GCA-TR-76-26-G
.VALUATION OF THE NEVADA
INSPECTION/MAINTENANCE
PROGRAMS
Final Report
by
Benjamin F. Kincannon
Alan H. Castaline
GGA CORPORATION
GCA/TECHNOLOGY DIVISION
Bedford, Massachusetts
August 1976
Contract No. 68-01-3155
Task Order No. 6
Technical Service Area 1
EPA Project Officer
Laurie Gresham
U.S. ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
-------
1744!
CONTENTS
Page
List of Figures iv
List of Tables v
Acknowledgments viii
Sections
I Introduction 1
II Technical Issues of Inspection and Maintenance 8
III Implementation Issues of I/M 34
IV Present I/M Program in Nevada 56
V Analysis of System Alternatives 68
VI Inspection and Maintenance Bibliography 86
Glossary 96
Appendix
A Number of Lanes and Facility Costs for Idle and Loaded
Mode Testing 101
iii
-------
FIGURES
No. Pa
1 Exhaust Emission Deterioration 24
2 Hypothetical Cumulative Probability Graph for Exhaust
Emissions 27
3 Overview of Inspection and Maintenance Program Issues 45
IV
-------
TABLES
No. P_a
1 Summary of I/M Program Contacts 5
2 Summary of Research by the Private Sector 6
3 Federal Agency Contacts 7
4 Manufacturers of Emissions Testing Instrumentation 7
5 Comparison of Short Test Procedures for Emission
Inspection 10
6 Comparison of Two Steady State Test Procedures 11
7 Idle Versus Loaded Mode Testing 13
8 Exhaust Analyzers Certified for Use in New Jersey 16
I
9 Criteria for Exhaust Emission Analyzers 17
' mvr
10 Operating Principles of Sun Exhaust Performance Analyzer
1 Model EPA- 75 20
11 Change of Emissions as a Function of Time, Percent 26
12 Typical Exhaust Emission Standards - Idle Test 30
13 Arizona Emission Standards 31
14 Locales Reviewing I/M 36
15 1974 Pollutant Concentrations for Cities with I/M Programs 37
16 Summary of I/M Programs 39
1? Expected Benefits of I/M Pilot Program 47
18 Public Relation Program 53
19 Quality Control Activities 54
-------
TABLES (continued)
No. Page
20 Exhaust Emission Standards 58
21 License Station Check List 60
22 Average Consumer Costs of the Current I/M Program 61
23 Survey Results of Emissions Reduction by Vehicle Model 52
24 Fuel Savings from Inspection/Maintenance Programs 63
25 Positive Aspects of the Existing Nevade I/M Program 64
26 Negative Aspects of the Existing Nevada I/M Program 65
27 Privately Run Stations - 120 Licensees (Vehicle
Population - 190,000) 71
28 Privately Run Stations - 200 Licensees (Vehicle
Population - 190,000) 72
29 Privately Run Stations - 315 Licensees (Vehicle
Population - 190,000) ^3
30 Annual State Administrative Costs for a Privately Run
Idle Mode System 74
31 Site Costs of a State Run Idle Mode System 75
32 Annual Administrative Costs for a State Run Idle Mode
System
33 Cost of a State Run Idle Mode System
34 Cost of a Contractor Run Idle Mode System
35 Costs Associated with a Contractor Run Loaded Mode
System
36 Consumer Cost of a Contractor Run Loaded Mode System
37 Average Repair Costs for Vehicles Rejected by Emissions
Testing
38 Estimated Potential Emission Reductions for Nevada
39 Summary"of I/M Alternatives for Clark County Nevada
vi
-------
TABLES (continued)
No.
A-l Number of Necessary Lanes for State or Contractor
Run System 101
A-2 Capital and Annual Operating Costs of a Single Lane
Idle Mode Facility 102
A--3 Capital and Annual Operating Costa of a Double Lane
Idle Mode Facility 103
A|-4 Capital and Annual Operating Costs of a Single Lane
Loaded Mode Facility 104
A-5 Capital and Annual Operating Costs of a Double Lane
Loaded Mode Facility 105
vii
-------
ACKNOWLEDGMENTS
Numerous persons and organizations have made significant contributions t
the overall study effort, and GCA/Technology Division wishes to sincerel
acknowledge their participation. On-going project supervision has been
received from Ms. Laurie Gresham, Project Officer, of EPA's Region IX Ai:
Programs Branch.
Specific thanks are due to Mr. E. "Curly" Silva of the State of Nevada's
Department of Motor Vehicles and Mr. Dale Reid and Mr. Chuck Thurston of
his staff for providing data on the current I/M program. Mr. Richard
Serdoz of the Nevada Air Quality Department and Mr. Ken Boyer, Executive
Secretary of the Nevada Environmental Commission also provided assistanc
on various matters throughout the course of the study. Finally, the
information provided by the various individuals and their organizations
mentioned in the text are deeply appreciated.
viii
-------
SECTION I
INTRODUCTION
ispection/iuaintenance programs are intended to reduce emissions from in-
;e vehicles by retarding emission deterioration. Increases of vehicular
lissions occur because of a combination of improper, inadequate and in-
requent maintenance. An I/M program is a way of insuring that motor
ihicles are properly operated and maintained and thus will emit less
jllutants.
ispection/maintenance is an integral part of the Federal Motor Vehicle
aission Control Program (FMVECP). As specified in the Clean Air Act of
970, the FMVECP enables the federal government to promulgate and regulate
Missions standards for motor vehicle emissions. Section 110 of the Act,
hich governs the content of the State Implementation Plan (SIP), deals
itlj I/M. I/M, unlike the FMVECP, has been established as an element of
he SIP. The state is responsible for the selection and implementation of
/M as a control strategy. In this manner, I/M will be implemented first
n areas with the most severe air quality problems to ensure that vehicles
aintain specified standards which complement the FMVECP.
'URPOSE OF STUDY
!he overall objective of this study is the analysis of the cost and
effectiveness of the present inspection/maintenance (I/M) program in
tevada and of alternative I/M programs for Clark County. The fulfillment
>f this objective involves two major tasks, each of which is discussed
ielow.
-------
The first task involves a detailed review of the current regulations for
the Nevada I/M program and of all associated test procedures and hardware
specifications. The product of this task is the identification of the
strengths and weaknesses of the current program including hardware selec-
tion, calibration practices, inspection procedures, and quality assurance
practices. Information on the present costs of the system are also
presented.
The analysis of alternative I/M programs is the subject of the second part
of the study. First, idle mode testing under three operational alternatives
(state run, contractor run, and privately run) is analyzed. Then a con-
tractor run system with key mode testing is reviewed. Each of the alterna-
tives is analyzed in terms of their cost, effectiveness, energy impacts,
and consumer protection features.
DATA SOURCES
The results of this study are based upon information obtained from govern-
mental and private sources. It was our goal to gather as much available
information as possible on both the technical and practical issues associated
with I/M. This information provides a perspective by which to evaluate the
present system in Nevada and also serves as an information source for
the assumptions made, and data used, in the evaluation of alternative
systems.
The following five avenues were used to obtain information:
1. General literature searches utilizing the facilities of
university, governmental and private literature retrieval
services.
2. Contact with agencies and individuals responsible for the
planning, implementation, operation and analysis of exist-
ing and proposed Inspection and Maintenance programs for
other locales throughout the nation.
-------
3. Communication with individuals at universities and private
facilities responsible for the conduct of research programs
involved with the technical issues surrounding Inspection
and Maintenance procedures.
4. Communication with government agencies responsible for
enforcement, technical and policy considerations of
mandatory inspection.
5. Communication with manufacturers of vehicle emission
inspection instrumentation.
Section VI presents the information sources used in the preparation of
this report.
The general I/M search utilized the services of the New England Research
Application Center (NERAC) Research Retrieval Services, environmental
journal indexes, abstracts from conference and professional society,
National Technical Information Service (NTIS) and university catalog
facilities. The material identified as most relevant to the current project
requirements was obtained, reviewed, and classified by issues. The result-
ing bibliography provides background material and analyses of existing
Inspection and Maintenance programs and related work performed by others.
The general literature search identified the existence of a number of
ongoing inspection programs, in addition to a few past and present pilot
or demonstration programs. The agencies responsible for these programs
were contacted for specific details on current operations. A summary of
the agencies contacted along with brief notes on the local programs is
presented in Table 1. Additional references discussed the merits and
demerits of the various programs.
Research being conducted by the private sector on I/M is presented in
Table 2. This literature was reviewed and supplemented by communication
with key staff members at the various research institutions.
Contacts with various officials of the federal agencies concerned with
vehicle emissions testing programs and the related issues of emissions
-------
testing provided information on the latest technical and policy ideas.
Table 3 lists the offices contacted and includes a brief synopsis of the
responsibilities of each. Official documentation of U.S. EPA sponsored
research program was obtained. In addition the material received includes
a compilation of I/M background material assembled through the joint action
of a consortium of U.S. EPA offices.
A representative sample of vehicle emission testing instrumentation manu-
facturers and suppliers were contacted. Table 4 lists the companies who
forwarded literature on their products. The purpose of the instrumentation
review was threefold. Firstly, data on the costs of equipment for the
various I/M program alternatives was requested. Secondly, information on
the operating principles and specifications was required to understand the
possible effects of equipment during the conduct of an I/M program. Last,
it was desirable to learn of the manufacturers' involvement in the develop-
ment of equipment for improved test reliability and increased processing
rates, especially for high capacity test lanes.
ORGANIZATION OF REPORT
The following sections discuss in detail the results of our analyses.
Section II presents the technical aspects of I/M including testing pro-
cedures, instrumentation, and the determinants of emission reduction.
Section III reviews the implementation issues associated with I/M and
presents information on what has been found in other states having I/M
programs. The analysis of the present program in Clark County is the
subject of Section IV, while Section V presents the analyses of alternative
I/M programs for Clark County.
-------
Table 1. SUMMARY OF I/M PROGRAM CONTACTS
Location
Program
Trenton, New Jersey
Bureau of Air Pollution Control
New Jersey Dept. of Environmental Protection
Phoenix, Arizona
Air Pollution Control Division
Department of Health Services
Portland, Oregon
Vehicle Emission Department
Oregon Department of Environmental Quality
Chicago, Illinois
City of Chicago
Department of Environmental Control
Cincinnati, Ohio
Air Pollution Control Division
Los Angeles, California
California Air Resource Board
State run, idle mode in-
spection, mandatory repair
and retest required state-
wide. Combined with safety
inspection.
Contractor run; loaded mode
| inspection. Marlcopa and
I Plraa Counties only. Manda-
i tory inspection 1/76. Man-
datory repair and retest
1/77.
State run, idle mode in-
spection. Portland Metro
Service District only
(approx. 3-county area).
Inspection required every
2 years. Certification of
compliance required for
registration renewal.
City run voluntary program,
idle test similar to CVS
Test. Program costs paid
through city registration
fees.
Annual mandatory I/M, idle
test, as of 1/75 combined
with City Safety Inspection.
Program operated by Depart-
ment of Public Utilitiss.
Only 40 percent of vehicles
have taken test. No en-
forcement to take test but
maintenance and retest
enforced.
Phasing in loaded mode,
state run I/M program.
Present - Riverside
Volunteer Program. 1977 -
Test at change of owner-
ship. Late 1970'a - Annual
j I/M for South Coast Air
I Basin. Current mandatory
i tune-up, statewide, at
I change of ownership.
j Highway patrol random
[ pullover inspection phased
i out during April 1975.
-------
Table 2. SUMMARY OF RESEARCH BY THE PRIVATE SECTOR
Organization
Research area
Environmental Activity Staff
General Motors Technical Center
Warren, Michigan
Exxon Research and Engineering Co.
Linden, New Jersey
Hamilton Test Systems
Phoenix, Arizona
Colorado State University
Fort Collins, Colorado
Clayton Manufacturing Company
El Monte, California
Automotive Testing Laboratories
Aurora, Colorado
Olson Laboratories, Inc.
Anaheim, California
Idle versus loaded mode testing.
Emission deterioration and engine
degradation.
Idle emission testing. Statistical
i analysis of emissions. Fuel economy.
! Engine malfunctions. Diagnostic and
j maintenance procedures. Mechanic
! training programs.
i
Contractor to State of Arizona.
j Development of instructor and mechanic
training programs and materials. EPA
supported.
Key mode engine evaluation system.
Emission deterioration and engine
degradation. Emission testing at
| high altitude.
I
i Emission deterioration and engine
degradation.
-------
Table 3. FEDERAL AGENCY CONTACTS
Office
Responsibilities
U.S. DOT National Highway Traffic
Safety Administration
Washington, D.C.
U.S. EPA
Office of Mobile Source
Enforcement
Washington, D.C.
U.S. EPA
Office of Transportation and
Land Use Policy
Washington, D.C.
U.S. EPA
Emission Control Technology
Division
Ann Arbor, Michigan
Conduct of Diagnostic Inspection De-
monstration Project. Objective is
to explore feasibility of using dia-
gnostic test devices to conduct dia-
j gnostic safety and emission inspec-
' tion (Refer to FR 40:113 6/11/75
p. 24904).
EPA policy branch. Conducting work-
shops on 1/M at Regional Offices.
Prepared summary of policy issues.
Refinement of Control Strategies for
In-Use Vehicles 11/72.
Technical issue analyses. Conducting
major study of I/M effectiveness,
emission deterioration. Involved with
analyses of correlating short tests
with Federal Test Procedures.
Table 4. MANUFACTURERS OF EMISSIONS TESTING INSTRUMENTATION
Manufacturer
I Location of branch contacted
Sun Electric Corporation
Atlas Supply Company
Hamilton Test Systems
Beckman Instruments, Inc.
Allen Test Products Division
Clayton Manufacturing Company
Stewart-Warner Alemite Sales Co.
Chicago, Illinois
Brockton, Massachusetts
Chicago, Illinois
Windsor Locks, Connecticut
Wakefield, Massachusetts
Needham, Massachusetts
North Bergen, New Jersey
Canton, Massachusetts
-------
SECTION II
TECHNICAL ISSUES OF INSPECTION AND MAINTENANCE
EMISSION TESTING PROCEDURES
The function of emission testing is to identify those vehicles which
fail to comply with established motor vehicle emission standards. These
vehicles are determined to exhibit the potential for significant emission
reductions upon application of specified maintenance.
The effectiveness of testing programs depends upon the ability of testing
procedures to distinguish those vehicles which exhibit high emission
characteristics from the entire vehicle population. The second require-
ment of the test procedure is that it produce results in a rapid and
efficient manner. The feasibility of such programs depends on the
attainment of large testing capacity while placing constraints on total
program costs.
Short emission test cycles have been developed to closely correlate with
the emissions measured during the Federal Test Procedure (FTP). The FTP
is generally applied to new vehicle certification. The FTP specifies
a seven-mode, seven-cycle process which is modelled after typical driving
cycles. This test is initiated with the vehicle at the cold soak con-
dition and requires nearly 14 hours for completion, which includes the
time required for the vehicle to sit to assure a true cold start.
The minimum requirement of an emission test is that it be short, appli-
cable to warmed-up vehicles and can identify the high emitting vehicles.
Two distinct emission testing procedures have been developed for
-------
measuring pollutants emitted through the vehicle exhaust system, which
satisfy these criteria. These test procedures are referred to as
idle mode and loaded mode testing. Loaded mode testing procedures can
be further divided into steady state or transient types. Table 5
identifies the major characteristics of the short test procedures.
Definition of Idle and Loaded Mode
For the purpose of this report further discussion will be limited to
the idle mode and loaded mode steady state (key mode) test procedures.
These are the only short tests that have been implemented in programs
directly affecting the testing of vehicles owned and operated by the
general public. However, variations exist in the exact definitions of
the testing modes among the agencies and organizations conducting I/M
programs or research. The definitions presented are based on a general
consensus.
The idle mode test is the test of the exhaust emissions with the vehicle
in a neutral gear operating at an unloaded state. Often HC and CO levels
are recorded at both a low and a high (or hot) idle speed. The test at
the low idle speed is taken at the manufacturer's recommended idle,
measured in revolutions per minute (rpm), then the engine speed is
increased to 2250 +10 percent rpm for the high (or hot) Idle speed test.
The standards must be met at both levels.
The loaded (or key) mode test is the test of the exhaust emissions with
the vehicle in a forward drive gear operating at a loaded state. Pollu-
tants are measured at various test conditions as specified by a testing
procedure. The loaded mode, steady state (simulated highway cruise)
test measures emissions at high cruise, low cruise, and idle. Emissions
are not tested at the transient modes of acceleration and deceleration.
Table 6 compares two steady state procedures. A chasis dynamometer is
utilized to apply the desired loads to simulte driving conditions.
-------
Table 5. COMPARISON OF SHORT TEST PROCEDURES FOR EMISSION INSPECTION
Short test
Idle
Loaded mode
Shorter urban test
.cycles (New Jer-
sey ACID cycle,
We Quick Cycle)
Longer urban test
cycles (e. g. , EPA
short test cycle
and single cycle
of the seven-mode
hot start)
Cycle description
Idle in drive and/or
freevheeling at
2500 rpm
Steady-state at high
cruise, low cruise
idle in drive
Consist of acceler-
ations, cruise, de-
celerations, and
idle in drive
Seven to nine modes
including combina-
tions of accelera-
tion, cruise, de-
celeration, and idle
Cycle test
time
< 60 sec
60 sec
60 to 80
sec
124 to 137
sec
Kumber of
technicians
required
1 or 2
2
2
2
Special test
equipment
required
None
Chassis dynanometer
(single power ab-
sorption curve)
Chassis dynanotneter
(variable Inertia
and power absorp-
tion with automa-
tic test settings)
Same as above
Inst rumentation
required
HC and CO exhaust
gas analyzers
HC, CO, and NOX
exhaust gas
analyzers
CVS sampling sys-
tem - HC, CO,
and NO gas
analyzers with
computerized
data reduction
Same as above
Applications to date
N.J. Test lane;
Portland, Ore. ,
Chicago, Cincinnati,
Calif .-roadside:
Calif. -end of
assembly line
Arizona, Riverside,
Calif. , Washington,
D.C. test lanes
End of assembly line
testing by EPA and
Calif. ARB
-------
Table 6. COMPARISON OF TWO STEADY STATE TEST PROCEDURES
st
eral
ee
e
yton
e
Vehicle weight
class , Ibs
Below 2500
2500 - 3500
3500 - 4500
Above 4500
Below 2800
2800 - 3800
Above 3800
Transmission
range/gear
Drive or 3rd gear
for 30 raph test
Drive or high gear
Drive or high gear
Drive or high gear
In lower gear (3rd)
Drive or high gear
Drive or high gear
High speed
cruise
Speed
mph
50
50
50
50
36 - 38
44 - 46
48 - 50
Load
hp
21
26
31
36
14
23
29
Low speed
cruise
Speed
mph
30
30
30
30
22 - 25
29 - 32
32 - 35
Load
hp
9
12
15
18
5
9
11
Idle
mode
Automatic
transmission
in neutral
Automatic
transmission
in drive
key
Source: "Description of short tests" fact sheets. Supplied by Peter Hutchins, Characteriza-
tion and Application Branch, Office of Mobile Air Pollution Control, U.S. EPA,
Ann Arbor, Michigan. June 1976.
-------
Idle Mode Versus Loaded Mode Testing
In the past I/M had been considered as a typical TCP strategy to produce
additional emission reduction. It is now considered as an essential
portion of the motor vehicle control program. The reason is that tune up
components (carburetor, etc.), tend to deteriorate and cause an increase
in emission, rather than breakdowns in the emission control equipment.
Although loaded mode testing is regarded as slightly more effective and
more beneficial to the vehicle owner, an idle mode test is a viable method
for identifying vehicles with high emission levels.
Loaded mode testing is a better indicator because testing simulates actual
driving conditions. Although the correlation between either idle or
loaded mode with the Federal Test Procedure (FTP) is not well established,
loaded mode test is characterized by a greater correlation factor. The
ability of the loaded mode test to produce better diagnostic information
on engine maladjustments and malfunctions-^* 4,5 and its ability to identify
high emitting vehicles, creates the potential for greater total emission
reduction when compared with the idle mode test procedure.
Idle mode testing is not without advantages, however. The idle mode test
is simpler to perform and requires less technician training. Inspection
lanes utilizing idle testing would have a greater annual capacity and thus,
costs per vehicle inspection would be lower. Another significant aspect
is that public acceptance may hinge on the ability of the repair industry
to guarantee the effectiveness of the repairs. This would prove costly if
the industry were to invest large sums to install dynamometers and related
equipment.
Table 7 summarizes the advantages and disadvantages of idle and loaded
mode testing procedures mentioned above. The U.S. EPA and private
12
-------
Table 7. IDLE VERSUS LOADED MODE TESTING
Advantages
Disadvantages
Idle mode
testing
Loaded
mode
testing
2.
3.
Simple test procedure
which requires minimum
training
Adjustments can be made
during test
Diagnose some maladjustments
and malfunctions
Can be duplicated by either
public or private test
systems.
Requires minimal test time
and equipment j
Engine operated under simu-
lated road cruise conditions
Includes idle test
Additional diagnostic infor-
mation to repair facility
Test cycle repeatable; no
test requirement at ac-
celeration or deceleration.
3.
4,
Malfunction that occurs
under loaded conditions
may not be detected
Poor correlation between
idle and FTP CVS emis-
sions
Requires dynamometers
and other additional
equipment
Test cannot be dublicated
in most repair facilities
due to lack of dynamo-
meter
Requires more test time
Uncertain correlation
between loaded test and
FTP CVS emissions
13
-------
research organizations have found idle mode testing to be almost as
effective as a loaded steady state test in identifying gross emitters,
and thus a viable inspection technique.1»2,3 jn summary, the fact that
the loaded mode test is slightly more effective does not diminish the
importance of idle mode testing programs.
VEHICLE EMISSION TESTING INSTRUMENTATION
The selection and approval of motor vehicle emission testing instrumenta-
tion is dependent upon the mode of inspection chosen. It can be seen
from the previous section that the instrumentation requirements are
greater for loaded mode testing. This is due primarily to the necessity
of a chassis dynamometer to stimulate on-road driving conditions. The
actual emission testing instrument need not vary except for alternatives
in the sophistication of the operation of the I/M program selected.
Exhaust Gas Analyzers
The exhaust gas analyzer is central to the objectives of an Inspection
and Maintenance program. The instrument must be reliable and be easily
calibrated in order to assure the quality of emission testing. A further
consideration is that the accuracy and repeatability within an inspection
network and agreement with the repair industry diagnostic readings is
imperative to system efficiency. The repair industry is developing
diagnostic information from the testing programs utilizing the emissions
analyzers to check and set basic adjustments on the motor vehicle engine.
The use of the basic analyzer is quite simple. The probe is inserted
into the vehicle tailpipe. Two meters located on the face of the instru-
ment, one measuring carbon monoxide and the other measuring hydrocarbon,
indicate the pollutant concentration emitted through the exhaust. The
potential for significant variability in the recorded levels exists
among instruments, either by the same or different manufacturers.
Because of this variability, basic specification criteria have been
14
-------
developed to minimize the effects. Although the instruments may be
designed to operate within the desired specifications, they require
proper maintenance and calibration to insure quality readings.
Various agencies have performed analyzer certification programs. The
approved list of instruments is being distributed to the repair industry.
Table 8 presents the New Jersey list of approved emission analyzers.
Among the established specifications were the following areas:
Range
Sensitivity
Accuracy and repeatability
Response time and hang up
Warm-up time
Calibration
Table 9 presents the entire list of criteria for exhaust emission
analyzers developed as a result of another program. The latest
analyzer models on the market appear to easily satisfy these criteria,
as manufacturers continue to develop the state-of-the-art.
Operation Principles of Exhaust Analyzer
The analyzing devices used to test vehicle emissions measure carbon
monoxide expressed as percent of CO in air and hydrocarbons as hexane
expressed as parts per million (ppm) of hexane In air. The devices
operate on the nondispersive infrared principle.
Some manufacturers had utilized luft or microphone types which are being
replaced by the use of optical infrared filters. The microphone type
uses the infrared absorbing gas as an infrared selector and detector,
while the use of solid state detectors have been made possible by the
introduction of an optical filter for obtaining selectivity. The
microphone instrument utilizes a hot filament as the source of infrared
energy. The optlca. infrared filter instruments use a variety of
15
-------
Table 8. EXHAUST ANALYZERS CERTIFIED FOR USE IN NEW JERSEY
Supplier
Model
Allen Electric Company
American Motors Corporation
American Parts Company
Atlas
Autoscan, Incorporated
Barnes Engineering Company
Beckman Instrument Company
Chrysler Corporation
Ford Motor Corporation
Kal-Equip
Marquette Manufacturing Corporation
NAPA Balkamp
Horiba Instruments Limited
Peerless
Stewart-Warner
Sun Electric Corporation
Womaco-Yanaco
i Emission Analyzer Model 23-060
I series and 23-070 series
A Mserv Model 23-067 series and
23-077 series
Powerready Infrared HCKO Analyzer
I Model 370-400
Exhaust Emission Tester Model 340
CO and HC Analyzer Model 710
I and 4030
I
Emission Analyzer Model 8335
i HC/CO Vehicle Emissions Analyzer
! Model 590
Technician Service Equipment
j Program; Model DCE-75, 23-066
j series and 23-076 series
I
| Rotunda Equipment Program;
1 Rotunda Analyzer Model BRE-42-730
and BRE-42-731
[ HC/CO Infrared Emissions Analyzer
jModel 4094-C
I Emissions Analyzers Model 42-151
| and 42-153
i
j Infrared HC/CO Emissions Analyzer
i Model 14-4787
i Engine Exhaust Analyzer Models
I CSM-300 and Mexa-300
! Infrared Exhaust Gas Tester Model 600
i Infrared Gas Analyzer Model 3160-A
| Sun EET-910, U-912, U-912-I, and
! EPA-75 Exhaust Emission Testers
Exhaust Gas Analvzer Model EIR-101
16
-------
Table 9. CRITERIA FOR EXHAUST EMISSION ANALYZERS'
Characteristic
Target
CO range
Scale divisions
HC range
Scale divisions
Meters
Accuracy
Repeatability
Warm-up time
Response time
Purge time
Stability
Calibration
Flow meter or alarm
Condensate trap
Particulate filter
0-10%
0.2 above 1%
0-2000 ppm
20 or 50 ppm
Minimum size 8 inches on a side
No static interference
Below mid range: + 0.25% CO, +50 ppm HC
Above mid range: + 0.5% CO, +100 ppm HC
Within accuracy limits for minimum 6 mos.
Less than 30 minutes
Less than 10 sec for 90% reading
Less than 30 seconds
Zero setting: less than 2% FS drift in
8 hours
Span setting: less than 2% FS drift in
8 hours
Maximum 2 adjustments/day
Hold to targets with frequent temperature
fluctuations
Capable of external gas calibration
Rapid internal calibration with controls
on front panel
Capability of calibration with probe in-
serted in tailpipe
Equipped
Capable of complete condensate removal
Self dumping
Easy cleanout
Easily replaceable
i Infrequent replacement
17
-------
Table 9 (continued). CRITERIA FOR EXHAUST EMISSION ANALYZERS'
Characteristic
Target
Sample line
Sample probe
Moveable cart
Minimum 20 feet long
Low HC adsorption
I Flexible and strong
I
30 inch flexible metal hose or reinforced
joint where flexible hose joins rigid
pipe
j Device to hold probe inside tailpipe
i
; Equipped
Sensitivity to line voltage None to normal fluctuation
Response to HC classes
Response to interfering gases
18
-------
standard infrared detection sources such as thermopiles, thermistor,
and lead selenide. The advantage of the optical filter type detector
is its longer life and its power to minimize interference from carbon
Q
dioxide (C02) and water (H20).
Table 10 is a reproduction of the operating principles of the Sun
;1
9
TM
Electric Corporation's Exhaust Performance Analyzer Model EPA-75,
presented here as an example of the operation of one model.
Equipment Sophistication
In those programs where the inspection of vehicles is conducted by the
private automobile repair industry, the cost of the emission analyzers
must be kept relatively low since none of the private garages could
expect trade in sufficient volume to properly amortize large capital
investments. The prices of the equipment listed in Table 9 generally
fall in the range of $1500 to $2500. Other programs such as in
New Jersey where the state operates test lanes for the sole purpose of
vehicle inspection, equipment specifications tend to be much more sophis-
ticated. The equipment used for a state run idle mode test costs in the
vicinity of $20,000 per lane. Cost of equipment for a loaded mode test
as used by Arizona is nearly double, due to the high price of a dynamometer.
The exhaust analyzers used by state run facilities are identical to those
purchased by the private repair stations. The difference lies in the
add-on devices specified by state requirements. These specifications are
required to adapt the instrumentation to the demands of a high-volume, short
test time condition. Safety and convenience factors are also considered
in the final design. A sample of the modification to the standard test
instruments follows:
Redesign of probe and probe handle to assist rapid inspection.
Fail test lights that are energized when emissions exceed
the standard.
19
-------
Table 10. OPERATING PRINCIPLES OF SUN EXHAUST
PERFORMANCE ANALYZER MODEL EPA-75y
The EPA-75 is a nondispersive Infra-Red gas analyzer which operates on the
principle of absorption of specific wavelengths of infrared energy by CO
and HC (as N-Hexane) present in the sample exhaust stream. It uses a
dual-beam analyzer with separate air reference and sample cells mounted on
a single frame to provide great stability to the system. At one end of
the frame is an infrared heat source operated by 115-volt AC, 60 Hz elec-
tric power. A prefocused concave mirror reflects the energy from the
source which is chopped by a motor operated chopper, which also controls
reference and signal synchronization LED devices.
At the opposite end of the frame, a second reflective mirrored surface
focuses the transmitted energy through two optical filters sensitized to
transmit energy at wavelengths in the CO and HC spectrums of interest onto
two lead selenide detectors.
Mr in the sample cell allows maximum chopped energy to be transmitted
through the cell and on through the optical filter to the CO and HC de-
tectors. Passage of exhaust gases through the sample cell absorbs infra-
red energy in the spectrum of the wavelength of interest, reducing the
energy available to the CO and HC detectors, depending upon the concen-
trations of the two gases in the sample stream. The detectors thus pro-
vide an alternating current signal proportional to the amount of energy
absorbed at the chopper frequency.
The signal from each lead selenide detector is then fed through its own
preamplifier and on through separate processing channels to the meters for
display.
The, reference signal from the LED is synchronized with the signal passing
through the air reference cell to the detector. This electronically clamps
the detector reference signal to a ground reference.
Automatic Gain Control circuits detect and feed a signal back through an
optically-coupled isolator circuit to control the sample signal levels for
each channel at a convenient voltage. This signal is by-passed to a solid-
state operational amplifier. At this point the zero potentiometers on the
front panel can be rotated to adjust the meter pointers to zero.
The signal synchronization output is finally fed to a Field Effect Transis-
tor switch which permits the sample signal to be integrated and read out
on the meter.
20
-------
Thermostat and heater to provide constant Internal temperatures
for winter operations.
A screen filter to remove particulate matter from the exhaust gases.
Other changes include redesign of control panel and meter faces to facili-
tate operation and interpretation of results. Some systems also include
a diagnostic printout of the engine malfunctions most likely contributing
to a specific vehicle failure. Portland, Oregon makes use of a computer
system to store vehicle standards to automatically compare with test
readings. A printout of the test and diagnostic results is supplied to
the vehicle operator while also providing a storage bank of test results
for program analyses.
Sophistication in emission testing instrumentation and procedures is a
function of volume of vehicles to be tested. State test lanes are designed
to handle efficiently and effectively on the order of 2500 vehicles each
month. The private service stations cannot be expected to inspect more
than 5 percent of that total (as a rough estimate), due to the constant
use of their facilities for regular vehicle repairs. Since the sole
purpose of the state lane is for the inspection of vehicle emissions
(and safety, in some cases) specification for convenience, speed, and
diagnostic information as a motorist aid is imperative.
Summary
The requirements of an emission test procedure are that it be quick
(2 to 3 minutes), applicable to warmed-up vehicles (condition at time
of inspection) and capable of identifying a large percentage of high
emitters (correlations with FTP emissions). Emission analyzing equip-
ment reliability is imperative to accomplish -hese tasks. Additionally,
it is desirable to achieve the repeatabilitv 'f -.est results. Thus the
operating characteristics of the equipment TTL L :?et basic criteria to
insure duplication among manufacturers' proc-:.',«.
21
-------
DETERMINANTS OF EMISSION REDUCTION
Emission reductions achievable from an Inspection and Maintenance program
are dependent upon program characteristics. The issues range from the
effectiveness with which testing procedures can identify and diagnose
vehicles with excessive emissions to the ability of the repair industry
to perform required maintenance to reduce emissions from the rejected
vehicles. These program parameters can be classified as either
exogenous or endogenous. The issues mentioned above are primarily
exogenous, that is they can not be varied by adjustments to the internal
program design. Selection of test type and instrumentation was previously
discussed while other exogenous issues vill be discussed further in the
next section on implementation issues. Implementation issues, in
general, affect emission reduction by such means as consumer education,
mechanic training programs, and by the selection of the motor vehicle
population to be covered by the test.
The technical issues are endogenous to the design procedure because they
can be adjusted within the program to affect the operation and thus the
net emission reduction. These issues include the frequency of test
(inspection interval), the exhaust emission standards (failure criteria),
and the rejection rate (percent failed). These criteria determine the
emission reduction based on the emission characteristics of the motor
vehicle populations and the rates of emission deterioration and engine
degradation.
Emission Deterioration
There are two considerations to take into account when evaluating the
effect of emission deterioration:
The increase in emissions which normally takes place
(normal engine degradation without I/M)
The rate of emission increase between inspections both for
vehicles which passed tbe_original inspection and for
vehicles which required maintenance
22
-------
The net emission reduction is the difference between the reduced emis-
sions from the repair of rejected vehicle and the normal emission deteriora-
tion of all vehicles.
Deterioration studies such as that conducted by Olson Laboratories^, which
examined emissions from repaired vehicles, have shown that emissions return
to pre-adjusted levels fairly rapidly. The purpose of maintenance is to
retard the rate of engine degradation and resultant exhaust emissions.
However, maintenance only has short term effects on emission deterioration.
It does not negate the need for future inspection and regular maintenance.
Typically, emissions rates are regained and suppassed in about 6 to 9
months.11>12,13 Figure 1 is a plot of emission deterioration from one of
these studies.l^ These curves depict the time interval in which post-
tune-up emissions deteriorate to pre-tune-up levels. Once pre-tune-up
levels are reached, further maintenance is required to offset continued
deterioration.
The primary objective of the Olson Laboratories Study was threefold;
determine the effectiveness of an I/M program and a
mandatory maintenance program considering the degrada-
tion factors associated with each.
f determine the rate of exhaust degradation in the California
population if no I/M program is instituted
compile the above information on a vehicle sample repre-
sentative of January 1975.
The research program organized the test vehicles into four groups.
Three of the four groups received various degrees of maintenance during
the program period. The four groups are as follows:
1. Control group - monitored normal emission deterioration,
vehicle tested only at beginning and end of program
2. Inspection group - vehicles only given repp.ir required to
pass inspection, maintenance-only at beginning and end.
23
-------
to
5.00
4.50
4.00 h
0 50
i
0
CARBON MONOXIDE ~
...I..
3
b=BEFORE TUNE-UP
a =AFTER TUNE-UP
...J -I .-1 I...... J J -4
4 5 6 7 8 9 10
ELAPSED TIME, months
500
450
400
350
300 §
250
200
150
100
50
u
o
i
Ul
2
\Z
Figure 1. Exhaust emission deterioration
12
t ',
-------
3. Manufacturer's Specification group - restorative maintenance
to original performance conditions.
4. Mandatory Maintenance and Parameter Inspection group - mainte-
nance consisted of mandatory replacement of tune-up components.
Parameter inspection consisted of replacement of other devices
to meet original performance conditions.
Vehicles were tested at 0, 1, 3, 6, 9, and 12 months, as shown in
Table 11. Table 11 presents the changes in emissions over the test
period. Emissions at approximately the 9 month interval have returned
to the levels of the "As Received" inspection. As stated previously,
one-time maintenance will not eliminate the need for future inspection
and regular maintenance.
Corrective actions can reduce deteriorating emission levels. An I/M
program would identify those vehicles most in need of maintenance and
supply that maintenance. As a result the tuned vehicle will emit less
pollutant emissions for some period of time until deterioration effects
gradually cause greater emission levels.
Criteria for Offsetting Emission Deterioration
The test frequency, exhaust emission standards and the rejection rates as
previously introduced are the design criteria which affect net emission
reduction. As explained above, the emission deterioration rate is a
prime consideration: otherwise extreme overestimating of program effect-
iveness and misdesign would result.
Deterioration studies have shown that a semiannual inspection interval
could be warranted on the basis of minimizing emissions. However, con-
siderations of test capacity costs, operation mechanisms and program
acceptance support the selection of an annual inspection interval. Annual
inspection is generally selected for I/M, as experienced by existing
programs. Thus for fhe remainder of this discuss ion an annual inspection
interval is assumed most effective.
25
-------
Table 11. CHANGE OF EMISSIONS AS A FUNCTION OF TIME, PERCENT
13
N)
Pollutant
Hydrocarbon
Carbon monoxide
Group
1
2
3
4
1
2
3
4
As
received
-
27.1
11.7
25.7
-
17.3
24.1
38.0
oa
0
0
0
0
0
0
0
0
m(
1
-
-1.1
-1.2
1.4
-
2.4
-0.6
-1.3
ma
1
-
1
2
4
-
4
6
3
[nterval after
Lntenance (month)
3
-1.1
8.9
2.8
-
1.8
0.6
8.2
6
-
11.0
2.0
26.2
-
12.6
6.2
11.2
9
-
22.6
16.6
10.9
-
16.3
13.5
16.2
12
28.9
47.7
26.9
57.8
10.8
24.9
12.9
25.1
After
final
maintenance
1.0
6.2
3.8
12.6
-8.2
2.8
-3.5
0.6
Normalized reference
-------
The exhaust emission standards and the rejection rate are related in that
the standards are developed to achieve a desired emission reduction by
identifying an estimated quantity of vehicle as high emitters. These
vehicles make up the fraction of failed vehicles, those requiring main-
tenance to comply with the standards, otherwise referred to as the de-
signed rejection rate.
A number of factors constrain the selection of a rejection rate and thus
the development of emission standards. Figure 2 shows a hypothetical
cumulative probability graph of exhaust emissions. The rejection rate
range is denoted by the vertical lines. The extreme limits reflect the
minimum and maximum reasonable rates. The maximum rate must consider such
circumstances as incremental benefits to emission reductions and burdens
on repair facilities. The minimum rejection rate must at least reject
the high emitting vehicles. This limit is based on a graphical interpre-
tation of the inflection point of the rate of increase of emission levels
with vehicle population.
HIGH
EMITTING
LfMIT
CONSTRAINED
RANGE
FOR REJECTION
3ATES
10
20 30 40 50 60 70
POPULATION, p«rc«nt
90 100
Figure 2. Hypothetical cumulative probability graph for
exhaust emissions
27
-------
High emitting vehicles when tuned have exhibited reduction of over
50 percent. Obviously vehicles in lower decile groups will show a
less dramatic reduction. The point to be made is that the range of
acceptable rejection rates is determined at the lower end by the high
emitting vehicles while the highest acceptable rejection rate is a
function of economic considerations. The failure of relative low emit-
ting vehicles, while fostering some emissions reduction, would not be
advantageous at the margin. That is, the marginal benefits in terms
of emission reductions would be of less than the marginal cost associ-
ated with correcting the operating deficiencies in these vehicles.
Frequency of inspection and the vehicle emission standards of an I/M
program can be adjusted to compensate for one another. The basis for
establishing these two technical variables is a function of the total
desired emission reduction (the I/M strategy can achieve up to 40 percent
annual pollutant reduction from LDV exhaust as related by the current CO
reduction potential of the Arizona program) and the rate of emission de-
terioration and engine degradation. Reasonable limits, however, serve to
constrain the selection of these criteria for the development of an ef-
fective and feasible program.
Review of Criteria for Existing Programs
To achieve the greatest reduction possible from I/M, the testing of motor
vehicles should be completed every 6 months. However, as can be seen
from Table 12, annual inspection is generally chosen. In fact, no per-
manent program has been implemented using the 6 month interval. The
major reason is that a 6 month schedule is highlv noncost-effective.
Besides, an efficient mechanism exists for the conduct of the required
paper work and enforcement, on an annual basis. This is the motor
28
-------
vehicle registration renewal process. Those systems utilizing this pro-
cess will not permit vehicle owners to renew their registration until
their vehicle complies with the applicable emission standard.
Exhaust emission standards can vary based upon desired reductions. New
Jersey (see Table 12) has developed a three-phase approach, gradually
stiffening the standards. Their rejection rates (percent of vehicles
failing test) increased from an initial 10 percent to 20 percent during
the middle phase and is expected to reach 33 percent with the implementa-
tion of the Phase III standards. Nevada's standards are the same as the
Phase III New Jersey levels, except for the newer vehicles model years.
However, effectiveness of the Nevada program at the present time, in terms
of percent emission reduction, is significantly lower than in New Jersey
due to the fact that not all vehicles are inspected nor are vehicles
inspected on a yearly basis.
The exhaust standards for Chicago, Illinois; Cincinnati, Ohio; and Port-
land, Oregon (idle test programs) are slightly more stringent in com-
parison to the 1977 New Jersey standards. Portland, Oregon has devised
a system of standards that vary with make and year of vehicle, model type,
engine size and, for 1975 and 1976 vehicles, presence or absence of a
catalytic converter. One example is shown in Table 12. Because of the
variations in standards, Portland's program is considered by some as the
most equitable since variations in emission characteristics have been found
among vehicle makes and engines. These three programs were designed to
fail approximately 33 percent of the vehicles tested. (Cincinnati is not
meeting its designed rejection rate due to enforcement difficulties.)
Arizona has the only mandatory loaded mode I/M program in the country.
Its emission standards are shown in Table 13. Because of the nature
of the testing procedure (i.e., simulated road cruise conditions), ex-
haust standards are required to be met at three cest conditions, high
and low cruise and idle The idle standards ar<= slightly less stringent
29
-------
Table 12. TYPICAL EXHAUST EMISSION STANDARDS - IDLE TEST
UJ
o
V
17)!)
t-lil
' a
Locale
ida
~innati
Jersey
tland, Ore.
anda^'s vary
1th snake,
<)<)!>] , U'l- i «ht ,
in )" ; ; i ons
q:, ipuient)
e fxainple
hown)
nfleet)
Model year
Pre-1968
1968-1969
1970
1971 and later
Pre-1968
1968-1969
1970-1974
1975 >
Pre-1968
1968-1969
1970-1974
1975 ->
Ford
1975 Noncatalyst
catalyst
1972 1974 6&8 cyl.
1972-1974 4 cyl.
1971-1973 Capri
1970-1971
1968-1969
Pre-1968
Pro. -1968
J968--1969
1970-1974
1975 ->
CO, percent
7.5
5.0
4.0
4.0
6
5
4
1.5
7/72 2/75 1/77
10.0 8.5 7.5
8.0 7.0 5.0
6.0 5.0 4.0
3.0 2.0
Enforcement
Base std. tolerance
1.0 0.5
0.5 0.5
1.0 1.0
2.0 1.0
2.5 1.0
2.0 1.0
3.5 1.0
6.0 0.5
6.0
5.0
4.0
1.5
HC, ppm
1200
600
400
400
1000
600
500
250
1/Z1 2/75 1/22.
1600 1400 1200
800 700 600
600 500 400
300 200
Enforcement
Base std. tolerance
175 50
100 50
300 200
400 200
500 2°0
600 200
Varies Varies
1000
600
^00
.00
1
Frequency
of test
Change of
ownership
Annual
Annual
Biannual
Annual
Rejection
rate,
percent
Effective
rate
33
20
12/20/33
33
30
-------
Table 13. ARIZONA EMISSION STANDARDS
Type
4-stroke
4-stroke
4-st roke
4 -stroke
4-stroke
4-stroke
4-stroke
'; --:i - .>kc-
?.-st:roke
Vehicle
model
year
All
1975
and
newer
1972 Co
1974
1972 to
1974
1968 to
1971
1968 to
1971
1967 and
older
1967 and
older
All
Vehicle curb
weight, pounds
Less than 2,000
Greater than
2,000
Greater than
2,000
Greater than
2,000
Greater than
2,000
Greater than
2,000
Greater than
2,000
Greater than
2,000
All
Number of
cylinders
All
All
4 cylinders
or less
More than 4
cylinders
4 cylinders
or less
More than 4
cylinders
4 cylinders
or less
More than 4
cylinders
All
High cruise
mode
HC, ppm
700
100
380
300
450
380
1,000
700
23,000a
CO, %
8.6
0.9
3.0
2.50
3.75
3.00
5.00
4.25
8.0
Low cruise
mode
HC, ppm
120
380
300
450
380
1,000
700
CO, %
1.0
3.50
3.0
4.25
3.50
6.00
5.25
Idle mode
HC, ppm
1,050
150
450
350
500
450
1,300
950
23,000a
CO, %
7.5
1.5
5.5
4.0
6.0
5.50
9.50
7.75
6.0
as propane equivalent gas. All other HC values measured as N-Hexane.
Note: Projected rejection was 35 percent, but 47 percent of vehicles were actually falling in
early stages of the program.
-------
compared to the other programs (Table 12). While the cruise mode
standards are generally more rigid than the other programs, Arizona's
program was designed to reject about 35 percent of the vehicles tested
but in actual operation nearly 50 percent are failing. Arizona is pre-
sently analyzing their program in order to adjust the standards to their
original estimates.
32
-------
REFERENCES
1. Panzer, J. Idle Emissions Testing - Part II. Esso Research and
Engineering Co. Linden, N.J. Paper Presented at the Automotive
Engineering Congress, Detroit, Michigan. SAE Paper No. 740133.
February 1974.
2. General Motors Positions on Motor Vehicle Emission Inspection
Procedures. February 28, 1975.
3. Personnal Communications with Mr. Richard Penna. Office of Mobile
Source Enforcement, U.S. EPA, Washington, B.C. May 20, 1976.
4. Clayton Blue Book - Papers Germane to Mobile Source Emission Con-
trol Through Corrective Action. Clayton Manufacturing Company.
El Monte, California.
5. Personnel Communications with Mr. Max Moore. Project Manager
Dynamometer Group. Clayton Manufacturing Company, El Monte,
California. June 3, 1976.
6. A Review of Control Strategies for In-Use Vehicles. The Aerospace
Corporation and the U.S. EPA. Publication Number EPA-460/3-74-021.
Prepared for U.S. EPA, Ann Arbor, Michigan. December 1974.
7. Panzer, Jerome. Idle Emissions Testing. Esso Research and
Engineering Co., Linden, N.J. SAE Paper No. 720937. November 1972.
8. Andreatch, A.J. and J.C. Elston. Evaluation of Idle Inspection and
Maintenance Equipment Network. Department of Environmental Pro-
tection, New Jersey. Presented at Automotive Engineering Congress
Detroit, Michigan. SAE Paper No. 740134. February 1974.
9. Sun Product Technical Data and Specifications, Exhaust Performance
Analyzer Model EPA-75. Sun Electric Corporation. Chicago, Illinois.
10. Communication with Company A.
11. Panzer, Jerome. Idle Emissions Testing - Part III. Esso Research
and Engineering Company, Linden, N.J. Paper presented to Annual
APCA Meeting. Paper Number 74-130. June 1974.
12. Caprarotta, Gary L. and Douglas J. Orf. An Investigation of Motor
Vehicle Emissions Deterioration Through Idle Icr.ssions Testing.
Regional Air Pollution Control Agency, Dayton. Ohio. Paper Pre-
sented at Annual APCA meeting. Paper Number "'-*2. 2. June 1975.
13. Degradation Effects on Motor Vehicle Exhaust Emission. Olson
Laboratories Inc. Anaheim, California. Prepared under Contracts
ARB 3-199 and 3-584 for State of California Air Resources Board.
March 1976.
33
-------
SECTION III
IMPLEMENTATION ISSUES OF I/M
The Federal Motor Vehicle Emission Control Program (FMVECP) was devised
to promulgate and regulate emissions standards for motor vehicle emis-
sions. The federal government began setting emission standards for
automobiles with the 1968 model year. (The State of California began
2 years earlier.) The enabling legislation for the FMVECP is the Clean
Air Act of 1970.
The FMVECP regulates emissions but other programs are required to assure
that vehicles meet the specified standards. Four programs are available
at the present time for controlling vehicle emissions. The first three
listed below would be implemented by the Federal Government.
1. Certification Program certification of new vehicle
prototypes to show they are designed to meet emission
standards.
2. Selective Enforcement^Amiiting assembly-line testing
to assure that production copies of certified vehicles
meet standards when new.
3. Recall require manufacturers to recall vehicles types
found through in-use surveillance to fail standards
because of defects in design.
The objective of these programs is to provide consumers with automobiles
which will continue to meet emissions standards if the vehicle is properly
maintained and operated. It is the manufacturers' responsibility to pro-
vide vehicles with emission control devices with minimal defects. This
is not to say that vehicles are either pollution-free or maintenance-free.
Cost considerations preclude such "ideal" vehicles.
34
-------
The federal enforcement programs do not guarantee that in-use vehicles
meet emission standards. In fact, many in-use vehicles are not meeting
2
standards for various reasons. These are presented below:
1. Not all vehicles can be inspected at the end of the
assembly line. Vehicle types that pass certification
and the Selective Enforcement Audit may be produced
within reasonable tolerances but still result in many
vehicles not meeting standards.
2. Many in-use vehicles are found to be tampered with.
Emission control equipment or adjustments are dis-
connected or varied to affect vehicle performance.
3. Many owners do not properly maintain their vehicles.
Vehicles which are set to manufacturers specification
would be low emitters.
Inspection and Maintenance, the fourth program for controlling vehicle
emissions, would ensure that motor vehicles are properly operated and
maintained. In addition, I/M would be useful for support data for
initiating recalls.
A REVIEW OF AREAS REQUIRED TO IMPLEMENT I/M
The federal government has delegated the responsibility to implement and
operate I/M to the states. Several state or substate areas have already
implemented such programs, while several other locales have plans underway
to establish inspection and maintenance.
Table 14 lists those states and cities at various stages of review or
implementation. As shown by this table, I/M has been included in the
State Implementation Plan of 19 states and the District of Columbia. A
majority of the states have at the minimum initialed preliminary review
of the requirements of such a program, and areas in five states have fully
implemented I/M. Pilot or demonstration programs have been or are
presently being conducted at five additional locations. Other areas
such as Denver. Colorado have performed considerable research including
the design of a pilot program to be established in the near future.
35
-------
Table 14. LOCALES REVIEWING I/M
State City
i
Alaska j Fairbanks
Arizona | Phoenix
! Tucxon
California Los Angeles
San Diego
San Joaquin
j San Francisco
! Sacramento
Colorado Denver
Connecticut All
Illinois Chicago
Indiana Indianapolis
Maryland Baltimore
Massai husetts Boston
Springfield
New York New York City
New Jersey All
Nevada Las Vegas
Ohio Cincinnati
j D/iyton
Oregon Portland
Pennsylvania Philadelphia
Pittsburg
Rhode Island All
Texas Houston
Utah Salt Lake City
Washington Seattle
Spokane
- District of
i Columbia
Strategy Preliminary
requirement review or Pil
| SIP research prog]
X
XXX
XXX
1 X X X
: X X
: X X
i X X
' X X
X X
; x X
' x x
X X X
X
X X
X X
; x x x*
i X X X
x x : x
J I
X '
X ; X X
x
1 X ;
' X X :
x :
' X
3t I/M
ram Implementation
f ' ' ' " ~' '
: x
x
t
i
i
i x
3
x
i x
X
; x x '
: x x I
x x : xb
; i
"Loaded mode test for Medallion taxis.
bFundinK by National Highway Traffic Safety Administration (NHTSA) of the U.S.
Department of Transportation. A program to establish emission inspection
criteria for motor vehi-> diagnostic Inspection. (Funding also to
Alabama, Arizona, Puerto fico, am1 Tennessee)
36
-------
Table 16 presents a Summary of Inspection and Maintenance programs.
This table compares the five fully implemented programs, the California
proposed program schedule, and the current Nevada program in Clark County.
The service area defines the boundary within which registered vehicles are
affected. As can be seen, this ranges from a one county area to the entire
State of New Jersey. The frequency of tests discussed previously in this
text is generally on an annual basis.
The vehicle population is the number of vehicles registered in the service
area less any applicable vehicle exemptions. Further discussion on
these topics is included later in this section. The requirement serves
as a comment on the enforcement capabilities of the program. The test
type identifies the mode of testing used as defined previously. Lastly,
the organization denotes the sector which administers the test to the
public. A discussion of the advantages and disadvantages of the various
program organization alternatives follows.
ALTERNATIVE PROGRAM ORGANIZATION CONCEPTS
There are five basic inspection and maintenance alternatives for effecting
controls on the emissions from vehicles exhausts. These I/M programs are:
State/city I/M operation
Random pullover
Contractor I/M ooeration, surveillance by state
Franchised private garages I/M operation, surveillance
by state
Mandatory maintenance, responsibility of vehicle owner,
surveillance ':."
All program types '- '-« been implemented.
38
-------
The ten areas which have initiated at least a pilot program have ex-
perienced violations of the NAAQS for Carbon Monoxide and Photochemical
Oxidants. Table 15 lists the highest and second highest recorded con-
centrations for the Carbon Monoxide (8-hour average) and the Photochemical
Oxidants (1-hour average) which was measured during 1974 within each area.
Table 15. 1974 POLLUTANT CONCENTRATIONS FOR CITIES WITH I/M PROGRAMS
1974 Carbon
monoxide concen-
tration 8-hour
average, mg/m3
1974 Oxidant con-
centration 1-hour
average, yg/m3
State
Arizona
California
Illinois
Indiana
Nevada
New Jersey
New York
Ohio
Oregon
City
Phoenix
Tucson
Riverside
Chicago
Indianapolis
Las Vegas
Reno
Entire state
New York City
Cincinnati
Portland
(Vancouver)
District of
Columbia
<
High
25.0
11.4
16.0
; 21.1
,
! NA
-
i 16.3
!
' 17.5
i 31.4
32.1
' 10.7
! 14.8
; 10.0
Second high
22.6
11.4
15.7
21.1
NA
16.0
16.4
29.9
29.6
10.3
13.7
9.6
High
373
294
744
321
317
316
NA
452
362
215
NA
NA
Second high
275
274
666
268
315
310
NA
407
358
186
NA
NA
Note: NA Data rot available.
National Ambien: A: r Quality Standards:
Carbon monoxide 8-hour average = 10 mg/nr
Oxidant 1-hour average = 160 jjg/m.
Source: U.S. EPA Yonitcring and Air Quality Trends Report, 1974.
37
-------
Table 16 presents a Summary of Inspection and Maintenance programs.
This table compares the five fully implemented programs, the California
proposed program schedule, and the current Nevada program in Clark County.
The service area defines the boundary within which registered vehicles are
affected. As can be seen, this ranges from a one county area to the entire
State of New Jersey. The frequency of tests discussed previously in this
text is generally on an annual basis.
The vehicle population is the number of vehicles registered in the service
area less any applicable vehicle exemptions. Further discussion on
these topics is included later in this section. The requirement serves
as a comment on the enforcement capabilities of the program. The test
type identifies the mode of testing used as defined previously. Lastly,
the organization denotes the sector which administers the test to the
public. A discussion of the advantages and disadvantages of the various
program organization alternatives follows.
ALTERNATIVE PROGRAM ORGANIZATION CONCEPTS
There are five basic inspection and maintenance alternatives for effecting
controls on the emissions from vehicles exhausts. These I/M programs are:
State/city I/M operation
Random pullover
Contractor I/M operation, surveillance by state
Franchised private garages I/M operation, surveillance
by state
Mandatory maintenance, responsibility of vehicle owner,
surveillance by state.
All program types have been implemented.
38
-------
Table 16. SUMMARY OF I/M PROGRAMS
to
Locale
Nevada
A r i zona
Oregon
New Jersey
CM -.iyjo
(.: if),- i vnat i
G.J > v Cornia
Service area
1 county area
2 county area
3 county area
State
City
1 county area
South coast
air basin
Frequency
of test
1.0. c
1 yr
2 yr
1 yr
1 yr
1 yr
f
Vehicle
population
200,000
1,100,000
600,000
3,800,000
1,000,000
500,000
6,600,000
Vehicle
exemptions3
2,3,5,6
1,2,4,5,6
1,2,3,4,5
1,2,3
NA
NA
2,3,5,6
_. _~_ .... _ -i
Requirement"
M
M
M
M
V
M<1
f
Test
type
Idle
Loaded
Idle
Idle
Idle
Idle
f
Organization
Private Garage
Contractor
State
State6
City
Public
utilities
State
Vehicle exemption code
1. new vehicles (first registration)
2. weight limits
3. ' motorcycles
4. special registrations
5. age limits
6. other
b.
M
Ma
:,o\ y , V - V')! < mtary.
T.r.msf c.,: of ownership
with no enforcement equals voluntary.
JV'rsey allows reinspection of failed vehicles at private, state-licensed repair facilities.
. fV» ii'a; mandatory lune-up at change of ownership required statewide.
; .- 'V-.se I/M progr-im for S.C.A.B.:
i'l.as'- 1: Riverside Pilot Program (120,000 vehicles)
:'«;,.sft 2: Change of ox^nership (1,000,000 vehicles)
Plirise 3: Mandatory annual loaded mode (6,600,000 vehicles).
-------
Evaluations of the relative effectiveness of the various I/M alternatives
generally conclude the greatest emissions reductions to be achievable
through a state operated or contractor I/M program.3 Random pullover is
found to be almost completely ineffective, given the small percentage of
the total vehicle population covered each year. Random pullover requires
that the ability of the locale to meet ambient air quality standards be ,
based on the dual probability that high-emitting vehicles will be selected;
at random, and that the psychological reaction of the vehicle-owning
i
population will be able to undertake emissions-related maintenance even
though any individual vehicle may be stopped only once every 10 years.
Unfortunately the vehicle manufacturers' maintenance schedule is typically
not followed. Random pullover is also more difficult to enfore.
Mandatory maintenance programs are not as desirable as traditional in-
spection and maintenance programs for the primary reason that it is dif-
ficult to ensure that the work performed on the vehicles is done properly.
The advantage of I/M is that emissions analyses are used to verify that
the desirable effect in emissions is realized.
Emissions testing can be implemented to complement existing safety inspec-
tion programs. Only relatively minor costs for equipment and training
would be required to add emission testing to safety inspection programs,
whether the safety program is conducted at state test lanes or at private
service stations. Selection of an I/M alternative would be strongly
influenced by existing safety inspection configurations.
Other considerations, however, need be reviewed prior to final selection.
Advantages associated with the private garage approach are:
Inspection and maintenance can be performed at one station
for greater convenience to the vehicle operator. Large
number of stations also means greater cortvenience in travel;
Vehicle owners can utilize stations familiar with the opera-
tion of .;->o:lr particular vehicle;
40
-------
Minor adjustments can be completed at time of inspection;
No major capital expenditure is required for constructing
state test facilities. (A single state facility could
serve as a training center and complaint and check center.)
The disadvantages of such a program are:
The application of pass-fail criteria might not be interpreted
uniformly, thus program subjected to abuse.
The facilities might not have sufficient capacity to inspect
and repair the anticipated demand, resulting in a low and
inefficient processing rate; large number of stations
required.
Frequent use of highly trained and paid mechanics to perform
tests that require a lower skill level;
Limited to idle mode testing by economic considerations;
Tendency of mechanics to optimize performance, and not
minimize emissions, may lead to excessive and costly
maintenance;
Data handling and reduction more cumbersome.
In a state operated program, inspection test lanes designed for testing
capacity handles a large demand which offsets the large initial capital
costs. The advantages of an efficient state test lane operation include:
Trained personnel to provide uniform test results, capable
of making diagnostic recommendations to help reduce the
occurence of excessive repairs;
Ability to monitor the repair and maintenance industry;
Lower costs to vehicle owner;
Data handling and processing controlled by Computer
operations: also minimized due to. fewer collection
points;
Potential quality control greatest as a result of
uniform saecialized test centers;
41
-------
Increased test options since capacity allows cost-
effective use of loaded mode testing which provides
valuable diagnostic information.
The major disadvantage of state test lanes would be experienced by the
owners of vehicles which fail to comply with the standards. This group
must make arrangements for vehicle maintenance at private service stations
and then return for retesting. In addition, the state must initiate sig-
nificant initial expenditure of state funds for capital investments re-
quirements. Construction and implementation would require a long lead time.
Selection of contractor operated test lanes, avoids the potential problem
of legislating a significant sum of public funds. The contractor program
would achieve the same advantages as the state-run program. In addition,
the contractor test lane program would provide the following advantages:
Stimulation of the local economy by the capital investment
made by the contractor.
Industry operation more efficient; flexible decision making
capability and experience of program operations.
The disadvantages, besides the costs of the state administrative functions,
include the inconvenience in terms of additional travel for those con-
sumer's vehicles which fail test, and the longer lead time for construc-
tion and implementation.
PROGRAM DIMENSIONS
Test lane capacity requirements are a function of the program dimensions.
The program dimension is defined as the effective vehicle population
that is the vehicle population registered within the service area that is
required to comply with the applicable emission standards.
42
-------
Service areas are defined by easily distinguished limits such as a city
(Chicago) , a county (Clark County) , an Air Quality Control Region (Fnoenix-
Tucson Intrastate AQCR) or a State (New Jersey) . In general the I/M pro-
grams established or planned to date, are for areas with the most severe
air pollution problems. These are identified by AQCR boundaries in the
State Implementation Plans (SIP) .
There are several reasons for exempting certain vehicles from an I/M
program. Some of these are listed below.
Reduce potential hardships to owners of older vehicles or
special purpose vehicles. (Age limits or special
registrations)
Eliminate the potential of effecting the value and glamour
of antique vehicles. (Special antique exemptions)
Reduce testing capacity requirements by restricting effec-
tive vehicle population. (Weight limits)
Optimize cost-effectiveness by restricting effective
vehicle population. (Registration of new
vehicles)
Table 16 includes a summary of the program dimensions for several
programs .
PHASING OF PROGRAM IMPLEMENTATION
An I/M program involves a number of planned phases for proper implementation.
1. Initial planning
2. Design and operation of a pilot or
3. Analysis of pilot project and planning for full-scale
program.
4. First stage (Partial) Operation
5. Second stage (Full) Operation.
A3
-------
Strict adherence to the above steps is not imperative, but this or other
phasing schemes are valuable in that they provide a orderly progression
for consideration of a wide variety of program issues.
Initial Planning
A number of basic elements should be reviewed and studied for compatibility
with existing local programs and regulations. Figure 3 sketches the
Requirements and Approaches of the major issues and their influences on
the program.
Among the most important decisions are the initial definitions of the
program dimensions, the type of approach and organization to be selected,
and the type of test mode to be employed. These decisions determine
facility and instrumentation requirements, which in turn influence the
cost and effectiveness of the program.
The second group of considerations includes the determination of the en-
dogenous variables. These parameters have a major influence on net emis-
sion reductions as discussed in Section II. The selection of testing
frequency, rejection rates and emission standards will be based on pre-
liminary studies and incorporated in the subsequent design of a pilot
operation. Adjustments in these parameters may be required its a result
of an analysis of the technical and socioeconomic impacts of the pilot
program. Opportunities for adjustment exist at other stages or implementa-
tion, but ideally the program design should be established prior to full-
scale implementation. Other influences besides net emissions reduction
include capacity requirements, costs, and emission reductions on a per
vehicle basis.
The last consideration involves the actual impler.entPtior. pr^gtams which
are to be designed to achieve public acceptance. Successful implementation
44
-------
I.
II.
in.
IV.
VI.
VII.
Issues
Program ^.
i) imenslons
1
Approach ^^____^
and v^^
ory.an lzatiori^XssN_
1^*
Tea t mode y»
and ^--^^^^
J na t r unientat ion""*
i
Test . 9
f req
jency v.
^*
standards
and
reject Ion
rates
\
_!.._' » onK'n ^ a 1 1 OTT - -j>
\
\ ^
\
\
-------
hinges upon development of appropriate regulatory requirements for attain-
ment of adequate authority and provisions for program operation. Quality
control programs serve to educate the public and the automobile repair
industry on the benefits of I/M. Mechanic Training and licensing programs
tend to minimize the occurence of unnecessary repairs as only mechanics
qualified and knowledgeable in the performance of emission maintenance
would be licensed. Data handling and analysis provisions aid continued
program monitoring and provide a basis for necessary adjustments. A
strong and continuous public relation program including explanation of
technical material, release of program accomplishments and identification
of consumer complaint channels is a requiste for public acceptance.
Full-Scale I/M Phasing
This phase includes those steps which follow the initial planning require-
ments. The first step in this phase is a pilot program. This serves to
test planning decisions and to collect data on the emission characteristics
of the local vehicle population. In addition, it provides information on
the feelings of consumers. The benefits of a pilot program are presented
in Table 17.
Later steps involve analyses of the pilot program to provide adjustments
to the planning of the full-scale program. At this time the issues re-
viewed during the initial planning would be once again reviewed based on
the local input obtained from the pilot program.
After a pilot program, the full-scale I/M program can be implemented,
preferably in two steps. The first stage (partial) operation could
require only inspection and not maintenance. The maintenance require-
ments would be incorporated during the second stage. A second alternative
could be the New Jersey plan where the emission standards are being grad-
ually stiffened while requiring maintenance during all phases.
The California experience provides one scenario of an Implementation
phasing program.
46
-------
Table 17. EXPECTED BENEFITS OF I/M PILOT PROGRAM
Cost Determination
A. Cost comparison of various organizational approaches
B. Development of full cost model
C. Development of inspection fee structure
II Skill and Training Requirements
A. Instrumentation operation
B. Emission Maintenance
C. Data recording and handling
III Public Acceptance
A. Explain emission testing requirements
B. Explain program benefits
C. Consumer protection
IV Characteristics of Vehicle Population
A. Emission levels
B. Rejection rate
C. Maintenance requirements
D. Costs of maintenance
E. Exemption requirements
V Enforcement Requirements
A. Vehicle compliance
B. Instrument calibration
C. Repair activities
D. Quality assurance
47
-------
California Implementation Phasing Program
California has led the nation by 2 years in the use of emission control
devices (ECD) on new automobiles. I/M as a control strategy is intended
to check the deterioration of the engine and the ECD's. For the past
5 years, the State has required all vehicles that are to undergo transfer
of ownership to receive a tune-up prior to registration by the new owner.
This amounts to approximately 2.2 million vehicles statewide complying
with the required mandatory tune-up provision.
The California legislature in 1973 mandated an I/M program for the South
/
Coast Air Basin. More than 50 percent of the state motor vehicle popula-
tion is registered in this area. Air quality in this region may be the
worst in the nation due to its geographic and meteorologic influences.
The I/M program is to be implemented by three phases. The first phase,
a pilot program in Riverside, is nearing completion. Data from this
source plus testing by independent labs under contract with the California
Air Resource Board will be used to establish vehicle emission standards.
Additional experience and public awareness has been obtained through a
random pullover inspection conducted by the California Highway Patrol
in the South Coast Air Basin which was phased out during April 1975. The
second phase of the current program will require I/M for vehicles which
are to undergo transfer of ownership (identical to the Clark County,
Nevada program) and will eliminate the need for the state tune-up program
for these vehicles in the S.C.A.B. Additionally, the implementation of
this phase will accomplish four tasks:
1. Further promotion of I/M to public;
2. Achievement of a larger data base and experience;
3. Time for gradual construction of an I/M test lane
network with adequate capacity to test all vehicles;
4. Time for service industry to develop expertise in
emission maintenance and to provide adequate facility
capacity.
48
-------
The last phase will be a fully operational annual state-run loaded
mode vehicle emission inspection and maintenance program for the S.C.A.B.
CONSUMER ACCEPTANCE
The need for consumer confidence in an inspection and maintenance program
is obvious. The fact that such a program affects individuals' automobiles,
their second most expensive durable good, underscores the necessity of
public acceptance. Therefore, a special emphasis must be attached to this
area of concern.
A strong and continuous public relation program combined with an equally
strong program to guarantee equality and quality is requisite to the
gaining and the holding of the public trust. The public must be protected
from those who would exploit such a program (i.e., charging exorbitant
prices for repairs or performing unnecessary repairs). Also, a mechanism
must exist for the public protection of potential harmful government
regulations (i.e., vehicle registration cannot be prohibited without
due cause).
Arizona and Cincinnati provide examples of the effects of public reactions.
Arizona is utilizing a phase-in implementation schedule. Presently, in-
spection only is mandatory. Exhaust emissions standards were based on a
pilot program and developed to reject one-third of the vehicles. In
actuality, nearly one-half the vehicles are being rejected, an obvious
underestimate of the pilot program data. Another problem is the low key
public relations. Many people contend that they were never informed of
the program, while maTV do not see the need for I/M because of Arizona's
reputation for clea-< air and clear skies (despite air quality data con-
firming violations of carbon monoxide and oxidant National Ambient Air
Quality Standards). Further reasons for mistrust have occurred. First
registration renewal f-jras for a recent month were distributed nearly
2 weeks late. The vehicle owner was then left with only 2 weeks to
inspect his vehicle and file for renewal. The governor was forced to
49
-------
extend the deadline, because long delays were being experienced at the
testing centers. Maintenance and retest would have required much more
additional time. It is reasonable to assume that the 30-day normal
period between arrival of the forms and the renewal deadline would not
permit sufficient time. The Portland, Oregon program allows 3 months
for I/M and retesting.
In Cincinnati, I/M was implemented immediately (one step), with no period
for public familiarity. This schedule did not allow for sufficient lead
time to implement a PR program. This fact and the lack of enforcement
resulted in a situation where only 40 percent of the vehicles in the city
were tested. (The City of Cincinnati has conducted a safety inspection
program for 35 years, the only city in Ohio to do so.) Two inspection
lanes were constructed for emission testing in the surrounding county
but were closed after 6 months since only 2000 vehicles were tested.
Of the 500,000 vehicles in the city and the county, only about 100,000
were subjected to the emissions test. Enforcement exists for those
vehicles who fail the test in Cincinnati. They must be repaired and
retested in order to obtain a city certification. But those vehicles
that are not tested need not comply with the standards. Enforcement
is difficult since Cincinnati vehicles are not easily distinguished from
other vehicles. Rejection rates were initially set at approximately
30 percent, but have fallen to about 20 percent.
These two examples show the importance of a PR program and of proper
implementation scheduling and phasing. In addition, the nonequality of
enforcement in Cincinnati has hindered the effectiveness of the safety
program since more and more vehicle owners will not subject their
vehicles to the testing. Safety and air quality benefits are being
ignored by the public. Arizona's major problems are due to carelessness
and neglect. As a result, the Arizona legislature is considering mod-
ification or repeal of the I/M legislation.
50
-------
These situations could be tempered if proper mechanisms for quality
checks were established. Other problems which could have occurred
have not due to proper planning. The following discussion will review
those items that are essential if public confidence in I/M is to be
achieved.
The goal of every I/M program besides its objective of emissions reduction
is the repeatability of test results. Tests conducted at one facility
by one inspector should be able to be duplicated by another inspector at
another facility. To assure repeatability of testing, uniformity in
the type of equipment and the training of inspectors is of the utmost
importance. Instrumentation is selected and approved as discussed in
the previous section on hardware. The exhaust gas analyzer should be
calibrated with span gas periodically, typically specified as at least
once every 30 days (Nevada Regulations 11.9, Step 2). In addition the
instrument should be calibrated for drift prior to each test. Computer
operations can be programmed to perform the latter calibration for state
lane systems.
The training of inspectors falls into two categories. The first is the
state lane inspector. This individual is licensed by the locale to perform
vehicular emission tests. He must prove his competence by completion of
a training program or examination. The training program would cover such
topics as the operation and care for the inspection instrumentation, type
and operation of emission control devices, engine components which contrib-
ute to the emissions of HC and CO, and other test procedures; for example,
safety and smoke detection. An EPA sponsored program at Colorado State
University has developed and is constantly refining a course for the
training of Instructors.1*
The private service station inspector is the second group. Typically,
these inspectors would be the mechanics who work regularly at these
automobile repair facilities. The Colorado State University program is
51
-------
also applicable for this group. In addition, Exxon has developed an
emission related engine diagnostic procedure for its mechanics. The
technique allows the repairman to use the emissions data obtained on the
inspected vehicle to identify and repair the malfunctions. Exxon mechanics
in New Jersey were offered the training course free of charge.
The preferred testing program would have central lanes constructed for
the sole purpose of vehicle inspections. All the inspectors would use
identical equipment and would have undergone identical training. Private
mechanics would use equipment from various manufacturers and would tend
to produce erratic test results. A central lane system would maximize
the potential for repeatability of test results.
A public relations program would consist of three major activities, as
listed in Table 18. Public information advertising would serve the
purpose of explaining the testing program, interpretation of its result
(use as a diagnostic tool) and benefits to air quality and fuel conserva-
tion. This activity would also be directed toward consumer protection.
It could inform the public of the benefits of the attainment of multiple
estimates and of the recognition of mechanic training certification.
A consumer protection mechanism must be established to handle inquiries
and complaints from the public. This activity could be responsible for
certification of mechanics and facilities. The consumer education
material developed as discussed above would also be a function of this
section of a PR program.
An I/M program should not cause undue public hardship. Certain classes
of vehicles may require an exemption. Typical vehicle exemptions were
listed in Table 16. In all cases, a successful program hinges on the
cooperation among all the agencies and facilities concerned with any
aspect of inspection and maintenance.
52
-------
Table 18. PUBLIC RELATION PROGRAM
Public information advertising
1. Explain need and air quality and fuel conservation benefits
2. Explain testing procedure
3. Explain interpretation of test results engine malfunctions
cause failure
4. Explain consumer protection rights
5. Protection against unnecessary repairs; benefits of multiple
estimates and recognition of mechanic training certification
II Consumer protection activities
1. Mechanic and facility certification and behavior
2. Consumer complaint mechanism
3. Consumer education
4. Exemption classifications
III Cooperation among I/M personnel
1. Implementing agency
2. Inspection centers
3. Mechanic and repair facilities
QUALITY CONTROL PROGRAMS
Quality control programs are required to sustain reliability in the
functions of an I/M program. Each aspect of the program demands con-
tinued monitoring in order to provide a quality product.
Quality begins with the development of well-thought-out thorough legisla-
tion which establishes the legal authority to develop operating rules
and regulations. These rules and regulations would determine program
issues, objectives snd enforcement activities. Table 19 lists the
major program issues identified earlier and their associated objectives
within the overall framework. The quality control actix'ities applicable
53
-------
to each is also presented in Table 19. This table exhibits that
the key to a creditable program is the development of specific quality
control activities designed for the individual parameters. An effective
program, the objective of any operation type, would be measured on
public acceptance as well as benefits to air quality.
Table 19. QUALITY CONTROL ACTIVITIES
Program issue
Objectives
Quality control activity
II
Dimensions
Performance of
I/M
Test all applicable
motor vehicles
Identify high emit-
ting vehicles and
repair
III Instrumentation Emission analyzing
IV Test frequency
V Emission stan-
dards and re-
jection rates
VI Implementation
VII Operation
Net emission
reduction
Emission reduction
per vehicle
Public acceptance
Effectiveness
Enforcement through reg-
istration process or
window sticker system
Inspector training and
licensing. Mechanic/
garage training and
licensing. Surveil-
lance programs. Pub-
lic education programs,
Equipment certification.
Calibration methods.
Data monitoring
Data monitoring and sur-
veillance for program
effectiveness
Public education program
I Rules and regulations
54
-------
REFERENCES
1. Shutler, Norman D. Overview of Inspection and Maintenance. Paper
presented at the Fourth North American Motor Vehicle Emission Con-
trol Conference. Sponsored by STAPPA. Anaheim, California.
November 5-7, 1975.
2. Personal communication with Mr. Richard Penna. U.S. EPA Office
of Mobile Source Enforcement. June 1976.
3. TRW. Inspection/Maintenance of Light-duty Vehicles in the Denver
Air Quality Control Region. November 1974.
4. Gillaspy, Roy. Motor Vehicle Emission Control Instructional
Material. Colorado State University. Paper presented at the
Fourth North American Motor Vehicle Emission Control Conference.
Sponsored by STAPPA. Anaheim, California. November 5-7, 1975.
5. Panzer, Jerome and Hugh F. Shannon. Effectiveness of Maintenance
in Reducing Emissions. Exxon Research and Engineering Co. Paper
presented at the Third Annual North American Motor Vehicle Emis-
sions Control Conference. San Antonio, Texas. September 25, 1974.
55
-------
SECTION IV
PRESENT I/M PROGRAM IN NEVADA
PROGRAM BACKGROUND
The State Implementation Plan adopted by Nevada in 1971 included a number
of measures designed to reduce carbon monoxide and hydrocarbon emissions
to enable attainment of the national ambient air quality standards for
carbon monoxide and oxidants in Clark County. Among the measures was an
annual automotive inspection testing certification program administered
jointly by the Nevada Environmental Commission and the Department of Motor
Vehicles.
In September, 1974, the Environmental Commission promulgated final regula-
tions outlining a motor vehicle inspection and maintenance program. In
July, 1975, the program was amended by the State Legislature to require
emission inspections only for change-of-ownership vehicles. The Legislature
also directed the commission to study implementation and maintenance costs
of a compulsory annual inspection/maintenance program.
If inspection/maintenance is to develop into a viable measure of the
State's control strategy, it is imperative that the study examine not only
the actual costs, but also the air quality benefits of an. inspection/
maintenance program.
56
-------
TECHNICAL PROGRAM ELEMENTS
The present I/M program in Clark County is a hot idle test administered by
stations licensed by the Emission Control Section of the Department of
Motor Vehicles. All light-duty vehicles which change ownership are re-
quired to be tested prior to being registered by the new owner. Through
May, 1976, 107,850 vehicles have been tested by the 125 certified in-
spection stations.
The testing of a vehicle is an eight-step procedure. The steps, as they
appear in the State of Nevada Air Quality Regulations, are as follows.
Step 1: The motor vehicle manufacturer's emission control specifi-
cations manual or other approved reference shall be consulted to
determine the required emission control devices and performance
specifications for the specific vehicle. The following motor ve-
hicle manufacturer's specifications shall be recorded:
Ignition timing
Idle setting (rpm)
PCV valve required
Engine identification type CID CYL
Model and year of vehicle
Dwell or air gap
Cost of adjustments and parts
Step 2: The exhaust gas analyzer shall be calibrated prior to the
inspection of each vehicle and the calibration reading recorded
on the certificate of compliance. The exhaust gas analyzer shall
be calibrated with span gas at least once every thirty (30) days.
Step 3. Connect the ignition timing device and idle setting device
(rpm) and set vehicle to manufacturer's recommended emission control
performance standards.
Step 4: With the vehicle in neutral gear, all accessories off,
handbrake secured, accelerate engine to greater than 2,250 rpm and
observe for visible smoke in the exhaust emissions and crankcase
emissions.
Step 5: Any vehicle required to have a positive crankcase ventila-
tion valve shall be inspected to see that the system is connected
and operating. The inspection shall consist of a check of crank-
case depression by means of a vacuum gauge placed over the oil filler
opening. A negative pressure at manufacturer's recommenced idle-
engine speed shall be required in order to pass inspection.
57
-------
Step 6: With the engine running at manufacturer's recommended idle,
insert sampling probe of exhaust gas analyzer into the engine ex-
haust outlet. The steady state levels measured as percent carbon
monoxide and parts per million of hydrocarbons in the exhaust gas
shall not exceed the exhaust emission standards and shall be re-
corded on the certificate of compliance.
Step 7: Increase rpm to 2,250 rpm, plus or minus 250 rpm. The HC
and CO levels shall not exceed the exhaust emission standards and
shall be recorded on the certificate of compliance.
Step 8: The certificate of compliance shall be signed by the in-
spector upon completion of the inspection.
The exhaust emission standards which must be met are given in Table 20.
Table 20. EXHAUST EMISSION STANDARDS
Model Year of Vehicle
Up to and including 1967
1968 - 1969
1970
CO, %
7.5
5.0
4.0
1971 and latera | 4.0
i
HC , ppm
1,200
600
400
400
Vehicle engine must be tuned to manufacturer's
emission control specifications.
Note: All measurements are to be made after
engine has been operating a sufficient period
of time to attain normal operating temperature
and the engine purged if it has been operating
at an idle for greater than five (5) minutes.
ADMINISTRATIVE ELEMENTS
As mentioned, the overall responsibility of the current I/M program resides
in the Emission Control Division of the Department of Motor Vehicles (DMV).
The first function of DMV is the certification of insoection stations. For
a station to be certified certain basic criteria tr.uet be -net. First, the
establishment must have an approved gas analyzer available or. the premises.
58
-------
Table 21. LICENSE STATION CHECK LIST
Date
STATION NAME_
ADDRESS
_STATION LICENSE # Ea-_
NUMBER OF INSPECTORS "
YES | NO
Station
Are the paper licenses displayed?
Inspectors
Is an adequate sign posted?
Dark letters on white background?
Are letters at least 2 inches high?
Is it at least 24" by 24"?
Is total inspection fee listed?
Does it include the words "Authorized Station"?
Are approved references available?
State exhaust emission standards?
Specification manual?
Title
Are the following types of tune-up equipment available?
Ignition analyzer-oscilloscope
Does it calibrate properly?
Tachometer?
Pressure gauge? (0-10 PSI)
Vacuum gauge?
Cam angle dwell meter?
Ignition timing light?
Distributor advance tester?
Engine exhaust analyzer?
Is it on the approved list?
Are the inspection records available and complete?
Are the Certificates of Compliance forms available?
Are they filled out properly?
Type of Equipment^
Serial #
Model
Calibration test
Tolerances
Correlation factor
PPM
HC PPM
Hi Standard Lo
CO %
Hi Standard Lo
First
Second
Third
Fourth
test reading:
test reading:
test reading:
test reading:
CO
CO
CO
CO
% HC
7. HC
% HC
"'- HC
PPM Time
PPM Time
PPM Time
??Y. Time
GENERAL REMARKS:
60
-------
Second, one or more of the employees at the establishment must be a certi-
fied emissions inspector. This requires demonstrated competence to operate
the exhaust gas analyzer and the successful completion of a written exam-
ination administered by DMV. Once these requirements are met and the es-
tablishment is bonded, a license is issued. All licenses expire on Decem-
ber 31 of each calendar year.
A second function of DMV is the monitoring of the program. This includes
both data analysis and spot checks of licensed stations. The data analysis
is performed on inspection fees, repair costs, and emissions reduction
achieved through the program. In addition to the data analysis, stations
are inspected every 90 days when DMV personnel calibrate the emissions
analyzers with span gas. While at the station, DMV personnel complete
the station check list, a reproduction of which is presented in Table 21.
This ensures compliance with the existing regulations.
The costs incurred by DMV in administering the I/M program are offset by
two sources of revenue. The first source is the annual $25 fee charged
each licensee. The second is the $2 fee charged for each inspection cer-
tificate sold to the licensees.
PROGRAM IMPACTS
The impacts of the current program include both the costs to the consumer
and the emissions and energy benefits arising from I/M. While no rigorous
cost-benefit analysis has been attempted due to insufficient data, some
information is available on these matters.
The consumer costs arise from the fee charged to individuals having their
vehicles inspected and from any repair costs necessitated by the failure
of a vehicle to initially meet the emissions standards. DMV has tabulated
two sets of data on inspection fees and repair costs. The first inspection
survey was conducted from March 19, 1976, to April 27, 1976, and covered
59
-------
the inspection costs and repairs of 3,625 vehicles. The second survey be-
gan on April 29, 1976 and as of June 23, 1976 included 527 vehicles. This
second survey not only included data on fees and repair costs, but also
gathered before and after emission data. This latter aspect is referred
to later. The information on consumer costs gathered from these surveys
is presented in Table 22. As shown in the table, the average cost of
inspection is $11.74 per vehicle, including the $2 charge for a Certificate
of Compliance. Repair costs for the 122 vehicles requiring such work av-
erage $10.96. It should be pointed out that 3 percent of the vehicles sur-
veyed required more than minor adjustments.
Table 22. AVERAGE CONSUMER COSTS OF THE CURRENT
I/M PROGRAM
Range Average
I
Inspection cost3 $8.50 - $ 17.00; $11.74
Repair cost
$1.95 - $101.3l! $10.96
o
Includes the $2 charge for Certificate of
. Compliance
The first and perhaps most significant benefit of an I/M program is the
reduction in hydrocarbon (HC) and carbon monoxide (CO) emissions and the
consequent improvement in air quality in the region. The before/after
survey conducted by DMV provides some idea on what is being achieved by
the present program. This information is presented in Table 23. As
seen in the table, for the 527 vehicles tested, HC emissions after testing
were 63 percent of the emissions before testing. The ratio for CO is 0.58.
The survey of 527 vehicle tests conducted by DMV represents a sample of
the entire vehicle population subjected to inspection. During 2 years of
the program approximately 55,000 vehicles have been tested annually. If
the DMV survey is assumed to be representative of both the model distribu-
tion of the entire vehicle population and of the emission characteristics
61
-------
Table 23. SURVEY RESULTS OF EMISSIONS REDUCTION BY VEHICLE MODEL
Vehicle model
All models
Ford
Lincoln
Average HC emissions, ppm
tested i Before test
!
i
527 510
i
110 520
5 420
M«rcury j 24 1 530
i i
Buick : 16 760
Cadillac 26 280
Chevrolet : 94 550
Oldsmobile 30 j 420
t
Pontiac 44 440
; j
Chrysler ; 7 720
Dodge ! 32 460
Plymouth
AMC
Jeep
International
Datsun
Flat
28 580
15 520
5 620
J
7 440
7 i 440
i
2 i 650
i |
Honda 1 110
Mazda j 6 j 730
Mercedes 3 ' 250
MG
f
2 310
Porsche j 1 i 1,460
Rolls Royce j 1 30
Siraca 1 i 2,000
Subaru 1 , 400
Toyota
Triumph
Volkswagen
12 410
2 380
45 ! 540
After test After/before
320 0.63
310
250
350
400
170
0.60
0.59
0.66
0.53
0.61
340
0.62
340 0.81
300
0.68
590 0.82
!
270
0.59
380 0.66
350 i 0.67
320
260
300
0.52
0.59
0.68
430 0.66
80 0.73
| 240 0.33
I 220 0.88
i
i
310 1.0
1,180 0.81
i 30 1.0
700 0.35
350 0.88
260 0.63
330 0.87
360 0.67
Average CO emissions, Z
Before test
4.7
5.1
5.2
5.3
6.3
2.2
4.6
4.6
3.7
6.4
5.6
4.9
4.9
4.S
4.4
3.0
5.0
0.2
6.5
1.3
3.0
7.0
0.5
10.0
6.0
3.9
5.5
4.6
After test
2.7
3.0
3.0
3.0
3.6
1.8
; 2.6
2.9
i
2.1
1
1 4.1
1
; 2-6
!
1 3.0
I 2.7
; 4.4
1
2.0
1.7
; 2.0
I 0.2
i 1.8
! 0.7
: 3.0
I
i 2.6
i 0.5
; 3.o
1 4.0
1.8
3.0
3.0
After/before
0.57
0.59
0.58
0.54
0.57
0.82
0.56
0.63
0.57
0.64
0.47
; 0.61
i 0.55
0.91
:
0.45
I
0.57
0.40
1.0
0.28
0.54
1.0
!
' 0.34
1.0
0.30
0.67
0.46
; 0.55
0.65
62
-------
by models, then the emission reductions achieved by the sample can be as-
sumed representative of the potential emission reduction of the entire ve-
hicle population. It is important to note that the emission reductions
discussed above are only relevant at the time of the inspection and sub-
sequent maintenance. DMV has not initiated studies of the effects of
emission deterioration and thus the achieved reductions are not suitable
for projecting net annual reductions.
Fuel savings are a second area of benefits. Table 24 presents EPA esti-
mates of fuel savings from inspection and maintenance programs. The be-
fore and after survey conducted by DMV showed that 43 percent of the ve-
hicles tested needed at least minor adjustments. Assuming that this
corresponds to something between a 30 to 40 percent rejection rate, a
savings of $9.00 per vehicle per year would appear to be reasonable. The
aggregate fuel savings for an annual total of 55,000 vehicles inspected
would then amount to $495,000 per year or approximately 825,000 gallons
of fuel.
Table 24. FUEL SAVINGS FROM INSPECTION/MAINTENANCE PROGRAMS2
Failure
rate, %
50
40
30
20
10
Annual luei
savings - serviced
vehicles only
Percent
4.2
4.73
5.5
6.76
9.66
Gallons
36
40
47
57
82
Savings per
serviced
vehicle, $
21.40
24.00
28.00
34.40
49.30
Annual fuel
savings - all
vehicles
Percent
2.1
1.89
1.65
1.35
0.97
Gallons
18
16
14
11
8
Savings per
vehicle - all
vehicles, $
10.70
9.60
8.40
6.85
4.90
PROGRAM ANALYSIS
The preceding discussion dealt with the technical and administrative as-
pects of, and the impacts arising from, the current I/M program in Clark
63
-------
County. The purpose of this section is to provide a perspective on these
facts. Table 25 presents the positive aspects of the present program
and Table 26 the negative aspects. Those features of the current pro-
gram that are not listed in either table are considered to be neutral.
Table 25. POSITIVE ASPECTS OF THE EXISTING NEVADA I/M PROGRAM
Area of impact
Positive aspect
Technical
1. Use of accepted instrumentation
2. Setting dwell and ignition timing of all cars to
manufacturers' specifications
3. Inspection of vehicles required to have positive
crankcase ventilation valve for connection and
operation of same
Administrative
Public acceptance
4. Observe for visible smoke
1. Certification of stations and inspectors
1. Minimal registered complaints
As shown in Table 25, there are several positive aspects to the present
Nevada program. The test procedure and thoroughness of the test are more
than adequate. In essence, the present program is a mandatory maintenance
program (in the form of minor engine adjustments) followed by inspection.
A further advantage of the current program is its acceptance by the public.
This is reflected by the fact that very few complaints have been registered.
While the present program has a good foundation, there is room for improve-
ment. First, there are three technical areas which warrant comment. In
the existing emissions standards (Table 20) there are no separate stan-
dards for 1975 and 1976 vehicles. Since these model years are required to
meet stricter federal emission criteria, it is reasonable to assume that
stricter emissions standards could be set. The other two technical areas
exhibiting some shortcomings deal with the frequency of testing and the
vehicle population subject to testing. An annual test for all light-duty
vehicles is worthy of consideration.
64
-------
Table 26. NEGATIVE ASPECTS OF THE EXISTING NEVADA I/M PROGRAM
Area of impact
Negative aspect
Technical ! 1. No separate standards for 1975 and 1976 vehicles
j
' 2. Only vehicles which change ownership are re-
| quired to have emissions testing
1
i 3. Lack of chronological testing
Administration
1. Inspection form precludes before/after evaluation
2. Poor program monitoring, especially data analysis
3. Lack of mechanics' training program
4. Buyer in private transaction is liable for
testing
Public acceptance
1. No one fixed inxpection fee for all inspection
stations
2. No ceiling on repair costs
Administrative improvements can be made in several areas. First, the in-
spection form should allow for the recording of emissions before the engine
is adjusted. This would provide DMV with much needed data on the total
emissions reductions resulting from I/M. Further, DMV should tabulate such
information on a regular and consistent basis. DMV could also provide a
course for emissions technicians which would serve to enhance the quality
of the emissions testing. Current work on such a course is being sponsored
by EPA and was discussed in Section III of this report. A final administra-
tive issue involves the burden of responsibility for testing. The seller
of the automobile would be made responsible for securing emissions testing.
This, of course, is an issue only if the present program is continued.
There are two other pitfalls in the present program which are called out
separately since they directly affect the public. First, it would seem
65
-------
latter number includes the total number of service station, automobile
dealerships, and automobile repair shops located in Clark County.
A third group of assumptions dealt with the costs associated with this
alternative. The cost of equipment was obtained from various equipment
2
manufacturers. Labor costs were obtained by updating data from a
3
study of I/M done for the State of Colorado. These data were selected
since they were based upon a detailed survey of automotive establishments.
The estimates of the parameters associated with a privately run I/M pro-
gram are presented in Tables 27 through 29. As shown by these tables,
the cost of inspection ranges from a lox-j of $2.98 per vehicle (straight
hourly wage for operator with 120 licensees) to a high of $5.49 per ve-
hicle (315 licensees with overhead included in the cost of labor).
In addition to the costs of the establishments performing the test,
administrative costs must also be considered. In developing administra-
tive costs, it is assumed that the total annual administrative salaries
are equal to the administrative personal salaries. Items such as fringe
benefits, office space, computer time, etc. are thus excluded. Table 30
presents the staffing levels and salaries considered reasonable for the
administration of a privately run I/M program. These are based in part
upon the previously mentioned study done for the State of Colorado.
The charge to the consumer for an inspection under this system would
range from $3.50 to $6.25. This is the sum of administrative costs plus
the cost of inspection.
STATE RUN IDLE MODE TEST
Under a state run idle mode testing sysjtem, the State would actually be
responsible for conducting the emissions testing. This would require,
therefore, the State to construct the necessary number of testing sites
70
-------
desirable to have one fixed inspection fee for all stations. Secondly, a
ceiling on repair costs should be set to avoid any undue hardship on certain
individuals. This could be expressed as either an absolute dollar limit or
as a percentage of the blue book value of the vehicle.
In summary, the present I/M program in Clark County represents a good first
step in the implementation of a total I/M program. Section V analyzes
selected alternatives of a total program.
66
-------
REFERENCES
1. State of Nevada Air Quality Regulations. September, 1974. Amended
January 15, 1975; June 17, 1975; September 18, 1975.
2. Binder of I/M Background Material. Prepared by U.S. EPA. April 30,
1976.
67
-------
SECTION V
ANALYSIS OF SYSTEM ALTERNATIVES
INTRODUCTION
This section presents the analysis of alternative I/M system for Clark
County. Scenarios reflecting different weekly distribution of vehicles
coming in for inspection are developed for each option. Based upon these
scenarios, estimates of the capital and operating costs, repair costs,
energy savings, inspection fee, and emissions reduction potential are
made for four alternate systems. The systems analyzed are given below:
Privately Run Idle Mode Test
State Run Idle Mode Test
Contractor Run Idle Mode Test
Contractor Run Loaded Mode Test
Assumptions
The estimates made involve assumption on various features of the program.
The general assumptions applicable to all alternatives include the
following:
1. Vehicles are inspected annually. The number of annual
inspection is the total number of light-duty vehicles
registered in Clark County minus exemption for new
vehicles. Fleet operations are-assumed to perform their
own emissions testing under the privately run system.
68
-------
2. A failure rate of 33 percent is assumed. This is
consistent with the failure rates observed in other
I/M programs. A typical distribution of reasons
for failure has also been assigned. Given the test-
ing procedure followed in Clark County, however,
only 12 percent of the initial inspection will have
to be retested. This is due to the minor adjustments
made as a standard part of the inspections procedure.
In addition, the 12 percent retested assumes that
engine overhauls will be exempt from the program
due to a price limit placed upon repairs.
3. There are 25 inspection days per month.
4. One-twelfth of the vehicle population is inspected
each month.
PRIVATELY RUN IDLE MODE TEST
The first alternative analyzed is a privately run idle mode system.
Under this arrangement, DMV would licence private establishments to per-
form emissions testing. DMV would, however, be responsible for the
overall administration of the program. It is this type of organization
which currently exists, on a smaller scale, in Clark County.
Several assumptions are made concerning the length of time for a test,
the number of stations licensed, and the cost components of the test.
First, it is assumed that the total test time is 25 minutes. Twenty
minutes of this total is allowed for the mechanic to leave what he is
doing, set up the test equipment, and perform the test. An additional
5 minutes is alloted for the carburator adjustments and dwell and timing
checks which are part of the required testing procedure.
Secondly, three different assumptions are made concerning the number of
licensees. The first assumption is that only the 120 existing licensees
will perform emissions loses on the entire vehicle population. For the
second case, it is assumed that 200 establishments will be licensed.
Finally, it is assumed that 315 establishments will be licensed. This
69
-------
Table 27. PRIVATELY RUN STATIONS - 120 LICENSEES
(VEHICLE POPULATION - 190,000)
Cars inspected/station
- - - - -
Initial inspections
Retest (12% of initial inspection)13
Total
Annually
1585
190
1775
Monthly3
132
16
148
Hours spent/station
All inspections
Annually
740
Monthly3
62
Daily distribution/station
Case 1
Case 2
Case 3
1/3
1/3
1/3
- equal
- last 10 days
Inspect ions /day
6
15
j
- 1st 12 days
- next 8 days
- last 5 days
4
6
10
Hours/day
2.5
6+
2
2.5
4+
Hours/montha
62
62
j
Costs per station
Cost
Capital equipment
Annual cost
$2,200
Fee
Maintenance & depreciation
Labor ($5.20/hr - $9.92/hr)c
Total annual cost
Cost per vehicle inspected
!
j
j $3,848 -
j $4,373 -
| $2.75 -
$ 25
$ 500
$7,340
$7,865
$5.00
Twenty-five inspection days per month. -
Actual failure rate of 33 percent.
CLow end of range reflects straight hourly wages.
range includes station overhead.
High end of
71
-------
Table 28. PRIVATELY RUN STATIONS - 200 LICENSEES
(VEHICLE POPULATION - 190,000)
Cars inspected/station
Annually
Initial inspections \ 950
Retest (12% of initial lnspection)b j 114
Total j 1064
Monthly3
79
10
89
Hours spent/station
Annually j Monthly3
All inspections
443
37
Daily distribution/station
Case 1
Case 2
Case 3
1/3
1/3
1/3
- equal
- last 10 days
- 1st 12 days
- next 8 days
- last 5 days
Inspect ions /day j
4 |
9 1
3 ;
, i
6 i
Costs per station
Hours/day
2
4
1
2
2.5
Hours/month3
37
37
1 37
Cost
Capital equipment
Annual cost
$2,200
Fee !
Maintenance & depreciation 1
Labor ($5.20/hr - $9.92/hr)c
Total annual cost j
Cost per vehicle inspected !
$2,304 -
$2,829 -
$3.00 -
$ 25
$ 500
$4,395
$4,920
$5.20
aTwenty-five inspection days per month.
Actual failure rate of 33 percent
°Low end of range reflects straight hourly wage.
includes station overhead.
High end of range
72
-------
Table 29. PRIVATELY RUN STATIONS - 315 LICENSEES
(VEHICLE POPULATION - 190,000)
Cars inspected/station
Initial inspections
Retest (12% of initial inspection)13
Total
Annually Monthly3
j !
i 603 ! 50
72 ; 6
675 | 56
Hours spent/station
Annually Monthly3
All inspections
281
23
Daily distribution/station
I I
' Inspections/day | Hours/day ! Hours/month3
Case
Case
Case
1
2
3
1/3
1/3
1/3
- equa
- last
- 1st
- next
- last
1
10
12
8
5
days
days
days
days
2
6
i
i 1
i 2
: 4
Costs per station
1 \
2 ;
0.5 '
1 i
1.5 |
23
23
)
23
Cost
Capital equipment
Annual cost
Fee
Maintenance & depreciation
Labor ($5.20/hr - $9.92/hr)c
Total annual cost
Cost per vehicle inspected
$2,200
$ 25
$ 500
$1,461 - $2,788
$1,986 - $3,313
$3.30 - $5.50
Twenty-five inspection days per month.
Actual failure rate of 33 percent.
j-»
Low end of range re.fj.ects straight hourly wage. High end of range
includes station overhead.
73
-------
Table 30.
ANNUAL STATE ADMINISTRATIVE COSTS FOR A
PRIVATELY RUN IDLE MODE SYSTEM3
Annual cost
$
Administration
Administrator 20,000
Engineer 14,500
Technicians (2 at $12,000/yr) 24,000
Secretary 9,800
Clerks (2 at $8,000/yr) 16,000
Data processing
Supervisor 15,500
i
Data Analyst | 14,500
]
Keypunch Operator (2 at $8,000/yr) J 8,000
(
Total annual administrative costs 138,300
Administrative cost per inspection 0.75
. - __ _ _._. J _^, ^ ^ _._. ____ j
«3
Assumes total annual administrative costs are
equal to total annual administrative salaries.
and hire the personnel necessary for running them. In addition, the
State would be responsible for the data analysis and other administrative.
duties previously mentioned. The chief advantage of such a system is
that it ensures consistency in the testing procedures and interpretation
of the test results.
As with the estimation of the costs associated with a privately run
system, the cost estimation of this system involves several assumptions.
First, the necessary number of test lanes had to be estimated. Based
upon the three scenarios of the monthly distribution of vehicles coming
in to be tested, the necessary number of lanes is 7, 9, and 16. These
numbers reflect ^he necessary number of lanes under all but ultrapeak
days or periods. In developing these estimates, the test rime was
74
-------
assumed to be 4 minutes. The number of initial inspection is 190,000
vehicles (a figure explained previously) with 33 percent or 63,335 ve-
hicles requiring a retest. These vehicles would have to be repaired at
private establishments and then return for a retest. Thus, the capacity
of the testing facilities must reflect this number of retests. Appendix A
presents the calculations used to determine the necessary number of lanes.
Appendix A also presents the capital and operating costs of both a single
lane and double lane idle mode facility. The basis for these figures is
3
the previously mentioned Colorado study. Again, it must be emphasized
that the personnel costs given reflect only salaries and are exclusive
of fringe benefits. It should also be pointed out that the two-lane
test site is, because of economies of scale, less expensive on a per-
lane basis. For the calculation of the costs, the most cost efficient
scheme was chosen. This makes use of a minimal number of one-lane test
facilities.
Table 31 presents the cost of inspection for a state run idle mode sys-
tem. As shown in the table, the cost of inspection per vehicle ranges
from $2.75 to $6.00 depending upon the number of lanes built. It should
Table 31. SITE COSTS OF A STATE RUN IDLE MODE SYSTEM
Number of
7 (3 double
9 (4 double
16 (8 double)
lanes
4- 1 single)
+ 1 single)
1 Capital cost
! $
! 527,850
'] 666,050
i 1,105,600
Annual cost
520,825
663,455
1,141,040
Cost/vehicle3
2.75
3.50
6.00
r\
Vehicles are retested at no additional charge.
75
-------
be emphasized that while fewer lanes involve a lower inspection cost per
vehicle, waiting during peak period would be much greater.
The administrative costs of a state run system would be less than under
the privately run option. These costs are presented in Table 32. The
reason for the lower cost as compared to the privately run system is due
primarily to the lack of need for technicians and/or engineer to monitor
the testing facilities.
Given the administrative cost of $0.60 per vehicle, the cost charged to
the consumer for an inspection would be $3.35 for a 7-lane system, $4.10
for a 9-lane system, and $6.60 for a 16-lane system. These costs are
simply the summation of the administrative cost and the cost of inspec-
tion. This information is presented in Table 33.
CONTRACTOR RUN IDLE MODE TEST
A contractor run idle mode test is an arrangement whereby a corporation
is responsible for testing vehicles under the overall administration of
the state. The costs of such a system are the same as the state run
system, with two important exceptions. First, the contractor and not the
state bears the burden of constructing the test sites and hiring the per-
sonnel. Secondly, because the contractor bears this fiscal responsibi-
lity, allowance must be made for a return on its capital investment.
Therefore, the cost of inspection and charge to the consumer will be
higher by the amount of this return. Assuming a 15 percent return on
investment before taxes, the additional cost per inspection would be
$0.45 for a 7-lane system, $0.55 for a 9-lane system, and $0.90 for a
16-lane system. The charge to the consumer for this system is given in
Table 34.
76
-------
Table 32. ANNUAL ADMINISTRATIVE COSTS FOR A STATE
RUN IDLE MODE SYSTEMS
Annual cost
Administrative '
Administrator I 20,000
Assistant Administrator ; 15,000
Secretary ' 9,800
Clerk ; 8,000
Data processing
Supervisor ; 15,500
Data Analyst : 14,500
Keypunch Operator (2 at $8,000/yr) ', 16,000
Clerk i 8,000
Total annual administrative costs I 106,800
Administrative cost per inspection I 0.60
*a
Assumes total annual administrative costs are
equal to total annual administrative salsries.
Table 33. COST OF A STATE RUN IDLE MODE SYSTEM
Number of
lanes
7
9
16
Inspection
cost/vehicle
$2.75
$3.50
$6.00
Administrative \
cost/vehicle j
$0.60
$0.60
$0.60 :
Charge to the
consumer
$3.35
$4.10
$6.60
77
-------
Table 34. COST OF A CONTRACTOR RUN IDLE MODE SYSTEM
Number of
lanes
7
9
16
Inspection
cost/vehicle
$2.75
$3.50
$6.00
Administrative
cost/vehicle
$0.60
$0.60
$0.60
1
1
Profit/vehicle !
1
$0.45 1
$0.55
$0.90 ;
i
Charge to the
consumer
$3.80
$4.65
$7.50
CONTRACTOR RUN LOADED MODE TEST
The final alternative analyzed is a contractor operated loaded mode
test system. While the organization of such a system is the same as
in the contractor run idle mode system, the costs will vary for two
reasons. First, the loaded mode test takes 5 minutes to perform (as
opposed to 4 minutes for an idle test) and thus will require more
inspection lanes. The number of lanes is derived in Appendix A and
is 9, 11, and 20 under the respective scenarios of monthly distribution
of testing.
Secondly, the equipment costs are higher for a loaded mode facility.
This is due to the greater sophistication of the equipment. The costs
are given in Tables A-4 and A-5 in Appendix A.
The inspection costs of a loaded mode test are given in Table 35.
The costs or charge to the consumer for such a system are given in
Table 36.
ADDITIONAL IMPACTS OF I/M
The preceding discussion has dealt with the major cost issues of the
four alternate I/M systems analyzed. Specifically, the size of the
various networks have been estimated along with the inspect ion costs,
78
-------
administrative costs, profits (for contractor run systems), and the
fee charged to the consumer. The following discussion focuses an
additional costs and benefits of each of the four alternatives.
Repair Costs
Those vehicles which do not meet the emissions standards will be re-
quired to have necessary repairs before being issued a Certificate of
Compliance. Table 37 presents information on average repair costs for
these areas where data are available. The programs in Arizona and
Table 35. COSTS ASSOCIATED WITH A CONTRACTOR RUN LOADED MODE SYSTEM
Number of lanes
9 (4 double and 1 single)
11 (5 double and 1 single)
20 (10 double lanes)
Capital cost
$ 712,890
$ 861,450
$1,486,000
Annual cost
$ 669,085
$ 812,965
$1,438,800
Cost/vehicles
$3.55
$4.30
$7.60
Table 36. CONSUMER COST OF A CONTRACTOR RUN LOADED MODE SYSTEM
Number of
lanes
9
11
20
Inspection
cost/vehicle
$3.55
$4.30
$7.60
Administrative
cost/vehicle
$0.60
$0.60
$0.60
Prof it /vehicle
$0.60
$0.70
$1.20
I Charge to the
; consumer
$4.75
: $5.60
$9.40
79
-------
Table 37. AVERAGE REPAIR COSTS FOR VEHICLES
REJECTED BY EMISSIONS TESTING
Program location
Average repair costs
Arizona j $19.95
Nevada j $10.96
i
New Jersey j $32.40
I
Oregon j $21.90
Oregon which have a 33 percent rejection rate, and have an average
repair cost of about $20. New Jersey's average is higher at $32.40.
This reflects the fact that New Jersey was at the time rejecting only
12 percent of the vehicles inspected and, therefore, only high emitting
vehicles were being repaired. The Nevada data shows an average repair
cost of about $11. This is lower than the other due to the nature of
the current testing procedure in Clark County where minor engine
adjustments are part of the overall inspection procedure and are in-
cluded in the cost of inspection. It would seem appropriate to use
$20 as a figure for average repair costs for all alternatives except
the privately run idle mode system. Under that alternative, $11 appear
as a reasonable cost of repair figure.
Energy Savings
Table 24 in Section IV presented data on the fuel savings from I/M
programs. Assuming a 33 percent rejection rate for all the programs
analyzed, the fuel savings for all vehicles received would be $9/vehicle.
Thus, with a vehicle population of 190,000 the aggregate fuel savings
would be $1,710,000, or approximately 2,850,000 gallons of fuel. For
those vehicles which fail inspection and require repair, the fuel savings
per vehicle would be approximately $30 annually. This would, in most
cases, offset the cost of repair.
80
-------
Estimated Potential Emission Reduction
Emission reduction as reported earlier in Section II, is a function of
emission standards, rejection rates and deterioration effects. Various
other locales have determined annual emission reductions to potentially
be as high as 40 percent. Arizona reports this potential but computes
4
actual achieved CO reductions in the vicinity at 22 percent. Data
analysis of the Chicago program shows potential CO reductions of
approximately 27 percent. Results of New Jersey's air quality moni-
toring program exhibits a 13 percent improvement in air quality attributed
to I/M.-5" The exact relationship between emission reductions and improve-
ment in air quality is dependent upon a number of factors including
meteorological influences.
Calculation of the potential emission reductions estimated for the
Nevada alternatives were based on the deterioration results of the
Olson Laboratory study partially presented in Table 11 and the emis-
sions reductions shown in Table 23 of the current Nevada program.
The reductions from the Nevada before/after data are only valid for
a. base period since they are not adjusted to account for deterioration
effects. The Olson study was selected because it represents the most
recently released data on the subject.
Results of this brief analysis show potential annual emission reduc-
tions in CO emissions to range between 14 and 18 percent and range
between 18 and 22 percent for HC emissions. One conclusion of the
Q
Olson study and U.S. EPA officials is that the most effective approach
to obtain emission reductions is to repair only those vehicles which
require service. Thus the I/M approach currently operating in Nevada
is assumed to achieve emission reduction on the lowar end of t:e
range. A contractor or State test lane facility would achieve reduction
toward the upper end as shown in Table 38.
81
-------
Table 38. ESTIMATED POTENTIAL EMISSION REDUCTIONS FOR NEVADA
Program
Private garage
State test lane
Contractor test
Contractor test
alternative
, idle
lane,
lane,
Emission re-
duction, %
HC
! 18
mode 20
idle mode
loaded mode
CO
14
16
20 ! 16
22 ; 18
SUMMARY
This section has presented information on the costs, benefits, and the
issues associated with four alternate I/M systems for Clark County,
Nevada. No attempt was made to recommend one alternative over another.
Instead, our intent was to provide decision makers with data which
hopefully will aid in their final evaluation of an I/M program for
Clark County.
As with any effort of this sort, care must be taken in the interpre-
tation of the results. Specifically, certain limitations of this study
should be remembered. First, the bulk of information presented is
based upon an extensive literature and contacts with individuals
knowledgeable of I/M systems. What is true under one set of cir-
cumstances is not necessarily valid under changed conditions.
Secondly, the costs and benefits presented represent the best readily
available information. These numbers should not, however, be con-
sidered to be exact. They represent estimates and estimates only.
While care has been paid to establish reasonable estimates, certain
costs have not been considered. The most important of these is the
administrative costs associated with each of the alternatives. If
82
-------
anything, our administrative costs are an underestimation. Along
the same lines, the data on emissions reduction, energy savings, and
repair costs should be viewed as gross estimates. Good and vo-
luminous data on these areas do not presently exist.
It is with these limitations that the summary data in Table 39 is
presented.
83
-------
Table 39. SUMMARY OF.I/M ALTERNATIVES FOR CLARK COUNTY NEVADA
CO
Alternative
Privately run idle mode
State run idle mode
Contractor run idle mode
Contractor run loaded mode
Inspection feea
$3.50-6.25
$3.30-6.60
$3.80-7.50
$4.75-9.40
Annual repair
costs/vehicle
$11.00b
$20.00C
$20.0QC
$20.00c
Annual energy
savings/ vehicle
$9.00
$9.00
$9.00
$9.00
Perc
emiss
reduc
HC
18
20
20
22
Includes all construction, operating and administrative costs.
Average for 12 percent requiring retest.
'Average for 33 percent of the vehicle population.
CO
14
16
16
18
-------
REFERENCES
1. U.S. Bureau of the Census, County Business Patterns, 1973.
Nevada. U.S. Government Printing Office.
2. Communications with Company's A, B, C, D, E.
3. An Analysis of the Practical Application of an Inspection and
Maintenance Program in the Public and Private Sectors.
Prepared by Automotive Testing Laboratories, Inc. for the
State of Colorado.
4. Personnel Communication with Mr. Jack Hesse. Hamilton Test
Systems. Phoenix, Arizona. May 1976.
5. Poster, H. W. and J. Seliber. Chicago's Experience in Vehicle
Emission Testing. Department of Environmental Central City of
Chicago. Paper presented at SAE Automotive Engineering Congress
and Exposition. Paper No. 760368. Detroit, Michigan. February
23-27, 1976.
6. Elston, John. New Jersey's Auto Emission Inspection Program:
An Assessment of One Year's Mandatory Operation. Department of
Environmental Protection. Paper Presented at the Fourth North
American Motor Vehicle Emission Control Conference. Anaheim,
California. November 5-7, 1975.
7. Degradation Effects on Motor Vehicle Exhaust Emission. Olson
Laboratories, Inc. Anaheim, California. Prepared under Contracts
ARB 3-199 and 3-584 for State of California Air Resource Board.
March 1976.
8. Personal Communication with Mr. Richard Penna. U.S. EPA Office of
Mobile Source Enforcement. June 1976.
85
-------
SECTION VI
INSPECTION AND MAINTENANCE BIBLIOGRAPHY
I. INSPECTION AND MAINTENANCE ALTERNATIVES
A. I/M IMPLEMENTATION AND RELATED ISSUES
1. Inspection and Maintenance: A Guide for Implementation.
U.S. EPA. Strategies and Air Standard Division. Research
Triangle Park, N. C. February 25, 1974.
2. Issues on Inspection and Maintenance. U.S. EPA Region I.
March 24, 1975.
3. Control Strategies for In-Use Vehicles. U.S. EPA OAWP,
MSPCP, Washington. November 1972.
4. Gorman, George J. I/M Program Checklist. U.S. SPA Region III,
Philadelphia. PB 247825.
5. Meltzer, J. et al. A Review of Control Strategies for
In-Use Vehicles. Aerospace Corp., California, for U.S.
EPA. Emission Control Technology Division. PB 241768.
December 1974.
6. General Motors Position on Motor Vehicle Emission Inspection
Procedure. February 28, 1975.
7. Inspection/Maintenance Binder of Background Materials.
Prepared by OTLUP, OMSE, OAQPS, OPA, OPE, OMSAPC.
U.S. EPA. April 30, 1976.
8. Shutler, Dr. Norman D. Overview of Inspection/Maintenance.
U.S. SPA. Presented at MVECC-IV, Anaheim, California.
November 1975.
9. Calhoon, Joseph C. Experience with Inspection and Mainte-
nance Programs: A Manufacturer's Viewpoint. Environmental
Activities Staff. General Motors Corporation. Presented
at MVECC-IV, Anaheim, California. November 1975.
86
-------
10. Easterling, Mahlon. The Role of Periodic Motor Vehicle
Inspection in Air Pollution Abatement. Prepared for the
53rd Annual Meeting of the Highway Research Board.
January 1974.
B. I/M AS A TRANSPORTATION CONTROL STRATEGY
1. Evaluating Transportation Controls to Reduce Motor Vehicle
Emissions in Major Metropolitan Areas. APTD 1364. IPA,
Teknetron Inc., and TRW Inc. for EPA OAQPS. November 1972.
2. Horowitz, Joel. I/M for Reducing Automobile Emission:
Effectiveness and Cost. U.S. EPA. J Air Pollut Contr
Assoc. 23(4). April 1973.
3. Schwartz, S.I. Reducing Air Pollution by Automobile I/M:
A Program Analysis. University of California, Davis.
J Air Pollut Contr Assoc. 23(10). October 1973.
4. Socio-Economic Impacts of the Proposed State Transportation
Control Plans - An Overview. TRW. November 1973.
5. Appendix N - Emission Reduction Achievable Through Inspection/
Maintenance and Retrofit of LDV. U.S. EPA. FR. 38(110)-
15197. June 8, 1973.
C. IDLE MODE TESTING
1. Panzer, J. IDLE Emissions Testing. Exxon Res. & Eng. Co.
Paper presented at SAE National Fuels and Lubricants Meeting,
Tulsa, Oklahoma. Paper No. 720937. November 1972.
2. Panzer, J. IDLE Emissions Testing - Part II. Exxon Res. &
Eng. Co. Paper presented at SAE Automotive Engineering
Congress, Detroit, Michigan. Paper No. 740133. February 1974.
3. Panzer. J. IDLE Emissions Testing - Part III. Exxon Res. &
Eng. Co. Paper presented at APCA. Paper No. 74-130.
June 1974.
4. Panzer, J. IDLE Emissions"Testing: Some Effects of Engine
Malfunctions on Emissions. Exxon Res. £ Eng. Co. Paper
presented at XVECC IV, Anaheim, California. November 1975.
87
-------
D. LOADED MODE TESTINC
1. The Key Mode Engine Evaluation System, Clayton Manufacturing
Co., El Monte, California. 1971.
2. Cline, E.L. and Lee Tinkham. A Realistic Vehicle Emission
Inspection System. Dynamometer Division. Clayton Manufactur-
ing Co., El Monte, California. Paper No. 6S-152. APCA
Annual Meeting.
3. Norman, E.J. Dynamic Loaded Testing. Presented at MVECC-IV,
Anaheim, California. November 1975.
4. Clayton Blue Book. Literature Germane to Mobile Source
Emission Control Through Corrective Action. Prepared by"
Clayton Manufacturing Company. El Monte, California.
II. NEVADA
1. Nevada Air Quality Regulations
2. Nevada Hearings on I/M (portions)
3. Regulations and Procedures for Licensure and Enforcement
of I/M
III. I/M CITY/STATE EXPERIENCE
A. ARIZONA
1. Aymar, Arthur A. Arizona Key Mode Auto Inspection. Arizona
Department of Health Services. APCA Technical Paper 75-424.
Presented in Boston June 1975.
2. Arrigo, Anthony J. State of Arizona Vehicular Emissions
Control Program. Presented at Second North American
Conference on Motor Vehicle Emission Control at Denver.
3. Mandatory Annual Emissions Inspection of Motor Vehicles.
House Bill 2319. State of Arizona. May 1974.
4. Regulating Vehicle Fleet Emission Inspection and Inspection
Stations. House Bill 2313. State of Arizona. May 1975.
88
-------
5. Vehicle Emissions Program Operating Rules and Regulations.
Arizona Department of Health Services.
6. A Summary of Factual Information Concerning Emissions Testing,
Arizona Vehicle Emissions Inspection Program. Hamilton Test
Systems. March 1976.
7. Arizona's Vehicle Inspection Program: About Air and Autos and
Arizona. Cleaner Air for Arizona. A 5-Minute Test to Help
Everyone Breathe Easier. Preserving a Healthy Environment in
the Age of the Automobile. (4 Pamphlets from Arizona Vehicle
Emissions Inspection Program).
8. lacobelli, R.F. The Arizona Inspection/Maintenance Program.
Arizona Department of Health Services. Presented at MVECC-IV,
Anaheim, California. November 1975.
B. CALIFORNIA
1. Task Force Report on Periodic Vehicle I/M for Emission Control
and Recommended Program. California. October 1972.
2. Kelly, Warren. Exhaust Emissions and Cost Evaluation of the
State of California's Roadside IDLE Emission Inspection
Program. Scott Research Labs, California. (PB235-990)
December 1973.
3. DoIan, John H. Briefing on the California Vehicle Inspec-
tion Program and Detailed Description of the Phase I River-
side Trail Program. Program Manager, Vehicle Inspection Pro-
gram. Presented at MVECC-IV, Anaheim, California.
November 1975.
C. CHICAGO
1. Poston, H.W. The Chicago Vehicle Exhaust Emission Control
Program. Presented at Second North American Conference on
Motor Vehicle Emission Control at Denver. August 1973.
2. Poston, H.W. and J. Seliber. Chicago's Experience in Vehicle
Emission Testing. Department of Environmental Control. City
of Chicago. Paper presented"at SAE Automotive Engineering
Congress, Detroit. Paper No. 760368. February 1976.
3. Poston, H.W. The Chicago Experience - 2 Years Later. D.E.C.
City of Chicago. Presented at MVECC-IV; Anaheim, California.
November 1975.
89
-------
D. COLORADO
1. Motor Vehicle Emission Control Program, A.P.C.C. Colorado
Department of Health. 1973.
2. Motor Vehicle Emission Control Program. A.P.C.C. Colorado
Department of Health. 1974.
3. I/M of LDV in the Denver AQCR. TRW. November 1974.
4. An Analysis of the Practical Application of an I/M Program in
the Public and Private Sectors (DRAFT). Automotive Testing
Laboratories, Inc., Colorado. Prepared for Colorado Depart-
ment of Health.
E. NEW JERSEY
1. Elston, John C., Anthony J. Andreatch, and Laurence J. Milask.
Reduction of Exhaust Pollutants Through Automotive Inspection
Requirements - The New Jersey REPAIR Project. New Jersey
Department of Environmental Protection. Bureau of Air Pollu-
tion Control. Second International Clean Air Congress,
Washington, D.C. December 6-11, 1970.
2. Andreatch, A., J.C. Elston, and R. Lahey. New Jersey REPAIR
Project: Tune-Up at Idle. New Jersey Bureau of Air Pollu-
tion Control. J Air Pollut Contr Assoc. 21(12). December 1971.
3. Andreatch, A., and J.C. Elston. Evaluation of Idle I/M Equip-
ment Network. New Jersey Bureau of Air Pollution Control.
SAE Paper No. 740134. Automotive Engineering Congress,
Detroit. February 1974.
4. Elston, J.C., and D. Cowperthwait. New Jersey's Auto Emis-
sion Inspection Program: An Assessment of 1 Year's Mandatory
Operation. Paper 75.42.3. Presented at APCA Boston.
June 1975.
5. New Jersey Checks Auto Exhaust. Environmental Science and
Technology. 6(9):785. September 1972.
6. New Jersey Regulations, enabling legislation, public hearing
notice.
7. Your Car and Its Pollution Test. Plain Facts Abouc New Jersey's
Environment. (Pamphlet (2) handed out to motorists).
90
-------
8. Elston, John C. New Jersey's Automotive Emission Inspection
Program. Presented at Second North American Conference on
Motor Vehicle Emission Control At Denver. Seotember 1973.
F. PORTLAND, OREGON
1. Oregon TCP Technical Support Documents. EPA Region IX.
October 1973.
2. Summary of Definitions and Standards. March 28, 1975.
3. DEQ Clean Air Test. Does Your Car Have to be Inspected?
Information Bulletin No. 76050. (Pamphlet (3) handed out to
motorists.)
4. Householder, Ronald C. Oregon's Motor Vehicle Emission
Control Inspection Program. Administrator, Vehicle Inspec-
tion Program Oregon Department of Environmental Quality.
Presented at MVECC-IV, Anaheim, California. November 1975.
G. OTHERS
1. Williams, Harry. Pilot Study of Proposed Vehicle Inspection
Program in Marion County, Indiana. Director, APCD, Indiana.
APCA Paper 75-42.1. Paper presented at APCA Annual Meeting,
Boston, Mass. June 1975.
2. Caprarotta, Gary L., Douglas J. Orf. An Investigation of
Motor Vehicle Emissions Deterioration Through Idle Emissions
Testing. Regional Air Pollution Control Agency, Dayton, Ohio.
Paper presented at APCA Annual Meeting, Boston, Mass. June 1975.
3. Study Report on Proposed Inspection-Maintenance System.
State of Connecticut. Department of Environmental Protec-
tion. January 4, 1975.
4. Motor Vehicle Emission Inspection Establishment of Criteria
Federal Register Volume 40, Number 113, p. 24904.
June 11, 1975.
91
-------
8. Clayton Manufacturing Company Brochure.
9. Autosense, Hamilton Test Systems Package.
10. Stewart-Warner Infrared Exhaust Emission Analyzer,
VI. MOTOR VEHICLE AIR POLLUTION CONTROL DEVICES
1. Niepoth, Ransom, Currie. Exhaust Emission Control for Used Cars.
GM Corp: Advance Product Engineering. SAE Paper No. 710069.
January 1971.
2. A Speed-Regulated System for the Control of Exhaust Emissions.
RETRONOX Bulletin No. 6227-1. Dana Corp., Hagerstown, Indiana.
3. Air Pollution Control Devices on 1973 Model Vehicles. Motor
Vehicle Manufacturing Association.
4. Vehicle Emission Control. Second Edition. American Consolidated
Industries, Inc. 1973.
VII. FUEL ECONOMY
1. Panzer, J. Fuel Economy Improvements Through Emissions I/M.
Exxon Research and Engineering Co. Paper presented at SAE
Automotive Engineering Congress. Detroit. Paper No. 760003.
February 1976.
2. Clewell, D.H. Impact of Automotive Emissions Regulations on
Gasoline Demand. Mobile Oil Corp. W.J. Kuckl, Mobile Research
and Development Corp. Paper presented at SAE Energy and the
Automobile Conference. Detroit. Paper No. 730515. May 15, 1973.
3. Elston, J.C. Criteria for Evaluating Vehicle In-Use Inspection/
Maintenance Impact on Emissions and Energy Conservation. New
Jersey Department of Environmental Protection. Paper presented
at SAE Energy and the Automobile Conference. Detroit. Paper No.
730522. May 15, 1973.
4. Oberdorfer, Dr. P.E. Reducing Fuel Consumption and Emissions by
an Optimizing Tune-Up. Sun Oil Company. Presented >.t. MVECC-IV,
Anaheim, California. November 1975.
93
-------
VIII. ECONOMIC CONSIDERATIONS
1. Downing, Paul B. An Economic Analysis of Periodic Vehicle In-
spection Programs. Atmospheric Environment. 7:1237-1246.
1973.
2. Midler, Joseph L. and Owen P. Hall, Jr. Critical Uncertainties
in Cost-Effectiveness of Exhaust Emission Control Programs. TRW.
(Paper Presented at APCA Annual Meeting. Boston, Mass. 1975.)
3. Hall, Jr., Owen P. and Neal A. Richardson. The Economic Effective-
ness of Vehicle Inspection/Maintenance as a Means for Reducing
Exhaust Emissions: A Quantitative Appraisal (Report on
CRC-APRAC Project CAPE-13-68). TRW, Inc. Paper presented at SAE
Automotive Engineering Congress, Detroit, Michigan. Paper No.
740131. February 1974.
IX. ENGINE DETERIORATION
1. Report on a Study of Emission Deterioration and Engine Degrada-
tion for Colorado. Automotive Testing Labs. Inc., Colorado. 1974,
2. Degradation Effects on Motor Vehicle Exhaust Emissions. Prepared
for California Air Resources Board by Olson Laboratories, Inc.
Anaheim, California. March 1976.
X. HIGH ALTITUDE
1. Approval of Emission Control Modifications for High Altitudes on
New Motor Vehicles or Engines. EPA Office of Air Programs. MSPC
Program. June 8, 1972.
2. Vehicle Testing to Determine Feasibility of Emission Inspection
at High Altitudes. Automotive Testing Labs. Inc., Colorado.
Prepared for U.S. EPA. Contract No. 68-02-0439. September 1972.
3. Liljedahl and Terry. An Investigation of Idle Emissions I/M at Altitude
Automotive Testing Labs., and Sorrels. Colorado Department of Health.
J Air Pollut Contr Assoc. 26(4), Apr,il 1976.
94
-------
XI. MISCELLANEOUS
1. Analyses of Traffic and Air Quality Trends, TCP Effectivness, and
a Voluntary I/M Program in Washington and Oregon. GCA for EPA,
Region X. May 1975.
2. Horowitz, Joel. Transportation Controls are Really Needed in the
Air Cleanup Fight. U.S. EPA, Washington. Envir Sci and Technol.
8(9):800-805. September 1974.
3. A Pocket Guide to Periodic Motor Vehicle Inspection. Prepared by
Hamilton Test System.
4. A Pocket Guide to Emissions Inspection. Prepared by Hamilton Test
System.
5. Stork, Eric 0. Mobile Source Emission Control Strategy Paper.
Deputy Assistant Administrator, Mobile Source Air Pollution
Control.
6. Dekany, John P. and F. Peter Hutchins. Development of a Short
Test for 207(b): A Status Report. U.S. EPA, Emission Control
Technology Division. Presented at MVECC-IV, Anaheim, California.
November 1975.
7. Panzer, Jerome. Automotive Emissions Testing. Environmental
Science and Technology. 8(12):974-5. November 1974.
8. Policies for the Inclusion of Carbon Monoxide and Oxidant Controls
in State Implementation Plans (TCP Policy Paper) by Office of
Transportation and Land Use Planning, Office of Air and Waste
Management. U.S. Environmental Protection Agency. December 1975.
95
-------
GLOSSARY
Accuracy
Air Contaminants
Ambient Air
Approved Inspector
Authorized Station
Calibration Gases
Carbon Monoxide
Certificate of Compliance
The degree by which an instrument is able
to determine the true concentration of a
pollutant in the exhaust gas sampled.
Any fumes, smoke, particulate matter, vapor
gas, or any combination, but excluding water
vapor or stream condensate.
The surrounding or outside air.
An individual licensed for inspecting motor
vehicles and pollution control devices for
compliance with applicable regulations and
for installing, repairing and adjusting pollu-
tion control devices and motor vehicles to
meet applicable standards.
A station licensed for inspecting motor vehi-
cles and pollution control devices for com-
pliance with applicable regulations and for
installing, repairing and adjusting pollution
control devices and motor vehicles' to meet
applicable standards.
A blend of HC and CO gases using nitrogen as
& carrier gas.
A nonirritating, colorless, oderless gas at
standard conditions which has the molecular
form of CO.
A document which is issued upon completion of
the inspection which records the results of
the inspection and serves as proof of said
inspection for_ vehicle owner.
96
-------
Chassis Dynamometer
Crankcase Emissions
Drift
Emission Inspection
Program
Exhaust Gas Analyzer
Exhaust Emissions
Fleet Owner Authorized
Stations
Fleet Operator
A machine equipped with two parallel rollers
which support the rear wheels of a motor vehi-
cle. When positioned on the dynamometer the
vehicle may be "driven" to simulate the load-
ings the engine would experience when the ve-
hicle is operated on the road. A power ab-
sorption unit is connected to the rollers to
simulate the loading from the various sources
of fluid and mechanical friction present
during road operation. Weights can also be
coupled to the rollers to simulate the iner-
tial effects of vehicle mass during accelera-
tion and deceleration.
The products of combustion emitted into the
ambient air from portions of the engine
crankcase ventilation or lubrication system.
The amount of meter reading change over a
period of time. Zero drift refers to change
of zero reading. Span drift refers to a change
in reading of a calibration point on the
upper half of the scale. The calibration
point is established by reading a calibration
gas of known concentration.
An inspection and maintenance program in
which each vehicle is subjected at specified
intervals to a test of its emissions under spe-
cified conditions. The emission levels are
compared with a standard established for the
vehicle class. If the emissions are higher
than the standard, the vehicle is failed and
must be adjusted or repaired to bring its
emissions into compliance with the standard.
An instrument for sensing the amount of air
contaminants in the exhaust emissions of a
motor vehicle.
The products of combustion emitted into the
ambient air from any opening downstream of the
exhaust ports of a motor vehicle engine.
A permit issued to a qualified fleet owner to
perform vehicle emissions inspection limited
to his fleet only.
The owner of a fleet of three or more vehicles.
97
-------
Hang-Up
HC which clings to the surface of the sampling
and analyzer system in contact with the gas
sample stream which causes an erroneous in-
dication of HC in the measured value.
Heavy-Duty Vehicle
Hydrocarbons
Idle Test
Inspection and Mainte-
nance Program
Instrument
Key Mode Test
Light-Duty Vehicle
Loaded Mode Test
Medium-Duty Vehicle
Any motor vehicle designed for highway use
which has a gross vehicle weight of more than
10,000 pounds.
A compound whose molecular composition con-
sists of atoms of hydrogen and carbon only, HC.
An emission inspection program which measures
the exhaust emission from a motor vehicle
operating at idle. (No motion of the rear
wheels). A vehicle with an automatic trans-
mission may be in drive gear with brakes ap-
plied or in neutral gear.
A program to reduce emissions from in-use ve-
hicles through identifying vehicles that need
emissions control related maintenance and
requiring that maintenance be performed.
The system which samples and determines the
concentration of the pollutant gas.
A loaded mode test in which exhaust emissions
are measured at high and low cruise speeds
and at idle. The cruise speeds and dynamometer
power absorption settings vary with the weight
class of the vehicle. The dynamometer loading
in the high cruise range is higher than normal
load in order to more effectively expose mal-
functions leading to high emissions.
A motor vehicle designed for highway use of
less than 6000 pounds gross vehicle weight.
Further distinctions are sometimes made between
light-duty automobiles and light-duty trucks
such as pickup trucks.
An emission inspection program which measures
the exhaust emissions from a motor vehicle
operating under simulated road load on a
chassis dynamometer.
Any motor vehicle designed for highway use
which has a gross vehicle weight of more than
6000 pounds and less than 10.000 pounds.
98
-------
Model Year of Vehicle
Motor vehicle
Motorcycle
Positive Crankcase
Ventilation
Prescribed Inspection
Procedure
Registered Owner
Repeatability
Rejection Rate
Response Time
The production period of new vehicle or new
vehicle engines designated by the calendar
year in which such period ends.
Any self-propelled vehicle which is designed
primarily for travel on public right of ways
and which is used to transport persons and
property.
A motor vehicle having a seat or saddle for
use of the rider and designed to travel on
not more than three wheels in contact with
the ground, but excluding a tractor.
A system designed to return blowby gases from
the crankcase of the engine to the intake
manifold so that the gases are burned in the
engine. Blow-by gas is unbumed fuel/air
mixture which leaks past the piston rings into
the crankcase during the compression and
ignition cycles of the engine. Without posi-
tive crankcase ventilation these gases, which
are rich in hydrocarbons, escape to the
atmosphere.
Approved procedure for identifying vehicles
that need emissions control related mainte-
nance. In Nevada, also includes setting
vehicle to manufacturer's specifications.
An individual, firm, corporation or associa-
tion whose name appears in the files of the
motor vehicle registration division of the
department of motor vehicles as the person to
whom the vehicle is registered.
The instrument's capability to provide the
same value for successive measures of the
same sample.
The percentage of total vehicles tested in an
inspection/maintenance program in a given time
period that fail inspection and are required
to have maintenance performed.
The period of time required by an instrument
to provide meaningful results after a step
change in gas concentration level initiated
at the tailpipe sample probe.
99
-------
Smoke Small gasborne and airborne particles, exclu-
sive of water vapor, arising from a process of
combustion in sufficient number to be
observable.
Vehicle Dealer An individual, firm, corporation or associa-
tion who is licensed to sell motor vehicles.
Vehicle Emissions A specific emission limit allowed for a class
Standard of vehicles. The standard is normally ex-
pressed in terms of maximum allowable concen-
trations of pollutants (e.g., parts per
million). However, a standard could also be
expressed in terms of mass emissions per unit
of time or distance traveled (e.g., grams
per mile) .
100
-------
APPENDIX A
NUMBER OF LANES AND FACILITY COSTS FOR IDLE
AND LOADED MODE TESTING
101
-------
Table A-l. NUMBER OF NECESSARY LANES FOR STATE OR CONTRACTOR RUN SYSTEM
Necessary number of lanes
Test type
Idle mode
(4 min/test)
Loaded mode
(5 min/test)
Day of week
Monday
Midweek
Friday
Saturday
Suggested
number of
lanes
Monday
Midweek
Friday
Saturday
Suggested
number of
lanes
Equal monthly
distributions
4
5
7
9
7
5
7
9
11
9
All inspections
last 10 days
q
13
17
21
16
11
16
22
! 27
i 20
!
i
!
Normal case
3-6
4-8
S-ll
6-13
9
3-7
5-10
6-13
8-17
i
11
NOTE: Stations opened 10 hours/day
102
-------
Table A-2. CAPITAL AND ANNUAL OPERATING COSTS OF A
SINGLE LANE IDLE MODE FACILITY
Capital costs
Land @ $5/ft2 - 7,190 ft2 a $ 35,950
Bldg. @ $20/ft2 - 1,370 ft2 a $ 27,400
Landscaping and paving $ 10,000
Equipment $ 39,900
Emissions analyzer $ 6,800
Misc. tools $ 6,400
Office equipment $ 1,700
Mini computer $25,000
TOTAL CAPITAL COSTS
Annual costs
250
Amortization of capital investment over 10-year period $ 11,325
Interest on loan (10% of total capital investment)0 $ 1,130
Insurance (1% of total capital investment) $ 1,130
Labor
1 Supervisor: $16,100 per year $ 71,750
1 Senior Technician: $13,000 per year
1 Assistant Technician: $10,000 per year
2 Mechanics: $10,700 per year/mechanic
1 Clerk: $ 9,000 per year
1 Part-time Clerk $ 2,250 per year
Miscellaneous expenses
Laundry, office supplies, utilities, etc. $ 7,600
TOTAL ANNUAL COST $ 92,935
»q
Size estimates from TRW, Socio-Economic Impacts of the Proposed State
Transportation Control Plans: An Overview. November 1973.
v,
Analyzer cost from EPA, Region I memo dated March 24, 1975.
st
Paid in 1 year and amortized over 10 years.
103
-------
Table A-3. CAPITAL AND ANNUAL OPERATING COSTS OF A
DOUBLE LANE IDLE MODE FACILITY
Capital costs
Land @ $5/ft2 - 9750 ft2 $ 50,000
Building @ $20/ft2 - 1575 ft2 $ 31,500
Landscaping and paving $ 10,000
Equipment $ 46,700
Emissions analyzer $13,600
Misc. tools $ 6,400
Office equipment $ 1,700
Mini computer $25,000
TOTAL CAPITAL COSTS $138,200
Annual operating costj>
Amortization of capital investment over 10-year period $ 13,820
Interest on. loan (10% of total capital investment)3 $ 1,380
Insurance (173 of total capital investment) $ 1,380
Labor $117,450
1 Supervisor: $16,100 per year
3 Senior Technicians: $13,000 per year/technician
1 Assistant Technician: $10,000 per year
3 Mechanics: $10,700 per year/mechanic
2 Clerks: $ 9,000 per year/clerk
1 Part-time Clerk: $ 2,250 per year
Miscellaenous expenses
Laundry, office supplies, utilities, etc. $ 8,600
TOTAL ANNUAL COST $142,630
f*
Paid in 1 year and amortized over 10 years.
104
-------
Table A-4. CAPITAL AND ANNUAL OPERATING COSTS OF A
SINGLE LANE LOADED MODE FACILITY
Capital costs
a
Land @ $5/ft2 - 7,190 ft2 " $ 35,950
Bldg. @ $20/ft2 - 1,370 ft2 a $ 27,400
Landscaping and paving $ 10,000
Equipment $ 45,100
"Emissions analyzerb $12,000
Misc. tools $ 6,400
Office equipment S 1,700
Mini computer S25.000
TOTAL CAPITAL COSTS $118,450
Annual costs
Amortization of capital investment over 10-year period $ 11,845
Interest on loan (10% of total capital investment)0 $ 1,185,
Insurance (1% of total capital investment) ? 1,185
Labor $ 71,750
1 Supervisor: $16,100 per year
1 Senior Technician: $13,000 per year
1 Assistant Technician: $10,000 per year
2 Mechanics: $10,700 per year/mechanic
1 Clerk $ 9,000 per yesr
1 Part-time Clerk: $ 2,250 per year
Misce1lanepus expens e s
Laundry, office supplies, utilities, etc. $ 7,600
TOTAL ANNUAL COST $ 93,565
o
Size estimates :~rc
-------
TOTAL CAPITAL COSTS
$118,430
Annual costs
Amortization sf capital investment over 10-year period
Interest on leer- ^T1'. of total capital investment/c
Insurance (1% r>r *" :: .- capital investment)
Labor
1 Supervisor-
1 Senior Te '.bnician:
".. Assista*v; .'. V:;MV --
2 Mechanic.-;*
lerk
p-r " £
$16,100 per year
$13,000 per year
$10,000 per year
$10,700 per year/mechanic
:- 9,000 per year
fl 2,250 per year
$ 11,845
$ 1,185
$ 1,1"
$ 71,7.'v
Mis eel lane eu ?._>> '"' -,£ S;-/1.
Launch v, - - ..--- supplies, utilities, etc.
TOTAL ACTUAL JOS.C
Size es: :'. -.
°Paic ir.
.,% Socio-Economic Impact?
?'.ans; An Overview. Nove-
r.y A.
rtized over 10 years.
$ 7,600
$ 93,565
State
105
------- |