.50
.09
.52
.52
.64
.36
.40
.74
.90
.81
.98
.82
92.45 907.75 67.68 673.50 49.37 474.81
0.09 0.91 C.07 0.67 0.05 0.47
Percent
* *
2.6%
2.3% 0.2%
0.2%
0,1%
0.1%
*Plumbtesmo, fuel
canister checks.
inlet, catalyst,- air pump, PCV and evaporative
**Percent of
estimates of
traveled.
composite
passenger
mobile source emissions using MOBILE2
car and light-duty truck vehicle miles
-------
Inspection
Program
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
SFuel Inlet
Air Pump
Catalyst
Air Pump &
Fuel Inlet
Air Pump &
Pluir.btesmc
Fuel Inlet
& Catalyst
Piumbtesrao
& Catalyst
90
Table 28
Benefit of Anti-Tampering Inspections
Daring 1% Random Roadside Pullover
in Ncn-I/M Areas-
Per Vehicle Reduction
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+-
Pre-1980
1930-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1P80-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
in
Passenger Car
HC
1.
1 1
0.
3.
3 t
i!
6.
8.
4.
10.
15.
^
12.
16.
8.
5.
6".
1.
7 .
11.
5 .
13.
17.
8.
12.
15 .
~6.
18.
23.
10.
64
90
58
28
81
25
36
76
33
89
15
54
09
35
01
18
00
9 3
96
26
20
21
94
53
05
07
38
70
25
18
CO
38.
5 9 .
18.
32.
38.
13.
48.
68.
33.
82.
118.
57.
91.
127.
61.
73.
101.
32.
78.
132.
53.
126.
134.
79.
104.
132.
54.
166.
201.
85.
32
28
12
48
94
02
23
36
23
71
31
79
34
44
40
39
17
12
56
54
64
43
98
22
52
84
56
67
17
27
Em
1
0
1
1
5
5
3
3
8
r
15
14
6
16
15
3
6
7
A_
11
11
8
18
17
7
18
18
12
28
27
1SS1
(600
EC
.60
.96
.50
. 9 9
.04
.14
.35
.85
.25
.69
.19
.08
.46
.75
.74
.90
.75
.41
.33
.07
.08
. 16
.49
» / w
e; 1
*J J.
.85
.63
-< ^
. « /
,47
.83
ons
Ligh
(me/mi )
t-Duty Trucks
0 Ibs)
CO
37
22
34
19
49
50
26
69
64
44
119
110
49
131
122
60
79
93
41
104
111
89
163
164
67
168
167
126
251
246
.42
.36
.94
.68
.91
.93
.06
.76
.59
.39
.96
.57
.91
.52
.70
.20
.68
. 44
.05
.78
.05
.32
.02
. 41
.18
.72.
.41
.08
.48
.63
(6000-8500
HC
0.06
a.
1.
0.
2.
C.
0.
4.
10.
0.
7.
17.
0.
8.
20.
0.
3.
o >
0.
£
14!
0.
9.
22.
1.
o
24.
1.
14.
36.
56
88
27
49
94
47
38
51
80
51
86
90
2S
21
38
42
85
61
66
07
98
24
46
03
32
68
5 ^
08
56
1.
13.
4.3.
2.
24.
63.
3.
34.
81.
6.
59.
i ? a
«<.*
6,
65.
156.
4.
41.
122.
5.
; -5
-» w *
140.
8.
82.
207 .
o t
83.
222.
13 .
124.
324 .
Ibs)
CO
50
16
94
66 -.
67
71
66
^
0 ^
82-
26
35
51
97
06
45
53
49
85
81
93
1 2
82
76
08
18
41
10
61
34
64
-------
91
Table 28 (continued!
Per Vehicle Reduction
Affected
Inspection Model
Program Years
Fuel Inlet Pre-1980
& Catalyst 1980-1983
& Air Pump 1984+
Plunbtesmo Pre-1984
& Catalyst 1984+
& Air Pump
Plumbtesmo Pre-1984
& Fuel In- . 1984 +
let & Catalyst
Plumbtesmo Pre-1984
& Fuel In- 1984+
let & Air Pump
Plumbstesmo Pre-1984
& Fuel In- 1984+
let & Catalyst
& Air Pump .
Total All Years*
(in gm/mi)
in
Emi
ssicns (
mg/mi)
Light-Duty Trucks
Passenger
HC
14.61
18.09
7.42
21.03
26.55
11.33
20.57
24.86
10.74
13.93
19.16
S.OO
22.90
28.16
11.88
62.94
0.06
151
202
76
203
273
108
181
214
89
123
194
82
219
286
112
618
0
Car
CO
.08
.29
.72
.94
.00
.35
.95
.47
.79
.76
.35
.92
.22
.30
.87
.39
.62
10
23
23
14
34
34
14
31
31
7
20
19
16
37
37
37
0
(60U
HC
.55
.37
.67
.78
.13
.02
.04
.65
.55
.80
.14
.48
.45
.31
.81
.72
.04
0 Ibs)
(6000-8500
CO
118
224
235
154
317
326
140
279
279
68
175
177
169
345
158
379
0
.14
.60
.67
.86
.94
.34
.55
.05
.20
.18
.56
.40
.33
.50
.91
.70
,38
1
11
31
1
16
44
1
15
42
1
ia
24
2
18
50
25
0
HC
,29
.64
.25
.87
.97
.85
.75
.64
.05
.09
.05
.91
.08
.53
.34
.90
.03
Ibs)
CO
12
113
310
17
159
428
15
137
372
9
88
225
19
172
476
252
0
.53
.14
.25
.59
.29
.85
.44
.93
.71
.58
.94
.08
.42
.88
.92
.22
.25
Percent**
1.8%
1.6%
0.1%
0.1%
0.0%
0.0%
*Plumbtesmo, fuel
canister checks.
inlet, catalyst, air pump, PCV and evaporative
**Pe.rcent of
estimates of
traveled.
composite
passenger
mobile source emissions using MOBILE2
car and light-duty truck vehicle miles
-------
92
Table 29
Benefit of a Fueling Station
Enforcement Program Begun January I, 1284
In an Annual I/M Area
Per Vehicle Reduction (January '.
in Emissions
Annual
Inspection
Procram
None
Air Purnc
Only
Catalyst
On 1 y
Fuel Inlet
Only
Plumb tesmo
On.lv
Plumb tesmo
aFuel Inlet
Air ?ur,o a
Catalyst
Air ?ui?,c «
Fuel Inlet
Air Pump £
Plumb tesmo
Fuel Inlet
& Catalyst
Affected
Model
Years
Pre-1280
1280-1283
1284 +
Pre-1980
1980-1983
1984 +
Pre-1280
1280-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1280-1283
1984 +
Pre-1980
1980-1283
1984 +
Pre-1280
1980-1283
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1280-1283
1984 +
Pre-1980
1980-1983
1984 +
1 , 1 Q
- / -« *
88)
(me/ mi )
Light-Duty
Pass
enger Ca
EC
11 .
18.
11.
12 .
i 9
11.'
15 .
22.
13.
7.
10.
6.
3 .
C
3 .
2 .
4 .
2.
16,
22 .
14 .
8.
12.
7.
4 ,
6 .
3.
8.
12.
7.
97
12
11
74
26
80
36
53
63
24
80
58
75
32
23
24
59
74
27
97
50
51
04
27
42
09
63
30
15
26
CO
90
140
86
97
149
22
124
185
113
56
86
52
31
46
27
27
40
24
122
197
120
66
95
58
36
51
31
67
100
61
r
.94
.45
.77
.08
.68
. 41
.54
.56
.03
.84
.22
.20
.63
.13
.86
.22
.24
.18
.97
.87
.47
.04
.87
.35
.71
.80
.10
.25
.20
.04
(6000
EC
5.77
16 .76
15.21
6 .68
12.40
17.61
7.24
22 .07
20.94
3.62
10.50
9.53
2.02
5.88
5.33
1.79
5 .20
4 .72
9.30
27.01
24 .52
5.13
13.87
13.28
2.32
7.88
7.50
4,22
12.46
11 . 21
Ibs)
£0
45
132
120
C -5
155
141
67
194
176
29
85
77
17
51
46
15
46
42
79
220
209
41
112
107
24
68
64
36
105
o =,
*> ''
Trucks
(6000-35
HC
.57
.34
.11
,58
. 5 2
.20
.02
.32
.81
.56
.83
.90
.72
.46
.70
.98
. 41
.12
.52
.92
*«//'
.50
.65
. 4 9
.62
.20
.24
. 22
.20
.43
0
3
18
0
0
21
i
11
25
0
5
11
0
2
6
0
2
5
T -1
J. ^
30
n
6
17
0
-5
Q
0
6
-, -5
.83
.30
.72
.27
.61
.67
t i 5
.42
.77
.52
.20
.72
.29
.21
.56
.26
. 5 7
.30
.37
. i /
.86
.22
.'20
.53
.62
00 IDS)
CO
6.
65.
147.
7 .
77 ,
172.
9.
96.
217.
4 .
42.
9.5.
2.
25.
57.
2.
22.
51 .
11.
114.
257 .
55 .
3 t
33!
81.
5 2 ,
52
52
32
75
02
78
70
45
61
27
50
8-7
56
48
48
21
28
83
50
32
22
36
74
38
" 1
34
24
09
51
-------
93
Table 29 (continued:
Per Vehicle Reduction
-in Emissions
Inspection
Program
Plunbtesmo
& Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Plumbtesmc
& Catalyst
& Air Pump
Plumbtesmc
& Fuel Inlet
& Catalyst
Plumbtesmo
&. Fuel Inlet
Air Pump
Plumfastesmo
& Fuel Inlet
& Catalyst
a Air Pump
Affected
Model
Years
Pre-1980
1980-1983
1384 +
Pre-1980
1980-1983
1984 +
Pre-1980
1983-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
(me/mi )
Liaht-Du
Passenger
HC
3.07
4. -51
2.73
8.91
13 .05
7.89
3 .42
5.00
3.02
2.30
3.38
2.04
3.57
5.07
3.03
2.65
3.87
2.34
Car
CO
24
37
22
72
107
65
27
41
25
18
27
16
20
44
26
21
22
19
.91
.11
.61
.46
.80
.62
.80
? -5
^ -J
.16
.68
.83
.96
..74
.36
.67
.57
.05
.50
(6000
EC
1.59
4.61
4.19
5 . 12.
14.89
13.51
2.05
5.97
5 .41
1.19
3.46
2.14
,
2,24
6.50
5.90
1.66
4.81
4.37
Ibs)
CO
13
38
35
43
127
115
17
51
46
10
29
26
20
58
52
14
41
37
tv T
r u c k s
(6000-8500 Ibs)
HC
.42
.96
.36
.90
.48
.69
.68
.34
.59
.06
.22
.52
.09
.35
.96
.22
.60
.75
0
2
- 5
0
7
16
0
2
6
0
1
3
0
3
7
0
2
. 5
.23
,28
.15
. 74
.37
.63
.30
.95
.66
.17
,71
.87
.32
.22
.27
,24
.38
.38
CO
1.
19.
43.
6.
63.
142.
2.
25.
57 .
1.
14.
32.
2.
28.
65.
2.
20.
46.
94
29
52
5 C
w -/
11
29
56
42
34
46
47
64
91
89
18
07
60
46
-------
Biennial
Inspection
Progr am
None
Air Pur.o
Cnlv
Catalyst
Onlv
Fuel Inlet
Only
Plumbtesino
Onlv
Plumbtesino
SFuel Inlet
Air Pump i
Catalyst
Air Pump s.
Fuel Inlet
Air Pump i
Piumbtesmc
Fuel Inlet
i Catalyst
Snf ore
94
Table 30
Benefit of a Fueling Station
ement Program Eegun January 1, 1984
In an Biennial I/M Area-
Per Vehicle Reduction (Januarv 1, ;
in Smi
Affected
Model
?ears
Pre-1980
1930-1932
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1932
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984-
Pre-1980
1980-1982
1984 +
Passencer Car
HC
11 .97
18 .12
11.11
12.68
19 .15
11.73
15.36
22.53
13.63
7.24
10 .80
6.53
3.75
. 5.39
3.23
3.24
4.59
2.74
16 .22
22. 76
14 .27
8.26
11.91
7.20 '
4 ,49
6.16
2.66
3.20
12 .16
7.26
. CO
90
140,
86
96
148
91
124
185
112
56
86
52
21
46
27
27
40
24
121
196
119
65
94
57
3 7
52
21
6 7
100
61
.94
.45
.77
.64
. 9 5
.95
. 5 4
. 5 6
.02
.84
.22
.90
.62
.13
.36
.92
.24
.13
. 7 7
.11
. 41
.06
, 94
.83
.17
.26
..36
'.25
.20
.04
5
16
1 ^
* a'
6
19
17
7
23
20
>
10
0
2
S
5
1
3
4
a
26
24
5
13
13
2
8
^
4
12
-i
1988)
ssicns (mg/mi)
Liqh
t-Dut
(6000 Ibs)
HC
. 7 7
.76
.21
.64
.27
. - 9
.94
.07
.94
.62
.50
.53
.02
.88
.32
.79
.20
.72
.11
. 45
.00
.02
.58
.00
.97 '
.02
.68
.29
.46
.21
45
122
120
5 3
154
140
67
194
176
29
85
77
17
51
46
15
46
42
77
225
204
40
110
104
25
69
65
26
105
9 5
CO
.57
.24
.11
.28
.71
. 41
-09
.32
.81
.56
.82
.90
.72
.46
.70
.98
. 41
.12
.74
7 £
Is?
. 44
.71
.97
.19
.12
.42
. 22
.20
.48
v Tr
(60
u c k s
00-8500 Ibs)
HC
0
8
13
0
9
21
1
11
25
0
5
11
0
2
6
0
2
5
1
12
29
0
6
16
0
3
9
0
6
1 -5
.83
.30
.72
.96
.54
: i
.15
.42
.77
. 52
.20
.73
.29
.91
.56
.26
.57
.80
.32
.10
.54
. 7 1
.72
.65
.42
.97
.34
.62
.17
.92
CO
6
65
147
7
76
172
9
96
217
4
42
9 5
2
25
57
2
22
C I
11
252
;
54
133
3
24
82
;
5 2
117
.59
. 5 2
.82
.70
.60
.81
.70
. 45
.61
. 27
.50
.87
. 5 6
. 48
.48
. 21
.98
.82
. 2 -
.' 77
.16
. 7 2
.78
r -r
.20
. 11
^ ^
.09
-------
95
Table 30 (continued)
Per Vehicle Reduction
in Emissions (rnc/mi)
Inspection
Program
Plumbtesmo
&. Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Plumbtesrr.o
& Catalyst
& Air Pump
Pluinbtesmo
& Fuel In-
let &
Catalyst
P_j..u]TibtesTTio
iFuel In-
Jrlt & Air
Ptrurn
Affected
Model
Years
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982"
1984 +
Light-Duty
Passencer
HC
2.07
4,51
2.72
8.91
12.05
7.89
2.52
5.16
2.12
2,20
2.28
2.04
2,62
5.16
2.08
Car
CO
24.91
27.11
22.61
72.46.
107.80
65.62
28.76
42.74
26.01
18.68
27.82
16.96
21.09
44.94
27 . 0 4
(6000
HC
1,59
4.61
4.19
5.12
14.89
12.51
2.21
6.42
5.8.2
1.19
2.46
2 .14.
2.28
6,61
6.00
Ibs)
CO
12.42
28.96
25.26
42 .90
127.48
115.69
19.10
55.46
50.24
10:06
29.22
26.52
20.22
59.05
52,59
Trucks
(6000-85
HC
0.22
2.28
5.15
0.74
7.27
16.62
0.22
2.18
7.17
0.17
1.71
2.87
0.33.
2.27
7.28
00 Ibs)
CO
1.94
19.29
42.52
6.25
62.11
142.29
2.76
27.46
61.95
1.46
14.47
22.64
2.94
29.24
65.96
Plunbstesmo
& Fuel In-
let &
Catalyst &
Air Pump
Pre-1980 " 2.76 - 22.54
1980-1982 J.Q4 23.46
1984+ 2.44 20.25
i.ai
5.26
4.78
15.75
45.72
41.50
0.26
2.61
5.88
2.28
22.64
51.07
-------
Annual
Inspection
Program
None
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Pluinbtesmo
Only
Pluinbtesmo
aFuel Inlet
Air Pump &
Catalyst
Air Pump &
Fuel Inlet
Air Pump *
Plumbtesinc
Fuel Inlet
& Catalyst
96
Table 31
Benefit of a Fueling Station
Enforcement Program Begun January I/ 1984
In a Ncn-I/M Area with an
Annual Inspection Program
Per Vehicle Reduction (Janua
in Emissions (
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1380
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980 '
1980-1983
1984 +
ng/m
i)
Light-Duty '
Passenoer
37
55
29
39
59
31
48
70
34
22
33
17
12
17
8
10
14
6
52
75
36
26
36
18
13
19
8
26
38
18
HC
.10
.69
.38.
.54
.25
. 16
.88
.39
.33
.74
.57
.12
.13
.22
.06
.57
.81
.73
.11
. 49
'.99
.04
.66
.20
.96
.03
.74
.39
.28
.81
Car
CO
285
437
225
305
466
239
402
592
232
181
271
134
103
14-9
67
92
131
57
430
632
300
205
296
143
118
165
73
217
320
152
.90
.09
.42
.62
.39
. 66
.47
.67
.15
.20
.81
.77
.81
.65
.78
.43
.69
.92
.14
.58
.26
.86
.72
.65
.09
.30
.60
. 34
.04
.36
(6000 Ibs)
HC
18
52
47
21
61
55
25
74
67
11
33
30
6
19
17
5
17
15
30
87
79
15
42
40
0
25
23
13
40
36
.17
.75
.87
.16
.45
T ?
. 1 /
.71
.65
.74
-.54
.52
.42
.65
.31
.52
.93
.22
.63
.25
.85
.73
.37
. 91
. 18
.17
.20
.43
.88
. 31
.53
CO
145
423
383
172
500
454
220
639
580
o 5
278
252
59
171
155
53
155
141
262
761
691
129
355
331
79
222
205
118
345
313
.69
.07
.96
.37
.56
.28
.34
.35
.70
.84
.32
,59
,00
.33
.49
.58
.59
.21
,38
.93
.48
.89
.96
.3 3
.83
. 3 1
.47
.98
.52
.58
rv I/ 19
Irucks
(6000-8
H£
2.63
26. 12
58.92
3.06
30.43
68.64
3.72
36.96
83.38
1.67
16.60
37.44
0.96
9.56
21.57
0.86
8.52
19.23
4.37
43.50
93.13
2.24
21.23
50.92
1.3Q
12.47
29.49
2.01
19.96
45 .02
88)
500 Ibs)
CO
21
209
472
24
247
559
31
316
714
13
137
310
8
84
191
7
77
173
37
377
351
18
176
4 L!
1 1
110
257
17
171
385
.07
.46
.55
.93
.82
.10
.36
.79
.68
.8-6
.79
.37
,53
.82
.36
.75
.03
.79
.94
.22
.02
5 0.
» V J
, 14
s o
w V
; 7
.'03
.26
.21
.06
.93
-------
97
Table 31 (continued)
Per Vehicle Reduction
in Emissions (.mg/zni)
Annual
Inspection
Program
Plumbtesmo
£ Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Plumbtesmo
& Catalyst
& Air Pump
Plujnbtesmo
& Fuel In-
let -& Cat-
alyst
Affected
Model
. Years
i i
Pre-1980
1980-1983
1984+
Pre-1980
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Light-Duty T
Passenoer
HC
9.78
14.18
6.97
28.39
41.12
20.14
10.88
15.76
7.71
7.33
10.63
5.23
Car
CO
80
118
56
234
344
163
89
132
62
60
88
42
.49
.53
.43
.41
.67
.53
.98
.22
.64
.37
.90
.32
(6000 Ibs)
HC
5.14
1 4 . 9 3
13.55
16.69
48.46
43.98
6.70
19.46
17 . 6 6
3.86
11.20
10.16
CO
44
127
116.
144
420
381
58
169
154
33
95
87
.07
.97
.14
.93
,86
.95
.48
.82
.12
.05
.98
.10
(6
0
7
16
2
23
54
0
9
21
0
5
12
rucks
000-8500
HC
.74
.39
.68
.41
.99
.13
.97
.63
.73
.56
.54
.51
CO
6
63
142
20
208
470
8
84
189
4
47
107
Ibs)
.37
.36
.94
.96
.36
.07
.46
,08
.68
.78
.52
.20
Piumbtesmo~
Fuel In-
tkt & Air
Pump
Pimnbstesmo
& Fuel In-
let & Cat-
alyst & Air
?uinp
Pre-1984
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
11.65 101.65 7.44
16,36 145.02 21.60
7.45 64.00 19.60
8.44 69.86 5.41
12.21 102.58 15.72
5.96 48.53 14.27
67.48
195.96
177.84
1,08
10.69
24.12
9 . 76
97.02
218.88
47.46
137.83
125.09
0.78
7.79
17.56
6.86
68 .24
153.95
-------
98
Table 32
Benefit of a Fueling Station
Enforcement Program Begun January 1,
In a Mcn-I/M Area with an
Biennial Inspection Program
or Change of Ownership Program
1284
Per Vehicle Reduction (January 1, 1988
in Emissions (me/mi)
Annual
Inspection
Procram
None
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmc
iFuel Inlet
Air Pump &
Catalyst
Air. Pump «
Fuel Inlet
Air Pump s
Plumfatesmc
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1933
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1283
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1280-1283
1984 +
Pre-1980
1980-1983
1934 +
Pre-1980
1980-1983
1984 +
Light-Dutv_
Passenger Car
HC
37.10
55.69
29.38
39.34
58.94
30.98
48 .83
70.89
34.83
22.74
33.57
17.12
12.13
17.22
8.06
10.57
14.31
6.73
51.65
74.83
36.68
25 .68
36.37
13 .10
14.13
19.23
8.80
CO
285.90
437.02
225 .42
304.31
464.23
238.36
402.47
592.67
282.15
181.20
271.81
134.77
103.81
149.65
67.78
92.43
131.69
57.92
426 . 18
£26.88
297 .67
203 .50
294 .72
142.95
119.22
166.32
73.98
(6000
JJC
18. 17
52.75
47.37
21.03
61.07
55.42
25.71
74 .65
67.74
11.54
33.52
30. 42
£.65
19.31
17.52
5.93
17.22
15.63
29.60
35.97
78.02
15.48
42.23
39.39
9 .35
25.53
23.80
Ibs )
CO
145.62
423.07
383.96
171.49
427.98
451.24
220.34
632.85
580 .70
95.34
278.32
252.52
59.00
171.33
155.42
53.58
155.52
141.21
256.37
744 .42
67 " £ 5,
1 -V t W w
127.23
351.40
32G .01
81.05
224.50
207.98
T r u c k s
(6000-8
HC
2.63
26.12
58.92
3.04
30 .23
68.21
3.72
36.26
83.38
1.67
16.60
37.44
0.96
2.56
21.57
0.36
8.52
12.23
4 .28
42.56
96 .02
2.19
20.20
49.73
1.32
12 .63
30.05
500 Ibs)
CO
21.07
202.46
472.55
24.30
246 .55
556.22
31.86
316.72
714.68
13 .86
137.72
310.87
8.53
84.82
191.36
7.75
77.03
172.79
37.07
368 .59
331.55
13 .07
173 .90
409.64
11.52
111 . 10
260 .99
-------
99
Table 32 (continued)
Per Vehicle Reduction
in Emissions (mc/ini)
Inspection
Pro-cram
Fuel Inlet
* Catalyst
Pluir.btesmo
& Catalyst -
Fuel Inlet
& Catalyst
& Air Pump
PluTT.b testae
& Catalyst
& Air Pump
Plumbtesmc
& Fuel. In-
1 r C r*3» ?
ifi-st
Plumbte-sr.o
& Fuel In-
let & Air
Pump
PluTT.bstesr.c
'& Fuel In-
let & Cat-
alyst & Air
Affected
Model.
Years
Pre-1980
1980-1982
1984 +
Pre-1980 :
1980-1982
1984 +
Pre-1980
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Pre-1984
1980-1983
1984 +
Passenger Car
HC
26.
' 38,
18.
Q _
14!.
6.
28.
41.
20.
11.
16.
7,
7.
10,
5.
11,
16.
7,
8.
12.
6.
39
28
81
78
18
97
39
12
14
25
28
95
33
63
23
81
61
60
81
74
21
CO
1
217
320
152
80
118
56
234
344
163
93
136
64
60
88
42
102
146
65
73
107
50
,
134
.04
.36
.49
.53
.43
.41
.67
.53
.14
.78
.71
.37
.90
.32
,69
.75
.04
.02
.15
.60
Li
(600
HC
13.88
40.31
36.58
5.14
14.93
13,55
16.69
48.46
43.98
7.22
20.97
19.03
3.86
11.2.0
10.16
7.54
21.90
19.88
5.93
17.23.
15.64
cht-Dutv
0 Ibs)
CO
118
345
313
44
127
116
144
420
381
63
183
166
33
95
87
68
198
179
52
151
137
.98
.52
.58
,07
.97
.14
.92
.86
.95
.28
.77
.78
.05
,98
.10
.19
.02
.72
.27
.78
.75
Trucks
(6000-8
HC
2.01
19.96
45.02
0.7.4
7.39
16.68
2.41
23.99
54.13
1.04
10.38
23.42
0.56
5 ,54
12.51
1.09
10.84
24,47
0.86
8.53
19.25
500 ibs)
CO
17.
171.
385.
6.
63,
142.
20.
208.
470.
0
j *
90.
205.
4 .
47.
107.
o >
98,
221.
7.
75.
169.
21
06
93
37
36
94
96
36
07
15
9 c-
27
78
52
20
86
04
18
56
15
53
-------
100
Table 33
Benefit of a Fueling Station
Enforcement Program Begun January 1, 1984
In a Non-I/M Area with a
1% Random Roadside Inspection Program
Per Vehicle Reduction (January 1, 1988)
1% Random
Roadside
Inspection
Program
Narte
Air Pump
Only
Catalvst
Only
Fuel Inlet
Only
Plu-ibtesmc
Cnly
?. lumbtes-o
aFuel Inlet
Air Pur.p i
'^ £ ^ Ca ** S w
Air ?u-c &
~"uel rn 1 s t
i i »- Oi'T-C a
* «»^ - Jn^" 3
3 7 rjj^ £ - g S~ , 0
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1930-1983
1984 +
Pre-1980
1980-1983
' 0 C ^ i
* * V - '
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984-
in
Smi
ssions (mg/mi)
Licht-Du
Passenaer Car
HC
37.
55 .
29 .
37.
56.
29.
48 .
70.
34.
24.
36.
18.
23.
33.
16.
22,
33
16
49
/ ]
/ J.
35
3 ]_
47
25
27
40
21
10
69
38
83
72
85
88
89
83
99
C C
^ -^
22
06
62
,78
, 77
.19
. 55
.49
87
* w f
.40
, / i
.58
.17
.29
.96
.75
CO
285.90
437.09
225.42
292.11
446.04
229.39
402 .47
592.67
282.15
202.65
301.00
' 146.38
188.05
278.43
134.71
185.90
275.11
123.00
406 .69
-PC "0
286.13
244.54
373 .72
193.21
210 .41
321.64
166. 9e
(6000 IDS)
HC
18.
52.
47.
1 0
55 .
50.
25 .
74 .
67.
12.
' 37.
; 34.
12,
34,
- 31.
11
34
3,]_
26
j ^
68
i ;
45
41
13
38
35
17
75
87
19
71
51
71
65
74'
93
54
13
,00
,35
.73
.87
.46
.38
.16
. 96
.38
.71
.63
.52
.3 4
. / D
. 3 9
CO
145 .69
423.07
383.96
155.
450 .
408.
220 .
639.
580.
109.
317.
288 .
ioi.
296.
269.
100.
12
44
36
34
85
70
21
16
29
94
05
48
87
292.95
266.
223 ,
649 ,
588
126
366
333
*
107
311
284
7 1
,52
.08
. 5 3
.37
.99
.96
.10
.06
.09
tv Truck
s
(6000-8500
HC
2.63
26.12
58.92
2.77
27.58
62.15
3.72
36.96
83.38
1.87
18.59
42.03
1.74
17.26
39.09
1.72
17.06
38.66
3.78
^ "7 £ 1
ii'.75
2.27
22.59
5 "' "> 5
1.93
19 19
43.65
Ibs)
CO
21
209
472
22
223
502
3 ]_
316
714
15
157
354
14-
146
331
14
145
328
32
321
v 724
18
181
411
J. S
i 5 t
350
.07
.46
.55
.43
.01
.41
.86
.79
£ 3
. 0 C
.79
.02
.99
.74
.57
.96
.59
.04
.58
.32
. 36
. 12
.28
.69
; -7
* /
A C\
.00
.34
-------
101
Table 33 (continued)
Per Vehicle Reduction
1% Random
Roadside
Inspection
Pro-grain
Fuel Inlet
s Catalyst
Plumbtesrno
& Catalyst
Fuel Inlet
S Catalyst
& Air Pump
Plumbtesino
& Catalyst
&. Air Pump
Plumbtesmo
Fuel In-
let s
Catalyst
Plumbtesmc
&, Fuel In-
let s Air
Pump
Flumfastesrno
& Fuel In-
let &
Catalyst &
Air PUIT.D
in Emissions (mg/ni)
Affected
Light-Duty
Model Passenger Car
Years
Pre-1280
1980-1983
1984 +
Pre-1980
1980-1983
1984+ .
Pre-1.980
1980-1.983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
HC
41
60
29
36
52
25
41
60
29
35
52
25
35
51
25
26
39
21
34
50
25
.52
.23
.70
,09
.35
..91
.69
.47
.81
.85
.01
.75
.29
,19
,35:
.64
,99
.25
.99
.76
.15
CO
341
503
- 240
297
437
209
343
505
241
295
434
208
290
427
205
205
313
163
288
424
203
.92
.54
.60
.16
.66
.89
.37
.63
.53
.10
.68
.57
.58
.97
.38
.39
.98
.10
.00
.25
.72
(60
HC
21
63
57
18
55
50
22
64
58
18
54
49
18
53
49
12
37
34
18
52
48
00 Ibs)
.84
.42-
.74
.98
.12 -
34.
.08
.11
.35
.64
.13
.46
.56
.90
.2.5
.99
.74
.49
.13
.67
i =;
CC
187.
543.
494.
162.
472.
431.
189.
550,
500.
15?.
463 .
423.
1.59.
462,
422.
104.
302.
276.
155.
450.
411.
(
( !
19
62
90:
69
49
4.8
"5 n
w *>
00
59
54
36
35
08
03
16
27
83
76
16
62
99
Trucks
6000-8500 Ib
HC,
3.16
31.40
71.13
2.74
27.29
62.07 .
3.19
31.74
71.88
2.70
26.80
61.00
2.68
26.69
60.74
1.88
18". 6 9
42.54
2.62
26.08
59.40
CO
27
269
609
23
233
532
27
272
616
23
229
522
23
228
520
15
149
341
22
223
508
s)
.07
.14
.69
.53
.93
.09
.39
.30
.66
.07
,41
.13
.01
.75
,67
.08
.93
.37
.44
.10
.23
-------
102
Table 34
Benefit of a Fueling Station
Enforcement Program Begun January 1, 1984
In a Non-I/M Area with a
2% Random Roadside Inspection Program
Per Vehicle Reduction (January 1, 1988)
2% Random
Roadside
Inspection
Program
None
Air Pump
Only
Catalyst
Only
Fuel Inlet
Only
Plumbtesmo
Only
Plumbtesmo
uFuel Inlet
* * *- 'D\**-'-^ L
."*. * * %* 1 1 1 W *3
Catalyst
A.ir Puns &
Fuel Inlet
Air Pump &
Plumbtesmo
Affected
Model
Years
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1f\ f* A
j.984-1-
Pre-1930
1930-1983
1984 +
Pre-1980
1980-19 S3
1984 +
Pre-1930
1930-1983
«t {*> f*. i ,
i984-
Pre-1980
19 80-1983
1984-
Pre-1980
1980-1933
1984 +
Pre-1980
1930-1933
1984 +
in
Passencer Car
EC
37
55
29
33
57
30
48
70
34
23
34
17
21
30
15
20
30
14
49
72
35
29
44
23
23
34
18
.10
.69
.38
.13
.15
.05
.38
.89
.83
.91
.91
.47
.17
.77
.30
. 7 7
.16
.98
.75
.23
.62
.48
.22
.45
.23
.86
.63
CO
285
437
225
294
449
231
402
592
282
194
288
139
173
256
123
170
251
121
408
602
287
227
347
180
179
273
143
.90
.09
.42
.68
.74
.01
.47
.67
..15
.47
.33
.94
.82
. 44
.51
.78
.75
.09
. 51
* -i V
.74
. 41
.47
.07
.14
.81
.11
Emissions (me/mi)
Ligh
t-Du
(6000 Ibs)
KC
18.17
52.75
47.87
19.61
56.94
51.59
25.71
74.65
67.74
12.41
36.04
32,80
11.10
32.23
29.43
10.91
31.67
23.93
26.37
76.56
69.38
14.69
42.67
38.92
11.34
22.95
30 .29
CO
145.69
423.07
383
159
.96
.02
461.78
418
220
639
580
105
305
277
94
275
251
93
271
247
225
653
592
118
343
313
91
264
243
.33
.34
.85
.70
.14
.32
.88
.86
.48
.38
.34
.09
.43
.07
.56
.10
.37
.76
.52
.12
.66
.27
tv Trucks
(6000-8500
EC
2.63
26. 12
53.92
2.84
28.19
63.47
3 .72
36.96.
33.38
1.79
17.34
40.41
1.61
15.96
36.28
1.53
15.68
35.63
3 . 31
37.91
85.34
2. 13
21.13
47.98
1.64
16.21
37.43
Ibs)
CO
21.07
209 . 46
472.55
23
223
514
31
316
714
15
151
342
13
136
309
13
134
205
32
323
728
17
170
386
13
131
300
00
* w W
.62
.56
. 35 .
.79
.68
.20
.17
.31
.72
.39
.91
. 50
.22
1 S
. »
.57
.31
. 12
.19
.46
T g
* » w
. 03
.60
-------
103
Table 34 (continued)
Per Vehicle Reduction
in Emissions (-me/ nil)
2% Random
Roadside
Inspection
Procrain
Fuel Inlet
& Catalyst
Plunbte-smo
& Catalyst
Fuel Inlet
& Catalyst
& Air Pump
Plunbtesmo
&" Catalyst
«. Air Pump
Plumb-tesno
] Fuel In-
Catalyst
Pluizbtesino
& Fuel In-
let & Air
Pump
Plunbstesmo
& Fuel In-
let &
Catalyst &
Air Pump
Affected
Light-Duty
Model Passencer Car
Years
Pre-1280
1280-1283
1984 +
Pre-1280
1280-1283
1984 +
Pre-1280
. 1280-1283
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1280
1280-1283
1284 +
Pre-1280
1280-1283
1284 +
HC
38
55
27
30
44
22
38
56
21
30
44
22
22
42
21.
22
33
17
29
42
21
.48
.81
.61
.72
.67
.27
.72
.16
.76
.45
.18
.04
.66
.03"
.48
.31
.48
.93
.23
.42
.20
CC
316
466
223
252
373
180
313
469
224
' 250
262
178
244
3.59
174
172
262
137
240
254
171
.82
.62
.66
.53
.46
.43
.88
.58
.96
.61
.24
.56
.22
.76
.or
.04
.98
.67
.57
.42
.74
(6000 Ibs) 1
HC
20.24-
58.77
53.64
16.19
47.03
43.22
20.57
52.75
54.51
15.71
45.64
41.98.
15.60
45.. 31
41.62
-10.85
31.52 .
22.02
15.00
43.56
40 .14
CO
173.
503.
452.
138.
403.
370.
176.
51.2.
467.
124 :
390.
259.
133.
388.
357.
87.
253.
232.
128.
372.
343.
45
76
82
80
16
48
57
72
84
26
26
03
70
37
35
11
03
94
15
24
02
Trucks
[6000-8500 Ibs)
HC
2.92
29.10
66.14
2.34
23.29
53.40
2.98
22.58
67.20
2.27
22.59
51.82
2.26
22.43
51 . 5 3
1,57
15.61
5.88
2.17
21.57
49.64
CC
25.
249.
566.
20.
199 .
457.
25.
253.
576.
19.
193.
443 .
12.
192.
441.
12 .
125.
287.
18.
184.
424.
02
41
25-
07
6C
76.
s >
88
76
43
22
76
34
28
71
60
27
98
53
22
20
-------
104
Table 35
Benefit of a Fueling station
Enforcement Program Begun January l,
In a Non-I/M Area with a
1984
5% Random Roadside Inspection Program
Per Vehicle Reduction (January I, 1988
5% Random
Roadside
Inspection
Program
None
Air Pump
Only
Catalyst
Only
Fu.el Inlet
Only
Plumbtesmo
Only
Plumbtesmo
SFuel Inlet
Air Pump &
Catalyst
Air Pumc &
Fuel Inlet
Air Pump i
Pluinbtesrnc
Affected
Model
Years
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984-r
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1982
1984 +
Pre-1930
1980-1982
1984 +
Pre-1980
1930-1982
1984-
Pre-1980
1980-1982
1984 +
Pre-1980
1980-1983
1984 +
in
Emissions (mg/mi)
Passenger Car (
HC
37.10
55 .69
29 .38
38.59
57.31
30.34
48.38
70.89
34.82
22.22
22.27
16.17
18.26
26.26
12.02
17.68
25.47
12.57
50.17
72.92
25.96
26.02
39.03
20 . 82
16.94
25 . 42
13.87
CO
285
437
225
298
455
233
402
592
232
181
26S
120
151
222
106
147
215
102
411
607
290
200
306
1 "0
130
199
106
.90
.09
.42
.65
.48
.43
. 47
.57
.15
.30
.79
.09
.79
. 42
.39
.38
.60
.90
.49
.25
19
.89
.87
0 Q
.74
.84
. 6 5
K
18
52
47
20
58
53
25
74
67
11
33
30
9
28
25
-------
105
Table 35 (continued)
Per Vehicle Reduction
5% Random
Roadside
Inspection
Program
Fuel Inlet
& Catalyst
Plumbtesno
a Catalyst
Fuel Inlet
« Catalyst
&. Air Pump
Plurabtesmc
& Catalyst
& Air Pump
Plumbtesmo
& Fuel In-
et & '
"Catalyst
Pltnnbtesno
&. Fuel In-
let & Air
Pump
Plumbstesmc
& Fuel In-
let &
Catalyst &
Air Pump
in S
Affected
mission
s (mg/mi)
Light-Duty
Model Passenger Car
Years .
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
Pre-1980
1980-L983
1984 +
Pre-19-80
1980-1983
1984 +
Pre-1980
1980-1983
1984 +
EC
23
48
24
22
32
16
34
49
24
22
32
16
'20
30
15
15
23
12
20
29
15
.76
.98.
.41
.59
.79
.70
.11
.48
.63
.09
.08
.38
.95
.41
.57.
.60
.42
.85
.33
.53
.17
CO
278
409
197
186
274
135
280
413
199
181
268
132
172
254
125
120
184
98
167
246
122
.02
.52
.79
.02
.14
.44
.99
.81
.67
.77
.01
.75
.50
.23
.27
.43
.10
.81
,18
.57
.91
(6000 Ibs)
EC
17.
51.
47.
11.
34.
32.
18.
52.
48.
11.
32.
30.
11.
32.
30.
7.
21..
20.
10.
29.
27.
76
57
38
88
52
33
25
99
64
18
49
54
02
01
12
54
90
65
14
48
88
CO
152
442
406
101
295
277
156
455
417
95
277
260
94
274
258
60
175
165
86
250
237
.20
.09
.15,
.84
.92
.14
.72
.21
.73
.38
'.17
.59
.43
.42
.17
.56
.98
.88
.36
.99
.48
Trucks
(6000-3f
HC
2.57
25.53
58.54
1.72
17.09
40.18
2.64
26.24
60.07
1.62
16.09
38.00
1.59
15.85
37.49
1.09
10.84
25.72
1.47
14.60
34.76
:oo ii
CO
22
218
501
14
146
344
22
225
515
13
137
324
13
135
321
8
87
206
12
124
296
DS)
.01
,88
.80
.73
.51
.46
.67
.37
.93
.80
.23
.28
.66
,86
.32
.76
.13
.58
. 49
.26
.09
-------
1G6
References
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"Evaluation of the Applicability of a Lead-Sensitive Test
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Technical Report. Bill Smuda, U.S. EPA, I/M Staff.
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