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

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  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

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                              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

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                               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

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                         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

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                         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

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                           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

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                             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.

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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.

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    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

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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.

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         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.

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          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.

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                  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

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                               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

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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.

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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




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                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.

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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

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               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

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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

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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

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    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

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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

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                                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

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                   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

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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

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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

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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

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                                        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).

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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

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      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

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                   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

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 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

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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

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                              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

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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

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    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

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                  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

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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

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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

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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

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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

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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

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     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

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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

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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

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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

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                                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

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    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

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        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

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         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

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          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

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            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

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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

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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

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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

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         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

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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

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             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

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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

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     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

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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

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                           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

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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

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                              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

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    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

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      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

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    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

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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

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    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

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    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

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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

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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

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                               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

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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

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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

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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

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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

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                 APPENDIX A

NUMBER OF LANES AND FACILITY COSTS FOR IDLE
          AND LOADED MODE TESTING
                    101

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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

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          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

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           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

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           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
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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

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