UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
WASHINGTON. D.C. 20460
NGV29137E
OFFICE OF THE
ADMINISTRATOR
TO- Regional Administrators
SUBJECT: Inspection and" Maintenance
*h* rISUn^ aT1 3uu^? af>s?me ?f tt* ^certainties which have surrounded
the ISM program. While it has been generally believed that I&M programs
are benenciaU uncertainties resulted from a lack of sufficient data, and
differences, even within the Agency, in interpreting that data. The
attached. document represents the end of a long process during which all
orfices in the Agency having an interest in the subject have reviewed
and interpreted the data and have jointly developed a position. The data
Included in the document is accordingly considered to be reliable, as are
the interpretations of the data, and the resulting projections.
Although some questions, noted in the paper, still exist, the document
represents EPA's position on the subject.
Some of the more important conclusions are as follows: (1) deterioration
Troni cars on the road is greater than we had previously expected;
(Z) inspection and maintenance programs will, in a cost effective manner
reduce pollutants from in use vehicles; (3) the short tests which we have
now developed can readily identify high polluting vehicles; and (4) most
of these vehicles can be repaired at a reasonable cost.
It is important that this document be circulated within your offic*
to appropriate: personnel and, of course, distributed to State and local~
agencies as well as to interested members of the public. I suggest that
you inform appropriate personnel that if they wish to discuss any portion
of the document they should contact Michael P. Walsh of the Mobile
Source Enforcement Division in Washington, D.C.
'John R. Quarles, Jr.
Deputy Administrator
Attachment
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THE NEED FOR AND BENEFITS OF INSPECTION
AND MAINTENANCE OF IN USE MOTOR VEHICLES
Michael P. Walsh
Mobile Source Enforcement Division
November 9-, 1976
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SUMMARY
This review of available data indicates that the Federal motor
vehicle control program is not reducing emissions from in-use cars
as rapidly as expected. Improper adjustments and a lack of proper
maintenance seem to be major reasons for the shortfall. The latest
technology with catalytic converters seems as sensitive as older cars
to proper maintenance and adjustment* although the results in
California with catalysts and air pumps are more encouraging. The
ability of short tests to identify high polluters is established and
the service industry seems capable of repairing failed cars at
reasonable cast. Casts of repairing catalyst cars are still somewhat
of a question although initial indications are that required repairs
will be similar to those on non-catalyst cars. Deterioration of vehicle
emission levels following I/M is still subject to some dispute but a
best estimate indicates that I/M will slow down the long term rate of
s
emission control degradation. I/M is an effective and cost effective •
means of bringing cars into compliance with standards and early results
from New Jersey's I/M program are. encouraging.
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TABLE OF CONTENTS _
_PAGE
The Need For I/M
Ability of Short Test to Identify High
Polluters 7
Getting Cars Repaired 9
Deterioration With I/M 10
The Benefits of A Good I/M Program 17
Costs of I/M ' 19
I/M Cost Effectiveness . 22
Results in New Jersey 22
Voluntary I/M 23
Conclusions 24
References 25
Figures 30
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Inspect? on/Maintenance (I/M) programs are intended to identify cars
which need remedial maintenance or adjustment and require repair on these
cars. Also by providing a general incentive for owners to maintain their
vehicles it is intended to bring about an overall improvement in fleet
maintenance and reduced emissions. They are an integral part of the
Federal motor vehicle control strategy. As illustrated in Figure 1, other
key elements of this strategy include certification, assembly line testing
and recall. Initially, prototype vehicles are certified by EPA. Certification
confirms that the cars are designed so as to be capable of meeting standards.
Assembly line testing of production cars is conducted to assure that vehicles,
as manufactured, meet standards. In-use surveillance is carried but to
assure that properly maintained vehicles continue to meet standards for
five years or 5Q,QQQ miles; engine families found out of compliance are
subject to recall. These are the three major elements of the Federal
Motor Vehicle Control Program (FMVCP), and their execution is solely a
Federal responsibility. However, compliance with standards is ultimately
dependent upon the vehicles being maintained and adjusted correctly.
Inspection/Maintenance is intended to address this final step to "close
the circle". I/M is primarily a state responsibility with Federal support
in the forms of technical assistance and Federally prescribed warranties
against equipment and performance defects. I/M programs will provide
incentives to vehicle owners to get the maintenance done, incentives
to the service industry to do the maintenance properly and incentives to
the manufacturer to make vehicles more serviceable. Through the recall
and warranty elements of the Federal Motor Vehicle Control Program (FMVCP),
there will be ample incentive to the manufacturer to design vehicles which
4 •--
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I/M has a prominent role in many of the most important components of
the Federal Motor Vehicle Control Program. To the extent that
I/W identifies, relatively rapidly, vehicles which may be out of
compliance it can feed this information back to the recall and assembly
line test programs thereby allowing EPA to focus investigations and test
orders on these vehicles. It is key to the warranty program by which
individuals can identify equipment defects and it is a legal requisite
for the warranty against performance defects which are detected by a
Federally prescribed short inspection test. It is also the major
ingredient in the federal anti-tampering program, as the threat of I/M
failure is considered a strong deterrent to tampering. Without inspection/
maintenance, all of these programs are significantly weakened.
The need for and benefits of inspection/maintenance has been the
subject of intense controversy since the motor vehicle was identified
as a major air pollution source in the United States. It began when it
1 2*
was established that emissions were related to vehicle adjustment, '
and was intensified when manufacturers opted for modified adjustments on
vehicles as the major thrust of their initial emission control techniques.
As early as 1964, a study had been performed which showed initial emission
reductions on the order of 30% for hydrocarbons and 15% for carbon monoxide
$
were possible by means of a smog tune-up. This initial reduction has
subsequently been verified many times (see Figure 2) and even greater
initial benefits have been demonstrated. '
Unfortunately, much of the debate over I/M has taken place without the
Benefit of sufficient data to resolve other questions such as
deterioration of cars without I/M, adequacy of short tests to identify
polluting, cars .fesoeciallv if thev are ecuiooed with c»t?7v«,t^.
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abiTity of the service industry to repair high polluting cars and their '
deterioration subsequent to repair. In the absence of data* the debate
continued. Advocates of I/M argue that the benefits of emission control
depend upon proper maintenance and that I/M programs are both effective
and cost-effective means of assuring proper maintenance. Moreover, they
continue without programs of this type» much of the potential benefit of
8
the Federal Motor Vehicle Control Program will be lostt
On the other hand,, opponents of inspection/maintenance have argued
that the FMVCP can solve the emissions problem without I/M as newer tech-
nologies much less sensitive to maintenance are placed on cars', In the
recent past, many people were pointing to the catalytic converter as such
a maintenance insensitive technology, Opponents have also argued that
there is no good short test which correlates with the full Federal Test
Procedure (FTP), and that therefore the benefits and cost-effectiveness of
I/M will be quite poor. T In addition, it has been argued that consumers,
the owners of motor vehicles, will be thrown into the hands of an inadequate
service industry and that I/M is just a means of passing the buck from the
automobile manufacturers to individual consumers, thus shifting the burden
for cleaning up the motor vehicle air pollution problem from those respon-
sible for it.12
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The purpose of this paper is to review the available data to see
what this data reveals about the technical concerns which go to the
heart of the need for and benefits of inspection/maintenance. Particular
focus will be on deterioration of in-use vehicles with and without
inspection/maintenance, the ability of short tests to identify cars which
need remedial maintenance, the ability of the service industry to repair
high polluting cars and the costs and cost-effectiveness of I/M.
THE NEED FOR I/M
To the extent that cars in use meet standards throughout their
useful lives without the existence of I/M programs there is no need for
I/M programs. Conversely, to the extent that vehicles fail to meet
•
standards there is a need for additional strategies to lower emission
levels. I/M,of course,is one such option.
Figure 3 compares CO and HC exhaust emission levels based on data
collected during 1975 as part of the FY 74 emission factor program ' *
with those most..recently published- by;-.EPA; ... For carbon monoxide, the
measured results are consistently higher than the estimates while for
HC the differences are insignificant except for 1975 cars. Based on these
new data, as well as data collected from previous emission factor programs,
17 18
new estimates of emission deterioration have been projected ' and these
are contrasted with the earlier estimates in Figures 4 and 5. These figures
show emission estimates normalizad according to -their respective stanoards and
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indicate that previous estimates of 1975 model year emissions were
optimistic,, especially for carbon monoxide. In summary, the previous
predictions that average emissions would initially meet standards and
continue to do so for six or seven years for carbon monoxide, and two
or three years for hydrocarbons have been found overly optimistic.
Estimates based on the data now indicate that carbon monoxide emissions
are initially higher than- had been estimated, exceeding standards on the
average in the first year, and are projected to deteriorate rapidly in
subsequent years. For hydrocarbons, initial emissions are slightly higher
than estimated and are projected to exceed the standard on average after
about one year- The relationship of emissions for pre-1975 model year
cars to their appropriate standards as a function of time is similar to
the relationship for 1975 models.
The first question that comes, to mind is why do vehicles in use emit
at such high levels? The studies summarized in Figures 5 and 7 indicate
that the major reason is a lack of proper maintenance and/or proper adjustment
on in-use vehicles. More specifically, for 1973 model year vehicles with
approximately 15,000 accumulated miles, two different studies were carried
out. One focused on vehicles maintained according to manufacturers'
instructions and which were carefully tuned-up prior to testing. The other
focused on vehicles tested without special preparation, i.e., vehicles in their
20
normal state of maintenance. As the figures illustrate, carbon monoxide and
hydrocarbon levels for the normally maintained cars are substantially greater
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than for those maintained and tuned according to manufacturers' specifications.
For 1975 vehicles, parallel studies have not been done, except for normally
21
maintained cars at an average of about 8000 miles. The normally maintained
cars were subdivided according to idle adjustment into "properly adjusted"
0?
and "improperly adjusted" subclasses. These data indicate that the sensitivity
to idle adjustment may be even greater for 1975 models than it had been in
earlier model years, and again the impact is most significant, for carbon
monoxide.
Recent data have also been collected on 1975 cars in California '
and these data, summarized in Figure 8, show that. California cars are
considerably cleaner than 4-9 state cars, relative to their respective standards,
although at least some of the data indicates that they are dirtier than
expected. The reason for the relative cleanliness of the California vehicles
25
is somewhat speculative. The California assembly line test program may be
responsible; the mild climate may lead to less tampering than in other areas;
the state's certified repair facilities may result in better vehicle
maintenance; the technology which places much greater emphasis on air pumps
may be more forgiving of maladjustments or less Hke-ly to receive them because
of better driveability; the Title 13 Program which requires dealers to properly
set cars following maintenance may keep emission levels low; the tradition
which has been established over many years in California of controlling emissions
from cars, though difficult to quantify, may have the greatest impact of all.
Analysis by the California Air Resources Board however, indicates that
considerable tampering is going on, perhaps affecting as many as 15 - 20% of
1975 MY cars. Carefully screened 49 state cars have shown as much as 20
26
-25% tampering on 1975 cars after only one year. Since EPA studies have
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27 28
shown that tampering increases with vehicle age, * this raises questions
about the long term effectiveness of the California and 49 state vehicle
emission controls. A particular question for all of these vehicles is,
what will happen to the emission controls after 50,000 miles? The
Federal tools of recall and warranties are applicable only for 5 years
or 50,000 miles»whichever is less. I/M is the only compliance technique
which provides for the periodic evaluation of whether vehicles in use
continue to control emissions throughout their life.
Although many questions remain', two firm conlusions can be drawn. First,
with the possible exception of California, it is clear the Federal Motor
Vehicle Control Program (FMVCP) is not fully achieving its goal of bringing
cars in actual use into compliance with standards. Second, the lack of
proper vehicle maintenance and, particularly-for 1975 models, improper
vehicle adjustment seem to be primary reasons for the shortfall. Recognizing
the problem, attention must be focused on the questions of whether I/M can ,
identify the high polluting vehicles, whether such vehicles can be repaired,
the costs of such repairs and, in general, the overall emission reduction.
ABILITY OF SHORT TEST TO IDENTIFY HIGH POLLUTERS
How well can I/M do its job? The first question in this regard is how
well can an I/M short test identify high polluting vehicles? The full
Federal Test Procedure (FTP) of course, is the best true measure of a
vehicle's pollution characteristics but this is too expensive and time
consuming to be considered for a large scale I/M program. Several short
tests (idle, key mode, Federal three mode among others) which are better
suited to I/M have been investigated in terms of their ability to predict
FTP emission levels in a consistent reliable manner but the results have
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not been too encouraging.53 However the results have been very encouraging
in- terms of being able to predict whether a car would pass or fail the
standard on the FTP. In effect, though the short tests have not demon-
strated the ability to predict the absolute FTP result with any high degree
of" confidence, they have shown, that they can discriminate with high confi-
dence between clean and dirty cars. For example, based on data collected
29
in the FY 74 emission factor program, a recent EPA study selected cut-
points for the idle test which give approximately the same rate of errors
of commission (cars failing the short test but which would pass the full
federal test procedure) as the federal test procedure itself would give
30 31 32
i.e., 5% of the total population, *' Vehicles were then screened ac-
cording to these cutpoints with results as shown in Figure 9. These data
suggest that the idle test is capable of segregating low polluting cars
from high polluting cars.
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GETTING CARS REPAIRED
Once the polluters are identified, it is up to the service industry
to repair the cars. Questions have been raised about the ability of the
service industry to do these repairs as well as the cost of repairs.
Figure 10 shows the types of repairs required to pass the Portland I/M
program and Figure IT shows the associated costs for vehicles tested by
the Portland, Oregon, New Jersey and Arizona I/M programs through early
34
1976~ These data show that the types of repairs that are needed to pass
an I/M program are mainly carburetor adjustments and tune-ups, repairs
that are within the capabilities of the service industry today. Less than
10%. of the failing vehicles in Oregon required repairs costing more than
$50.00; in Arizona, this percentage was up to 14% while in New Jersey it
was 22%. The costs of repairs is reasonable in each case. Over 70% of the
repairs in Oregon cost less than $10.00 and the average is under $20.00.
In New Jersey, 55£ of the repairs cost less than $25.00 and the average
is under $35.00. In Arizona 66% of the repairs cost less than $25,00 and
the average is about $25.00. The present average I/M associated repair
cost is below the average cost generally experienced for a tune up.
Higher repair costs are reasonably expected in New Jersey, since the less
stringent standards applicable there will concentrate failures in the cars
with more serious problems.
Since virtually all the repair and cost data are based on results with
pre 1975 cars,, major questions remain regarding the ability of the service
industry to repair catalyst cars and the associated costs of such repairs.
Recall testing carried out on certain catalyst equipped 1975 models indi-
cates that repairs similar to those listed in Figure 10 were
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sufficient to restore these cars to a degree necessary to pass the idle
test with concomitant FTP emission reductions. However, these results
are preliminary and somewhat speculative with regard to other engine
families. Better data should be available in the relatively near
future- from the EPA restorative maintenance study which is currently
in progress.
The New Jersey program has also demonstrated that the service industry
can change in response to an I/M program. During the first year of the
voluntary program in New Jersey, after failing vehicles were fixed,.
on retest, their failure rate was still consistently above 40%. However,
within two to three months after the program became mandatory, the failure
rate on retest fell to approximately 18%. This strongly indicated that a
mechanics learning process was taking place. Mechanics now had to fix
the vehicles properly because owner's had an independent check on the
quality of repair. Training programs were developed by private industry
in: order to address the needs of the service industry. In particular, the
EXXON Corporation provided a training program for most of its own service
stations to be sure that work done by those stations would not result in
38
complaints. At this time, some stations in New Jersey advertise that
they will guarantee their repairs and that the work that they do will
assure passing the inspection/maintenance program.
DETERIORATION WITH I/M
Far and away the most important and controversial technical issues
regarding I/M effectiveness focus on deterioration, both during the
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year between inspections on failed cars which are repaired and the long
term deterioration of an I/M fleet compared to deterioration which would
have occurred on that same fleet in the absence of an I/M program. In the
first case, the benefits over the course of a year are substantially less
if the failing cars once repaired, deteriorate back to their previous level
in 2-3 months compared to 12-15 months. Not only is the absolute emission
level to which these vehicles rise important, and the time it takes them to
rise to it, but the shape of the deterioration curve can be quite sig-
nificant. For example, as illustrated in Figure 13, the end of year emission
level could be reached by three different shapes of deterioration rates:
(1) A very rapid initial deterioration (possibly due to
tampering) with a gradual leveling off.
(2) A linear deterioration throughout the year.
(3) A very slow deterioration for most of the year with a
rapid climb at the end.
Traditionally, EPA has assumed a linear deterioration rate back to
the level which would exist without I/M, thereby concluding that the
39
annual benefits of I/M are about one-half the initial reductions.
TO date, only one study has been carried out which measured emissions
40
from the same group of cars over a full year period. These tests were
conducted during 1975 by Olson Laboratories for the California Air Resources
Board on four similar groups of 1968 through 1974- model year vehicles,
systematically selected to represent the proportions of these vehicles in
the January 1975 .California vehicle population. Only two groups, an I/M
-------
group and a control group were used in the analysis which is illustrated
in Figures 13 and 14-.. Figures 13 and 14- show emission levels [normalized
to initial test levels. Results are illustrated for all vehicles which
completed the program on one hand and for selected vehicles with deteriora-
tion rates less than 400% on the other. Each vehicle in the I/M group was
initially subjected to an idle test with approximately 41% failing, and
those which failed were given adjustments and repairs only sufficient to
pass the idle test limits. Vehicles were tested according to the 1972
FTP as received, and (idle test failures only) 'after repair and at 1, 3,.
6, 9 and 12 months. The control group was tested at the start and end of
, 41
the year. Although this study is not definitive, all analyses have
concluded that the previous EPA deterioration estimates with I/M are too
high.
When the data from all cars which have completed the years testing are
used, it appears that the I/M fleet deterioration rate is greater than
the control (non I/M fleet) deterioration rate. This deterioration how-
sver is not sufficient to bring these cars back to non-I/M levels within
the one year time frame. Moreover it has also been pointed out that
the control fleet deterioration" rate is unusually high for HC, and that
if more normal deterioration were observed the I/M fleet deterioration
42
could have reached the level of the non-I/M fleet by year's end. This
analysis led to the conclusion that the overall effectiveness of I/M in a
program's first year is approximately 70% of the immediate reduction
following repair at the start of the year,42'52
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A.-second : analysis., has focused on apparent discrepancies in the
data* the most extreme of which went from 4.88 grams per mile HC at
the 9 month test point to 110.07 grams per mile at the 12 month test
point- If data points are screened from both the I/M and non I/M fleets
*
according to a criteria of eliminating all cars with deterioration rates
greater than 400S, the I/M fleet is reduced from 109 to 105 cars and
the non I/M fleet from 91 to 86. The I/M fleet in this case deteriorates
at about the same rate as the -non I/M fleet and for HC does not even
return to its pre I/M level in the course of a year. For CO, the fleet
does deteriorate to the pre-I/M level but not to the non I/M control fleet
level.
A third approach has been even more subjective, focusing on a
theoretical comparison of possible differences between the I/M and non
I/M fleets that could impact on deterioration rates. On the one hand, it
has been postulated that the I/M fleet would have a lower rate of
deterioration because the quality of service would generally improve
resulting in better maintenance for all cars across the board. In addition,
ta the extent that defective vehicle components exist and are identified
and repaired in the I/M fleet, it is argued that the subsequent secondary
deterioration to other parts due to that defect (e.g., catalyst burn up
due to ignition misfire problems) will be eliminated or at least ameliorated.
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*
On the other hand, it has been argued that more tampering may be done
to the I/M fTeet to compensate for possible driveahility problems which
.•
exist when the vehicles are adjusted to low emission levels.
Based on a careful review of the available data and lengthy discus-
sions between the respective offices, it is the collective best judgement
of the technical staff that the deterioration rates of the I/M and non I/M
fleets are the same within the limits of accuracy of current data, over
one year, although there are those who still disagree. This judgement is
reflected in the draft revised Appendix N which was circulated for comment
on September 30, 1976.43
In the past, EPA has assumed that the percentages of emissions
reduction obtained from successive I/M cycles was identical to that achieved
in the first cycle. The assumption of a repeat performance was reasonable
given a further assumption that one year ofter an I/M cycle emissions
return to the levels that would have existed in the absence of I/M. How-
ever, with the tentative conclusion as stated above that the I/M fleet does
not deteriorate to the levels which would have existed in the absence of
I/M and if one further assumes that the I/M vehicles will deteriorate and
be repaired in future years in the same manner as in the first year, the
I/M benefits will increase with time. Over a long term in other words,
if both of these assumptions are true I/M programs will actually impact
on the lifetime deterioration of vehicles.
This is illustrated in Figure 15.
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Nc study exists or win exist for several years which proves or
disproves the hypothesis that I/M vehicles will deteriorate over their
lifetimes at a lower rate than non I/M vehicles. Concern has been
expressed that because of some of the assumptions made, vehicle emissions
are estimated to remain at or near standards throughout their entire life
if a maximum*" I/M program is properly applied. There is considerable
disagreement over whether this is actually possible.
•
Other sources of data however, were reviewed to determine if they would
shed any light on this issue. Figures 16 and 17 summarize linear regressions
of all available emission factor and in-use compliance CO and HC data for
T972- and 1973 model year cars normalized according to their respective zero
mile values. The emission factor data are representative of the normal
non-I/M emission levels of in-use cars while the IUCP data represent what
emission levels could be if all cars were properly maintained and tuned up
just prior to testing (this may be a most optimistic I/M case except for
the potential impact of I/M on the quality of maintenance performed).
There is a lot of scatter in the data but it does indicate that properly
maintained and tuned cars tend to have lower deterioration rates for CO
and HC than "normal" cars. While this does not prove that I/M cars would
have lower lifetime deterioration rates than non I/M cars, it does indicate
that to the extent that I/M results in more and better maintenance it would
tend to lower deterioration.
The only data available which address this point for catalyst cars are
from the FY 74 emission factor program and are summarized in Figures 18 and
19. It should be noted that these figures represent extrapolations
'semi-annual inspection,. 50% stringency factor with mechanic training
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of data from vehicTes with very Tittle mileage accumulation; the average
accumulation is only 8700 miles and 752 of the sample have fewer than
15,500 miles. With the data available* however, regressions of emissions
versus miles were developed for two groups of cars, those which would
fail an idle inspection test with a cut point of 1.555 CO and those vehicles
which would pass. The CO deterioration rate for failing cars is significantly
greater than for passing cars while the reverse is true for HC.
In.terms of average emissions over a 100,000 mile lifetime, CO emissions
are projected to be substantially lower for passing cars than for failing
cars» HC slightly lower.
One of the critical factors upon which the impact of I/M on long term
deterioration hinges is the use of constant short test cut points. It
has been argued that the use of constant'cut points would increase failure
rates over time which would be politically unacceptable leading to a
42
gradual loosening of these cut points. Such a loosening would reduce
any tendency to slower I/M vehicle deterioration rates. Of course, the
critical question here is whether there will be a shift in in-use vehicle
*
maintenance due to an I/M program or not, a shift which not only goes to
the amount of maintenance performed but probably more importantly to the
quality of maintenance and adjustments made.
Figure 20 summarizes the mean idle test emission levels in the New
44
Jersey I/M program for each model year vehicle tested. ' These data
show that idle emission levels are fairly stable in New Jersey, presumably
in response to the I/M program. A glance at failure rates over time as
shown in Figure 21 also indicates a fairly stable failure rate for cars mars
than a year old. Data collected in New York State and Pennsylvania as illustra
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in Figures 22 and 23 also show that idle emissions in Mew Jersey are
lower than in surrounding areas although negligibly so for HC. These
data tend to support the argument that the quality of adjustment will
improve with I/M and that therefore there will not be a need to relax
I/M cut points with time.
THE BENEFITS OF A GOOD I/M PROGRAM
Ultimately, the benefits of an I/M program depend on the quality of
the program which is implemented. A poorly designed or poorly managed
I/M program could result in very little or even 'no benefit. On the other
hand a well planned, well operated system could be the cornerstone of the
entire motor vehicle control effort in a given area. What distinquishes
a good program from a poorer one? At a minimum, any good program would
provid'e for the following: '
0) regular periodic inspection (at least annually) of all
vehicles for which emission reductions are needed.
(2) retest of failing vehicles following maintenance to
assure that necessary maintenance is performed.
C3) a careful and well designed quality control program to
assure the reliability of the inspection system and
equipment accuracy. This should include routine
maintenance, calibration and inspection of equipment
and routine auditing of results.
Some question exists whether a decentralized I/M program could ever
achieve the full benefits that I/M is estimated to be capable of. If it is
to do so, certain additional provisions such as the following must at a
minimum be included:
(4} licensing of the inspection facilities which assures the use
of proper equipment in an acceptable manner by people 'who
have been adequately trained.
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(5) maintenance of records on each vehicle inspected including
vehicle descriptive data, test results and vehicle operator
signatures. Records must also be maintained on the calibration
of testing equipment.
(6) copies of these inspection records should be submitted on a
periodic basis to the governing agency for auditing.
(7) the governing agency should inspect each facility at least'
every ninety days to check the facilities' records, check
the- calibration of the testing equipment and observe that
proper test procedures are followed.
(8) the governing agency should have an effective program of
unannounced/unscheduled inspections both as a routine measure
and as a complaint investigative measure.
Finally, all good I/M programs should have provisions for dealing
directly with the service industry to keep them informed of system changes,
to handle consumer complaints and to assure that excessive tampering is
not taking place.
The absence of any or all of the above would tend to reduce the amount
of emission reductions achieved by an I/M program and could even make the
program worthless.
Based on the data presented in previous sections on emissions deterioration
without I/M, idle test/FTP correlation etc., and further based upon certain
key assumptions regarding service industry repair capability and deterioration
following such repair, also discussed previously, I/M emission reduction
47 48
estimates have been generated using computerized models.' ' The results
indicate that the benefits of a good inspection/maintenance program can be
significantly greater than had previously been believed. This conclusion is
summarized in Figures 24, 25 and 26 which reflect EPA's current estimates of
emissions with and without inspection/maintenance for 1975 and 1974 model cars.
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These figures show that stabilized emission reductions of 4-1% and 25%
are possible for CO and HC,. respectively, after several years of an I/M
program with catalyst cars at a 30% stringency factor. Higher or lower
numbers are possible if more or less stringent programs are implemented.
Since there is an almost infinite variety of options available to a
state in implementing a program (exemptions for vehicles requiring repairs
which cost in excess of some upper limit, selecting cutpoints which focus
on one or another pollutant exclusively, emphasizing fleet vehicles, to
give but three examples) the actual emission reductions attainable must be
estimated on a case by case basis.
As previously discussed, vehicles in use are deteriorating faster than
predicted. Accordingly, cities with mobile source air pollution problems
cannot expect the improvement previously estimated in their transportation
control plans. However, I/M can do more than previously estimated and can
therefore make up much of the shortfall. Figures 27 and 28 illustrate the
significance of these new estimates for an average LLS. City* with a mobile
source air pollution problem as well as certain representative cities (Phoenix,
Boston, Seattle and Portland). These data show that the typical emission
reduction from 1970 to 1980 expected from the FMYCP has been reduced to
about 60% of the previous estimate for CO and about 70% for HC. If an
I/M program were instituted in each of these cities in 1977 with a 30%
stringency factor** and mechanic training, much of the short fall could be
*ayerage. -UUS. car populatfon.and average, mileage, growth rate,for areas with
"existing transportation control plans-. " . .-..
**Strfngency factor fs a measure, of th\e"rfgor of a-program-based on the
estfmated fraction of .'the.-vehicle, population whose emissions cauld exceed
cut'-points for eitfrer or'Both, carBon-iEonoxfde and hydrocarbons, were no
improvements "*n ma-intenanca habits or quality to take place as a result of
the program. ' ' • -
-------
-20-
regained. Whereas I/M was formerly estimated to be responsible for about
4£ and 10% of the total reduction from the FMVCP and I/M combined for CO
and HC respectively, the latest estimates attribute roughly a third to
I/M for each pollutant.
COSTS OF I/M
Cost data with regard to I/M are available from three main sources, the
CARB/Qlson study, analysis of existing programs by the Office of Transportation
and Land Use Policy (OTLUP) and the Office of Planning and Evaluation (OPE)
and are summarized in Figure 29.
In the CARB/Olson study, a comparison of the maintenance and fuel costs
was made between the I/M fleet and the control fleet over a one year period.
The results showed that while the maintenance costs were greater for the
I/M fleet than for the control fleet, they were more than offset by the fuel
savings (assuming $0.60 per gallon fuel prices] of the I/M fleet resulting
in a net annual savings of $0.4-2. This study did not estimate the inspection
fee which would be required to pay for system start up, administration and
operating costs. A close examination of the data collected in this study
indicates that the maintenance cost estimate is probably high in that
subsequent to being repaired sufficiently to pass the idle inspection test,
the repair costs for the remainder of the year were found to be higher for
the I/M fleet than for the non-I/M fleet. This seems counterintuitive in
that one would expect some of the repairs which were done for the I/M fleet
to be needed during the year.by the control fleet cars. One possible
explanation is that since there was less "control of the non-I/M fleet during
the year some of the repair costs on these cars were not reported. Of course,
-------
-Z1-
arr alternative explanation might be that the cars repaired to pass the
I/M program experienced driveability problems and were subsequently
"readjusted".to drive better and therefore had higher costs.
49 50
The OTLUP analyses ' were based upon data collected by operating
I/M programs and derived relationships between initial failure rates and
repair costs and fuel consumption. It included estimates of fixed and
operating costs of various program types. As in the CARS/Olson study,
OTLUP's analyses lead to the conclusion that incremental maintenance
costs are completely offset by fuel savings; therefore the entire program
costs would be fixed and operating expenses for the inspection, which
ranged from $1.76 to $1.92 per car.
42
The OPE analysis was based upon a very comprehensive review of all
existing I/M programs as well as studies of maintenance habits in the
absence of I/M. Fuel savings were not analyzed by OPE but maintenance
costs were found to range from somewhat lower to about the same as
previous estimates. The inspection costs to cover start up and operating
expenses were estimated to be higher than OTLUP's estimates.
Based upon all three studies a best estimate is that incremental
maintenance costs and fuel savings approximately offset each other and
that the average out of pocket costs of I/M will be about $5 per car.
Some individuals, however, may be significantly impacted with high repair
costs possibly coupled with increased fuel consumption.
-------
-22-
Not included in this analysis is another cost which is not a direct out
of packet cost but is still a perceived cost; this is the cost of time
spent getting one's vehicle inspected and in some cases repaired and
reinspected. OPE has estimated this time to average 21 minutes with an
average cost of about $1.75 per car.
There are no comprehensive cost data with regard to catalyst cars and
inspection/maintenance. While the inspection costs will be the same as
for non-catalyst cars there is considerable uncertainty with regard to
the repair costs. Limited low mileage data collected by EPA indicate
that no permanent catalyst damage has occurred and normal engine repairs
bring cars into compliance, therefore indicating that the repair costs would
be approximately the same as for non-catalyst vehicles. However, there is
concern that in the long term, extended use of vehicles out of adjustment
could result in permanent catalyst damage and therefore much higher repair
costs. To the extent that this is true, however, the effectiveness of I/M
should also increase.
I/M COST EFFECTIVENESS
Based on the cost data cited in Figure 29 and the latest estimates of
I/M effectiveness, the cost-effectiveness of I/M has been calculated.
These results, and for comparative purposes the estimated cost effectiveness
of reducing light duty vehicle emission standards from interim to statutory
51 59
levels and stage 1 Vapor Recovery are summarized in Figure 30. I/M is
shown to be quite cost effective.
-------
-23-
RESULTS IN NEH JERSEY
The first fully mandatory I/M program was instituted by the State
of New Jersey in February 1974. The developers of the program adopted a
gradual phase-in approach, starting with relatively lenient standards
to allow the public and the service industry to adapt to the program and
slowly tightening down the cut points to the level which they initially
deemed appropriate. They remained in Phase 1 until November of 1975, failing
approximately 12% of the cars which were inspected. Investigations carried
out by EPA have indicated that gross tampering has gone down in Mew Jersey,
from 10" in 1974 to 5% in 1975 (compared to 15% recorded in 1974 in
Washington, D.C., an area which while .it has not been demonstrated to be
an appropriate control group for New Jersey, is known to differ in at least
one significant respect, that it was without a mandatory I/M program in
27 28
1974). * While many factors could influence this, including the
energy crisis and the change in vehicle mix, it could also be at least
partly the result of the disincentive provided by I/M.
Finally, while air quality is influenced by many factors (meterology,
transport, emission standards, etc.] it is enough to note that average
ambient carbon monoxide levels and contraventions of the air quality
standard declined during this time period. These results are summarized in
Figures 31 and 32. Similar reductions in oxidant levels were not recorded
although this is not surprising since oxidant levels are much more impacted
by other sources, and the initial Hew Jersey cut points were oriented more to
carbon monoxide than hydrocarbons.
-------
-Z4-
VOLUNTARY I/M
In many areas of the country, private groups and fTeet managers have
'instituted inspection programs on their own just for the fuel economy and
maintenance benefits which are derived. Notable among these are the
California State Auto Association, the City of Phoenix and various fleets
of American Telephone and Telegraph. In the latter case, recent data from
Cincinnati Bell as summarized in Figure 33 indicate that the program may
have helped reverse a trend of rising running expenses (.less gasoline) for
their fleet. Similar reductions were noted in fuel costs as shown in
Figure 34, which may also be due to their new maintenance program.
CONCLUSIONS
This review of available data indicates that the Federal motor vehicle . .
control program is not reducing emissions from in-use cars as rapidly as
expected. Improper adjustments and a lack of proper maintenance seem to be
major reasons for the shortfall. The latest technology with catalytic
converters seems as sensitive as older cars to proper maintenance and adjustment,
although the results in California with catalysts and air pumps are encouraging.
The ability of short tests to identify high polluters is established and the
service industry seems capable of repairing failed cars at reasonable cost.
Costs of repairing catalyst cars are still somewhat of a question although
initial indications are that required repairs will be similar to those on
non-catalyst cars. Deterioration of vehicle emission levels following I/M
is still subject to some dispute but a best estimate indicates that I/M will
slow down the long term rate of-emission control degradation. I/M is an
effective means of bringing cars into compliance with standards and early
results from Mew Jersey's I/M program are encouraging.
-------
25
REFERENCES
1. WHAT ARE WE DOING ABOUT COMBUSTION? BY J.M. Campbell, AMA
(August 16-18, 1954) SAE Preprint
2. SOME EFFECTS OF ENGINE-FUEL VARIABLES ON EXHAUST-GAS HYDROCARBON
CONTENT BY F.G. Rounds, P.A. Bennett, and G.J. Nebel, CMC
(January 10, 1955) Presented at SAE 50th Annual Meeting
3. "USING THE ENGINE FOR EXHAUST CONTROL" BY C.M. Heinen, Chrysler
(November 1962) SAE Paper S355
4. SMOG TUNE-UP FOR OLDER CARS BY Miles L. Brubacher, Donel R. Olson
(April, 1964) SAE Paper S403
5. DATA ON EXHAUST EMISSION REDUCTION BY TUNE-UP BY John Hawley
(February 24, 1971) New York State Department of Environmental
Cons ervation
6. EFFECTIVENESS OF SHORT EMISSION INSPECTION TESTS IN REDUCING
EMISSIONS THROUGH MAINTENANCE BY R.R. Carlson, T.A. Huls,
S.G. Kuhrtz, G.M. Wilson (June 24-28, 1973) APCA Paper f73-80
7. THE NEED FOR A NATIONWIDE S.YSTEM OF COMPREHENSIVE PERIODIC MOTOR
VEHICLE INSPECTION BY The Automotive Industry Coordinating
Committee To Conserve Energy
8. THE NEED FOR AUTOMOTIVE EMISSION INSPECTION BY Miles L. Brubacher
(September 20, 1972)
9. CLEARING THE AIR Federal Policy on Automotive Emissions Control
BY Henry D. Jacoby, John D. Steinbruner, and Others/--Ballinger
Publishing Co., 1973
10. THE AUTOMOBILE AND THE REGULATION OF ITS IMPACT ON THE ENVIRONMENT
BY Frank P. Grad, Albert J. Rosenthal, James A. Fay, John Keywood,
John F. Kain, Gregory K. Ingram, David Harrison, Jr., Thomas
Tietenberg (June 30, 1974)
11. ECONOMICS AND PUBLIC POLICY: THE AUTOMOBILE POLLUTION CASE BY
Donald N. Dewees MIT Press, 1974
12. VEHICLE INSPECTION AND MAINTENANCE FOR MASSACHUSETTS BY Greg
Conderacci (May 27, 1976)
13. HIGHLIGHTS FROM PRELIMINARY ANALYSIS OF RESULTS FROM EPA EMISSION
FACTOR SURVEILLANCE CONDUCED IN CHICAGO Eric 0. Stork to
Roger Strelow (November 14, 1975)
-------
26
14. 1974 EMISSION FACTOR PROGRAM Eric 0. Stark to John Hidinger,
B. Steigerwald, Norman Shutler (February 27, 1976}
15. PRELIMINARY DATA ON EXHAUST EMISSIONS FOR 1972-1975 MODEL YEAR
CARS FROM THE FY 1974 SURVEILLANCE PROGRAM Eric 0. Stork to
Roger Strelow
16. SUPPLEMENT NO. 5 FOR COMPILATION OF AIR POLLUTANT EMISSION FACTORS
U.S. Environmental Protection Agency (December 1975)
17. ESTIMATES OF EMISSION DETERIORATION FOR 1975 MODEL YEAR VEHICLES
Marcia Williams to John DeKany (August 6, 1976)
18. NEW ESTIMATES OF DETERIORATION FOR THE 1968-1974 MODEL YEARS
BASED ON THE CHANGE IN MEAN EMISSIONS OVER MILEAGE Lois Platte
to Eric Stork (September 13, 1976)
19. 1973 In Use Compliance Program
20. AUTOMOBILE EXHAUST EMISSION SURVEILLANCE ANALYSIS OF THE FY73
PROGRAM BY Jeffrey Bernard, Paul Donovan, H.T. McAdams,
.Calspan Corp. (July, 1975)
21. FY74 Emission Factor Program, preliminary data
22. EMISSIONS FROM PROPERLY ADJUSTED IN-USE VEHICLES, 1975 MODEL
YEAR (MSED INTERNAL MEMO)
23. FY74 Emission Factor Program, preliminary data
24. TELEPHONE CONVERSATION WITH CALIFORNIA AIR RESOURCES BOARD
REPRESENTATIVE (September 3, 1976)
25. DIFFERENCE BETWEEN CALIFORNIA AND 49-STATS EMISSION RESULTS
FOR 1975 MODEL YEAR CARS Michael P. Walsh to Norman D. Shutler
(June 17, 1976)
26. INTERNAL MSSD DATA
27. RESULTS OF THE D.C. TAMPERING SURVEY Albert K. Lee to Director,
Mobile Source Enforcement Division (June 10, 1974)
28. THE INCIDENCE OF TAMPERING ON CARS IN NEW JERSEY DURING 1975
Mobile Source Enforcement Division (June 22, 1976)
-------
27
29. COMMISSION/OMISSION ERROR RATES USING I/M CUT POINTS Michael
P. Walsh, to Benjamin R. Jackson (May 7, 1976)
30. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION Michael P. Walsh to
Norman. D. Shutler (November 20, 1975)
31. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION II Michael P. Walsh to
Norman D. Shulter (November 27, 1975)
32. ACCEPTABLE LEVEL OF ERRORS OF COMMISSION John P. DeKany to
Norman D. Shutler (December 12, 1975)
33. NEW JERSEY.,ARIZONA AND OREGON REPAIR COST DATA compiled BY
Joe Cutro (October 12, 1976)
34. CUMULATIVE COST-OF-REPAIR SUMMARY BY Oregon Department of
Environmental Quality,Vehicle Inspection Program (September
19, 1975 - April 30, 1976)
35. THE AUTOMOBILE TUNE-UP, Champion Spark Plug Company Second
Edition (April, 1975)
36. INTERNAL MSED DATA
37. NEW JERSEY'S AUTO EMISSION INSPECTION PROGRAM: AN ASSESSMENT
OF ONE YEAR'S MANDATORY OPERATION BY John C. Elston, Daniel
Cowperthwait (June, 1975) APCA Paper f75-42.3
38. EFFECTIVENESS OF MAINTENANCE IN REDUCING EMISSIONS BY Jerome
Panzer and Hugh F. Shannon, Exxon Research and Engineering
Company (September 25, 1974) MVECC III
39. 38FR15198, June 8, 1973, Appendix N, Emission Reduction Achievable
through Inspection Maintenance and Retrofit of Light Duty
Vehicles
40. DEGRADATION EFFECTS ON MOTOR VEHICLE EXHAUST EMISSIONS, Olson
Laboratories With State of California Air Resources Board
(March, 1976)
41. ISSUES REQUIRING RESOLUTION TO PERMIT COMPLETION OF APPENDIX N
REVISION Eric O. Stork to Ed Tuerk (August 23, 1976)
42. VOLUME 3: INSPECTION/MAINTENANCE: COST-EFFECTIVENESS AND
FEASIBILITY OF IMPLEMENTATION BY E.J. Bentz, Sandra J.
Bodmer-Turner, Barry Korfa,- William P. White III,
Office of Planning and Evaluation
-------
28
43. Draft Revised Appendix N, Hidinger to Addressees (September
30, 1976)
44. Discussion between R. Reichlen and Daniel Cowperthwait
45. Data from Walt Pienta, NYS DEC •
46. AEROSPACE REPORT ON "ANALYSIS OF REGIONAL DATA ON VEHICLE
IDLE EMISSIONS" John. P DeKany to Eric Stork (July 7, 1976)
47. COMPUTER SIMULATION OF EMISSION INSPECTION PROCEDURES - ASSESSMENT
OF EFFECTIVENESS By Marcia E. Williams (June, 1976) SAE
No. 760555
48. COMPUTER SIMULATION OF VEHICLE EMISSIONS FROM AN INSPECTION
AND MAINTENANCE PROGRAM Jay Wallace to Michael P. Walsh
(September 27, 1976)
49. BEST ESTIMATES OF I/M FUEL ECONOMY BENEFITS,'Joe Cutro,
OTLUP, 4/1/76.
50. BEST ESTIMATES.OF I/M COSTS TO CONSUMERS, Joe Cutro, OTLU?
51. DRAFT ENVIRONMENTAL AND INFLATIONARY IMPACT STATEMENT,
INTERIM HEAVY DUTY ENGINE REGULATIONS FOR 1979 and LATER
MODEL YEARS, MSAPC, 4/21/76.
52. OTLUP ANALYSIS OF CARB/OLSON STUDY, "DEGRADATION EFFECTS
ON MOTOR VEHICLE EXHAUST EMISSIONS," Joe Cutro (December 1975)
53. REGULATORY SUPPORT DOCUMENT SECTION 207 (b) NPRN,
THE EMISSION CONTROL TECHNOLOGY DIVISION MSAPC -..
9/21/76.
54. THE SHORT CYCLE PROJECT; EFFECTIVENESS OF SHORT EMISSION
INSPECTION TESTS IN REDUCING EMISSIONS THROUGH MAINTENANCE,
VOLUME 2-METHODOLOGY AND RESULTS, FINAL REPORT, EPA
CONTRACT 68-01-0410, OLSON LABORATORIES, INC. 31 JULY 1973.
55. HIGH ALTITUDE VEHICULAR EMISSION CONTROL PROGRAM;
VOL VII EXPERIMENTAL CHARACTERIZATION, D.R. Liljedahl
et al, AUTOMOTIVE TESTING' LABS, INTERIM REPORT
JULY 1974, STATE OF COLORADO.
56. CALIFORNIA VEHICLE INSPECTION PROGRAM.,. RIVERSIDE ;TRIAL
PROGRAM REPORT, OPERATIONS FROM 9/2/75 to 2/13/76, VOLUME 2-
SUMMARY REPORT, CALIFORNIA INSPECTION PROGRAM BRANCH,
BUREAU OF AUTOMOTIVE REPAIR, MAY 1976.
-------
29
57. IDLE EMISSION TESTING, PART III, J. Panzer, ESSO Research and
Engineering
53. DATA compiled by Joe Cutro, October 1976
59. COST EFFECTIVENESS OF STAGE 1 VAPOR RECOVERY AT SMALL BULK PLANTS,.
Robert R. Hunter to James J. Sakolosky, October 19, 1976
-------
PROTOTYPE
CERTIFICATION
PRECLUDE SALE
STATE
INSPECTION
PbQPER
MAINTENANCE
WARRANTIE
VEHICLES
CONFORM TO
STANDARD
ASSEMBLY-LINE
TESTING
IN-USE
SURVEILLANCE
RECALL
FIGURE 1
-------
! 1
FIGURE 2 !
I t
i ;
I/M STUDY RESULTS • 1
|
Fleetwide initial (imrvEsdiately following repair) Effectiveness i
i
PI1? Evaluations i
Short
Name of Study Test
Olscn Short Cycle 5/** Idle
" '• " Loaded
11 " " Loaded
t 55
ATL-TRW Colorado Idle
40
Olson Degradation Idle
56
CAKB-lUverside Idle
" ' " Loaded
" " Idle
Short Test Evaluations
Short
Name of Study 'Jest
Exxon 57 Idle
" Idle
11 Idle
58
New Jersey Idle
Special Sample
Conditions Size
299
149
w/ mechanic training 150
high altitude 55
144
. 238
393
1672
Special Sample
Conditions Size
i 396
M
II
9070*
Model
Years
1957-71
1957-71
1957-71
"••>
1964-73
1968-74
1955-74
1955-74
1975-76
Model
Years
1959-72
n
n
"thru '74
%
Failure
31
32
34
t
50
41
35
35
17,5
Failure
M
24
56
, 26
HC
21,
20,
33
18
23,
18,
17,
12
HC
22
23
35
26.
Emission Reduction i
(%) CO (%) NO^ (%) '
7 16,5 (-)l, 4 ;
3 15,9 0 . ; '
i :
22 (-)l. 5 I
1
12 HO, 8 ' j
i
1 14,8 (-)2,8 ;
8 15,0 1,4 |
3 15,6 (-)1,5 i
(est.) 22 (est.) 9 (egt,)
Emission Reduction
(%) CO (%) NOX (%)
i
11
i
!7
31
5 27,3
and after repair comparisons not performed on sane cars, Samole size is for all vehicles tested,
References
-------
FIGURE 3
EMISSIONS DURING CALENDAR YEAR 1975
MODEL YEAR
1975
1974
1973
1972
1971
1970
1969
1968
PRE-68
CARBON
AP-42
9.0
39.0
41.0
43.0
58.5
61.0
71.4
73.6
96.0
(1975 FTP)
•MONOXIDE
LATEST ESTIMATE*
23.7
43.2
50.0
56.8
63.6
70.3
77.1
83.9
117.2
f
HYDROCARBONS
AP-42
1.0
3.5
3.8
4.1
5.1
6.3
6.3
8.0
9.0
LATEST ESTIMATE*
1.4
3.4
4.1
4.7
5.4
6.0
6.6
7.3
9.4
* reflects latest emission data adjusted to reflect
July 1, 1975 emission levels.
-------
EMISSIONS DIVIDED BY STANDARDS Vs. CALENDER YEAR
i .as
at.sz
uS
of
en
en
cs
OT
Pi
m
01
rf
•a
a\
•3.01
Ui
I
I
as.
t .B
MCioen-
^^»CS™
ui
ni
or
ri
d
en
a
(Tl
-------
EMISSIONS DIVIDED BY STANDARDS Vs. CALENDER YEAR
a.czr
r .=
t.c
I
a
5
C3.S
O=»RBDM fia.viaxtos:
bra
r-
r-
trt
VEF1R
Of
si
i
a
en
[VI
3.21
2.S
2.CS
Ul
fi
ui
id
•CRt-ETNORF? VST3R
ai cri
r- r*
ct ai
en
CT
XI
-------
K Ut
CARBON MONOXIDE
973
tandard
39 /ml
53.5
1975
Standard
(15 g/ml)
23.01
12.7
Maintenance
and Tuned
1973 Model Vehicles
As Found
Condition
Avg, Mileii~15,QQQ
Proper
Adjustment*
All Vehicles
Tested
1975 Model Vehlclea Avg, Milea
-------
l.fif
I M
1.0
g
m
m
T
1,1
N
»— »
fn
p
z
Selected
All; All vehicles completing 12 month program
Selected: All vehicles except those showing deterioration in excess of
-t-
-h
H-
-t-
-t-
-t-
MPNTHS
FIGURE H
-------
SIGNIFICANCE OF MAINTENANCE
HYDROCARHONS '•
.973
Standard
4.07
1975
Standard
(1,5 e/m
1.01
1.33
Proper
Maintenance
and T uned
As Found
Condition
Proper
Adjustment*
All Vehicles
Tested
1973 Model Vehicles , Avg, Mlles^lS.OOO
1975 Model Vehicles Av{>. Mlles<10,000
adjustment means Idle CO levels equal to or less than 0,6$ for catalyst cars and equal to or
'less thah }.()% for hon catalyst cars,
-------
FIGURE 8
EMISSION DWA PRPM IN-UPK 1975' MODEL CALIFORNIA CARS
STDS
CO
HC
NOV
9.0
0.9
2.0
EPA ESTIMATE1/
75.. ....76 .
5.4 5.9
0.6 0.7
2.0 2.06
EPA DATA
CARD DATA
FY 74 EFPV FY75 EFp3/
5.7 (IB*)-7 10.6 (50%) 9.1
0.5 (0%) 0.7 (36%) 0.9
2.3 (35%) 2.7 (14%) 2.3
4/
43
8329
50%
14
19060
57%.
43
~>15,000
51%
No.
Miles
Failure Rate-Overall
(1) AP-42 (Supp, 5)
(2) Measured during calendar year 1975
(3) Measured during calendar year 1976
(4) Measured during calendar year 1976 by the California Air Resources Board
(5) Numbers in parentheses, refer to failure rates by pollutant
-------
FIGURE 9
CAN I/M IDENTIFY HIGH POLLUTING VEHICLES?
IDLE TEST IS EASIEST TEST
MEAN FTP RESULT MEAN FTP RESULT
CO RESULTS* 72 - 74 MY* £_ 75 - 76 MY** £_
CARS PASSING IDLE TEST 40,54 (39) 207 13.50 (15) 349
CARS FAILING IDLE TEST 65.39 290 36,73 230
IIC RESULTS*
i
CARS PASSING IDLE TEST 3.26 (3.4) 207 0.97 (1.5) 349
CARS FAILING IDLE TEST 4.92 290 1.03 230
*1DLE TEST POINTS SELECTED FOR 5% ERRORS OF COMMISSION; FTP vs. FTP CAN RESULT IN SAME COMMISSION
ERROR RATE ALTHOUGH LOWER OMISSION ERROR RATE
( ) STANDARDS
Data Source! FY 74 Emission Factor Program
*Pass/Fa11 outpoints for* Idle tests: 2.71% CO, 261 PPM !!C
**Pass/Fai1 outpoints for Idle tesU 1,0*» 160 PPM IIC
-------
FIGURE 8
EMISSION DKCA FROM H>HJPE 1*>75' MTDEL CAt JJOJRNIA CARS
CO
HC
NO
rx
5TDS
9.0
0,9
2.0
EPA ESTIMATE1/ EPA DATA
75 76
5.4 5.9
0.6 0.7
2.0 2.06
FY 74 EFP.2/_
. 5.7 (10%)-/
0.5 (0%)
2.3 (35%)
43
8329
50%
_F_Y75 EFJpV
10.6 (.50%)
0.7 (36%)
2.7 (14%)
14
19060
57%
CARD DATA 4,
9.1
0.9
2.3
43
^15,000
51%
No.
Miles
Failure Rate^Overall
(1) AP-42 (supp. 5)
(2) Measured during calendar year 1975
(3) Measured during calendar year 1976
(4) Measured durihg calendar year 1976 by the California Air Resources Board
(5) Numbers in parentheses, refer to failure rates by pollutant
-------
'.973
tatidatd
3.4
SIGNIFICANCE OF MAINTENANCE
HYDROCARBONS ,
1975
Standard
Ptopet
Maintenance
and T uned
As Found
Condition
1973 Model Vehicles , Avg. MilegMl5,oOO
1.01
1'ropet
Adjustment*
1.33
All Vehicles
Tested
1975 Model Vehicles AVR. MIletK 10,000
*pfoper adjustment toeans idle CO levels equal to or less than 0.6% for catalyst cars and equal to or
less than 1.0/6 for non catalyst cars.
-------
FIGURE 10
CAN SERVICE INDUSTRY REPAIR CARS?
OREGON RESULTS
TYPES OF REPAIRS NEEDED
CARBURETOR ADJUSTMENT 70%
TUNE UP 14%
ENGINE OVERHAUL 1«
VALVES , H
OTHER 6%
-------
FIGURE 11
REPAIR COSTS FOR EXISTING
PROGRAMS
New Jersey (.flunk rate - 12%)
less than $10
$10 to $25
$25 to $50
$50 to $100
29.7%
25.4%
22.1%.
nib re than $100
16.IS
5.6%
N = 16,000
Avg. Repair Cast = $32.97
Median: 50% of repairs cost
less than $21
65% of repairs cast less than
average
Arizona (flunk rate = 47%).
less than $5
$5 to $10
$10 to $25
$25 to S50
$50 to $100
more than $100
24%
17%
25%
20%
11%
3%
N = 4000 (does not include those
who performed their own repairs)
Avg~ Repair Cost = 25.42
Median: 50% of repairs cost
less than SI5
67% of repairs cost less than
average
Oregon (flunk rate = 35%)
No cost
less than $10
$10 to $30
$30 to $50
$50 to $75
$75.to $100
more than $100
32
40%
15%
6%
3%
2V
a
N = 6,527 (primarily newer cars)
Avg. Repair Cost = $18.86
Median: 50% of repairs cost
less than $6
79% of repairs cost less than
average
-------
FIGURE!?-
IMPACT OF POST MAINTENANCE DETERIORATION ON I/-1
EFFECTIVENESS OVER A SINGLE I/M CYCLE*
A HC EMISSIONS
RAPID
DETERIORATION
LINEAR
DETER 10PsAT I ON
SLOW
DETERIORATION
•TIME
EMISSION
REDUCTION
OBTAINED
* FOR PURPOSES OF ILLUSTRATION, THESE CURVES ASSUME THAT
THE I/M FLEET DETERIORATES SACK TO ITS PRE-I/M EMISSION
EVEL OVER ONE CYCLE AND THAT THE NON-I/M FLEET DOES
NOT DETERIORATE OVER THIS TIME PERIOD,
-------
in
z
q
fri
m
v:
1.1
u
n:
ri:
p
-y
Selecued
All; All vehicles completing 12 month prograpi
Solgcted; All vehicles except thooe showing deterioration In excess of 400%
~7~t-
MPNTHS
a
a •
FIGURE ,)3
-------
HYPRPCRRE5PNS
in
~z.
g
in
w
u
N
ft
}~
I'C
n
"Z.
tat1;
Control Group
All.
ivr
V<5*
SelectetJ
All} All vehicles completing 12 month program
Selected; All vehicles except those showing deterioration in excess of
—I—
MPNTHS
FIGURE- 14
-------
\I\
z
£3.
Ifl
yn
z
EI.
WTTtr r /v
*' -1- — *•* -i./ J.A
WITHOOT I/:-
EMISSIONS ': '
ELIMINATED 3Y I/M
WITHOUT i/:
WITH I/M
1 .
VEHICLE REE
Impact o
f _I/M_rieet_Dei
rioratica Races 0:
i Levels
-------
tu
-------
FIGURE 17
EMIS5IPN FRCTPRS-
-------
1 C2I0.
EEJ.
-ita.
2121.
CO GM/MI
FIGURE 18
DETERIORATION OF CO EMISSION Vs MILEAGE
1975 IN-USE VEHICLES
, MILEAGE (OOP) ,
Kl
fVJ
ta
n
ta
ta
in
ra
ISJ
m
-------
HC GM/m
FIGURE 10'
DETERIORATION OF HC EMISSION Vs MILEAGE
1975 IN-USE VEHICLES
.•a.
i.
-i—
MILEAGE (000)
Kl
td
PT
EJ
in
Kl
r-
cu
m
Kl
Kl
-------
FIGURE 20
Average Idle Test Emission Levels In Mew Jersey
1972 - 1976
c
o
o
t.
a
u
HEW JEnSEK DATA.
July I97Z to September 1975
S £
19S3 T.odct year
•j
S
YEAH
KSW JESSSi" aA?A
July 1972 to SepcaaSer 1975
ora 1353 social yaar
1973
1374
963
1373
197S
T*.\Z
-------
FIGURE 21
Failure Rates at
New Jersey
Calendar Year
Model Year
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
& Older
1972
10
23
30
18
26
24
.8
.6
.8
.0
.7
.1
1973
8
14
21
23
15
19
19
.7
.4
.1
.7
.5
.8
.1
1974
7.
15.
13.
27.
30.
20.
23.
21.
4
4
8
8
8
3
9
5 .
1975
16
14
16
19
26
29
21
24
19
.7
.5
.3
.7
.4
.6
. 4
.6
.2
197
—
13
17
21
25
32
22
27
13
6
.8
.1
.7
.9
.4
.4
. 1
.4
* Assumes phase I standards constant throughout this period
-------
H.K1
oY>
n
LJ
I .S:
.s:
3.7
3.3
3.0
ta.tzi
N.U. N.V. PF1.
IDLE TEST EMISSION RESULTS ON IN-USE VEHICLES DURING CALENDER YEAR 1975
(Based on Nationwide A9e Distribution for each Site).
FIGURE 22
-------
Di
Di
LJ
.J
I tad
CJ.IZI
317 PPM
322 PPM
330 PPM
N.t_L
N.Y.
Idle Test Emission Results on In-Ufse Vehicles During Calender Year 1975
••••
(Based on nationwide AqetDistribution fof Each Site)
'FIGURE 23
-------
EMISSION REDUCTIONS FRfflf I/f* PROGRAM AT'3G% STRINGENCY
Latest Estimate-No I/M
2. I/M witii Mechan
Trainin
FIR: YEIRR
FIGURE. 24 '
-------
303 STRINGENCY
ETL_ V El FT
____ tg
•- - en ...
LEGEND
1. Latest Estimate
Z. I/M with Mechanic
Training
3. I/M without Mechanic
Training
Hi ,
-7S MDO
c
LENDRR
Y
K
FIGURE 25
-------
FIGURE 26
LATEST ESTIMATES OF EMISSIONS REDUCTIONS
WITH A GOOD I/M PROGRAM-PERCENT
STRINGENCY
FACTOR
A-FIRST YEAR
.10
.20
.30
.40
.50
B-EIGHTH-'YEAR
.10
.20
.30
.40
.50 . '
CO
HC
PRE-CATALYST
3 (6)
3 (12)
13 (18)
19 (25)
22 (29)
CATALYST
PRE-CATALYST
21
26
31
37
40
(31)
(37)
(43)
(50)
(54)
8
20
28
33
37
25
38
46
51
55-
C-AVERAGE OVER VEHICLE LIFETIME
10
20
30
40
50
10 (16)
15 (22)
20 (28)
26 (35)
29 (39)
(11)
(24)
(33)
(39)
(44)
(33)
(46)
(55)
(61)
(66)
15 (19)
27 (32)
35 (41)
40 (47)
44 (52)
1
5
7
10
11
26
30
32
35
36
(4)
(9)
(12)
(16)
(18)
(36)
(41)
(44)
(48)
(50)
11 (17)
15 (22)
17 (25)
20 (29)
21 (31)
1
3
9
16
24
26
23
34
41
49
(4)
(7)
(14)
(22)
(31)
(33)
(36)
(43)
(51)
(60)
11 (15)
13 (18)
19 (25)
26 (33)
34 (42)
) with mechanic training
-------
Figure 27
FIWCP
CO
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LLJ KitTti
LU
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I/M A'pisunptions K\^\1
30% Stringency !.\\\N I/M
Program Starts in 1977
WI/A I/M '-II TM 1ECH, TRAINING
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-
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Figure 28
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CO
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I/M Assumptions
30% Stringency
Program Starts in 1977
CI .1 FMVCP
I/I
CD /•««
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LU
FORMER
/I////
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LATEST
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BOSTON
FORMER
LATEST
SEATTLE
FORMER
i
m
LATEST
PHOENIX
CITY
-------
CARS'*
Total
FIGURE 29
COSTS OF I/M
OTLUP^
OPE'*** BEST ESTIMATE
Maintenance 15.41
Fuel Savings -15.83
Inspection
9.60
-9.60
1.76-1.92
2.80-10.56
-
2.21-5.87
9.60
-9.60
5.00
5.00
Reference
**•
Reference 49,50
***Reference 42
-------
FIGURE
I/M COST EFFECTIVENESS ($/TON)
HC
CO
NEW APPENDIX N WITH
MECHANIC TRAINING
338.28
12.42
REDUCING LDV EMISSION
STANDARDS FROM INTERIM
TO STATUTORY
437
41
STAGE t VAPOR RECOVERY
446 - 1448
-------
-------
Figure 32
Contraventions of the Carbon Monoxide
Ambient Air Quality Standard at
Eighteen New Jersey Air Monitoring Sites*
irt 'd
c: n
O nJ
•r( ' 10
(U
H 0)
•|j -a
fi ••!
o x
o o
r;
M i o
O i-l
2000,
1500
1000
500
1971
1972 1973
il
I
1974 1975
Years
1976
1977
* Does not include Elizabeth Trailer, Atlantic City, Morriatown, and Trenton
-------
Figure 33
RECENT DATA FROH AT&T ON
CINCINNATI BELL FLEET
RUNNING EXPENSE LESS GASOLINE
PER 10,OOOM PER VEHICLE
1972 $610 $67*1
1973 708 693
1974 803 784
1975* 753 715
*No TUNE UP WITHOUT EXHAUST ANALYSIS
-------
3^..
BELL
CTJ
(2)
T003773
1044774
TOS7209
TG77324
T0595S3
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------- |