EPA-AA-IMG-84-1
Technical Report
Overview of I/M Activities and Issues
By
John Cabaniss
February 1984
NOTICE
Technical Reports do not necessarily represent final EPA
decisions or positions. They are intended to present
technical analysis of issues using data which are
currently available. The purpose in the release of such
reports is to facilitate the exchange of technical
information and to inform the public of technical
developments which may form the basis for a final EPA
decision, position or regulatory action.
Technical Support Staff
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air, Noise and Radiation
U. S. Environmental Protection Agency
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OVERVIEW OF I/M ACTIVITIES AND ISSUES
John M. Cabaniss, Jr.
Office of Mobile Sources
U.S. Environmental Protection Agency
Ann Arbor, Michigan
The 1977 Clean Air Act Amendments require motor vehicle
inspection/maintenance (I/M) programs in many areas which
could not attain the air quality standards for ozone or
carbon monoxide by the end of 1982. To date, twenty-one
programs have been successfully implemented across the United
States with another seven programs scheduled to be
implemented in the next six months. Current issues in
operating programs include non-compliance among vehicle
owners in some regionalized programs with sticker
enforcement, low reported failure rates in some decentralized
programs, and seemingly excessive waiver rates in some
programs.
EPA has traditionally provided and is continuing to
provide technical support to those States which are operating
or implementing I/M programs. This support includes the
development of effective enforcement and quality assurance
procedures. In addition, EPA is continuing to evaluate the
effectiveness of I/M programs, especially with respect to the
recent emission control technology characteristics of the
1981 and newer model year vehicles. Other current EPA
projects involve evaluating the effects of misfueling and
tampering on vehicle emissions and' developing a national
audit procedure for I/M programs.
There are several other aspects of I/M programs which
are receiving or soon will be receiving special attention.
Several States are incorporating I/M requirements for
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heavy-duty vehicles in order to address equity issues or to
gain additional emission reduction credits. Also many States
are now considering what changes may be necessary for their
programs to comply with the I/M-related emission performance
warranty [207(b)] requirements. A new 207(b) rulemaking is
presently in EPA steering committee review, and EPA is
planning a major 207(b) initiative after the rulemaking is
published in the Federal Register.
This paper was presented at the Air Pollution Control
Association's specialty meeting in Kansas City, Missouri on
February 15, 1984.
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OVERVIEW OF I/M ACTIVITIES AND ISSUES
Background
The requirement for motor vehicle inspection/maintenance
(I/M) programs stems from the 1977 Clean Air Act Amendments
(CAAA). The CAAA generally require that all nonattainment
areas meet the National Ambient Air Quality Standards by
1982. Recognizing that there were significant problems in
many areas with the transportation related pollutants ozone
and carbon monoxide, Congress included a provision for
attainment deadline extensions until 1987 for these two
pollutants. However, areas receiving such extensions were
required to meet certain conditions, including in most areas,
the requirement to implement an I/M program.
EPA policy limited the I/M requirement to urbanized
areas with populations of 200,000 or greater. Nevertheless,
I/M has been required in several cities with smaller
populations because of their inability to demonstrate
attainment by 1987 without an I/M program. Altogether, I/M
programs were required in thirty States and the District of
Columbia as a result of the CAAA. Except for those programs
in the cities with populations under 200,000, the I/M
implementation deadline established by EPA was December 31,
1982.
Implementation Status
The current implementation status of I/M programs
nationally is presented in Table I. The information included
in Table I identifies: 1) the States requiring I/M; 2) the
I/M areas within each State; 3) the type of I/M program in
each State; and 4) the start date or the scheduled start date
of each program. For ease in following the list
geographically, the States are listed in order starting in
the Northeast and progressing across the county to the
Northwest.
As displayed in Table I, there are currently twenty-one
operating I/M programs across the county. Of these, ten
programs are decentralized (seven of which were combined with
or related in some way to existing safety inspection
programs), six are centralized programs operated by
contractors, four are centralized programs operated by the
State or local government (three combined with existing
safety inspection programs), and one is a combined
decentralized and State-run centralized program. The longest
running program was started in New Jersey in February 1974,
and the newest program is in the Maryland program which
started in February 1984. All but four programs have started
since December 1981.
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TABLE I. I/M PROGRAM IMPLEMENTATION
STATUS AS OF FEBRUARY 15, 1984
State/Areas
Massachusetts
statewide
Rhode Island
statewide
Connecticut
statewide
New York
New York City
metro area
New Jersey
statewide
Pennsylvania
Philadelphia
Pittsburgh
Allentown
Delaware
Wilmington
Maryland
Baltimore
DC suburbs
Dis. of Columbia
Area-wide
Virginia
DC suburbs
North Carolina
Charlotte
Georgia
Atlanta
Tennessee
Memphis
Nashville
Program Type
Decentralized
Decentralized
Centralized Contractor
Decentralized
Decentralized
Centralized State-Run
Centralized Contractor
Centralized City-Run
Decentralized
Decentralized
Decentralized
Centralized City-Run
Centralized Contractor
Start Date
April 1983
January 1979
January 1983
January 1982
Combined Decentralized February 1974
and Centralized State-Run
June 1984
January 1983
February 1984
January 1983
December 1981
December 1982
April 1982
August 1983
July 1984
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TABLE I. (CONT'D)
State/Areas
I/M PROGRAM IMPLEMENTATION
STATUS AS OF FEBRUARY 15, 1984
Program Type
Start Date
Kentucky
Louisville
Cincinnati suburbs
Ohio
Cincinnati
Cleveland
Michigan
Detroit
Indiana
Chicago suburbs
Louisville suburbs
Illinois
Chicago
East St. Louis
Wisconsin
Milwaukee
Missouri
St. Louis
Texas
Houston
New Mexico
Albuquerque
Colorado
Denver
Ft. Collins
Colorado Springs
Utah
Salt Lake City
Arizona
Phoenix
Tucson
Centralized Contractor
unknown
unknown
unknown
Centralized State-Run
unknown
Centralized Contractor
Decentralized
Decentralized
Centralized Contractor
Decentralized
Decentralized
Centralized Contractor
January 1984
unknown
unknown
unknown
June 1984
unknown
April 1984
January 1984
January 1983;
expansion-
April 1984
January 1983
January 1982
May 1984
January 1977
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TABLE I. (CONT'D)
I/M PROGRAM IMPLEMENTATION
STATUS AS OF FEBRUARY 15, 1984
State/Areas
Nevada
La s Vega s
Reno*
Program Type
Decentralized
Start Date
October 1983
California
Los Angeles
Ventura
San Diego
San Francisco
Sacramento
Decentralized
March 1984
Fresno
Oregon
Portland
Medford*
Idaho
Boise*
Washington
Seattle
Spokane*
Alaska
Anchorage*
Fa irbanks*
Centralized State-Run
Decentralized
Centralized Contractor
unknown
unknown
unknown
July 1975
unknown
August 1984
January 1982
unknown
unknown
(1985)
*Areas under200,000 population.
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As shown in Table I, over the next six months, seven
additional I/M programs will be starting at the rate of about
one new program per month. Of these seven programs, four
will be decentralized programs, two will be centralized
contractor operations, and one will be a centralized
State-run program. Table II contains a list of these planned
programs arranged in chronological order by their scheduled
start dates.
TABLE II. I/M PROGRAMS SCHEDULED
TO BEGIN LATER IN 1984
State Start Date
California March 1984
All areas except Fresno
Wisconsin April 1984
Utah May 1984
Pennsylvania June 1984
Indiana June 1984
Tennessee (Nashville) July 1984
Idaho August 1984
The remaining four States (Illinois, Michigan, Ohio, and
Alaska) and Fresno County, California are classified as
"unknowns" in Table I. All of these areas are behind
schedule on I/M implementation. Illinois, Michigan, and
Fresno County, California are areas which EPA believes are
not complying .with the requirements of the CAAA. For that
reason, EPA has in each case begun the consultation process
required before EPA can impose transportation funding
limitations under Section 176 (a) of the Act.
Ohio and Alaska are also behind schedule but involve
different situations. Alaska's two I/M areas are both small
cities with significant carbon monoxide problems. The
particularly cold climate and other factors unique to Alaska
required a special feasibility study which has just been
completed. Because of this, EPA expects to receive a final
I/M plan from Alaska very soon.
In Ohio, both Cincinnati and Cleveland experienced
dramatic air quality improvements in 1980 and 1981. This
situation caused the State to be able to demonstrate
attainment by the end of 1982 in both cities in its 1982
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revision to the Ohio State Implementation Plan and, thus,
negate the need for an I/M program. However, 1983 air
quality data has shown that both areas actually remain in
nonattainment. Based on this new evidence, EPA has recently
notified the State that an I/M program must be implemented.
Two other areas (Medford, Oregon and Spokane,
Washington) are also listed as "unknowns" in Table I. These
latter two areas are both small cities with tentative I/M
plans. Medford has passed a local ordinance authorizing an
I/M program, but it is subject to a referendum in March. If
affirmed, the program is scheduled to start in Medford in the
fall of 1984. In Spokane the State included a commitment to
implement I/M in the 1979 revision of its State
Implementation Plan, if Spokane remained in nonattainment
beyond 1982. Because 1983 air quality data continued to show
violations, Spokane is now making plans for I/M
implementation by July 1985.
Issues in Operating Programs
Recent EPA evaluations have identified three primary
issues in the operating I/M programs:
1. High levels of non-compliance (in excess of 20
percent) among vehicles owners in some
regionalized programs with sticker enforcement
systems.
2. Low reported failure rates (less than half of
design) in some decentralized programs.
3. Seemingly excessive waiver rates in some programs
(waiver rates greater than 10 percent of failed
vehicles) .
EPA has always maintained that the most effective I/M
enforcement system is usually provided by denying vehicle
registration to noncomplying vehicles. However, States have
been allowed to use alternate enforcement methods, as long as
they were as effective as a registration denial system.
Because of their popularity in safety inspection programs,
many States have opted to use sticker enforcement systems in
their I/M programs. In regionalized I/M programs, however,
sticker systems have not worked well because of several
factors:
1. In regionalized I/M programs, there are many
unstickered, excluded vehicles on local streets.
Therefore, it is difficult for police to determine
whether an unstickered vehicle is actually a
violator.
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2. Stickers themselves are sometimes not designed
such that violators can be easily determined.
3. Stickers are usually on the windshield, whereas
the license plate (which may identify county or
month of inspection) is usually on the rear of
vehicle, thus confounding the comparison of the
two in order to judge compliance.
4. Police are often prohibited from citing parked
vehicles; therefore, the only vehicles closely
examined for compliance are those stopped for
other reasons.
5. Police often do not give as much priority to
enforcement of inspection stickers as they could.
Some decentralized I/M programs are experiencing low
reported failure rates. In evaluating I/M programs, EPA has
found that the reported failure rates in decentralized I/M
programs are often less than in comparable centralized
programs. Part of this phenomenon may be explained by
pre-inspection repairs or tune-ups. Another explanation may
be that inspection personnel take shortcuts in recording
inspection data and do not always report initial emissions
failures which they repair and retest immediately. EPA
believes that each of these arguments is valid to an extent,
but that these factors should not dramatically lower the
reported failure rates.
Investigations of these problems are under way to
determine the causes for the low reported failure rates and
identify any needed program modifications to address the
problem. Such modifications could include:
1. More stringent I/M emission standards.
2. Retraining of inspection personnel on record
keeping procedures.
3. Changes in inspection forms to allow better, or
Changes in inspection fo
easier, recording of data.
Some States are reporting seemingly high waiver rates.
High waiver rates are a concern because, in general, lower
emissions reductions are obtained from waived vehicles. High
waiver rates are often symptomatic of other problems. For
instance, high waiver rates can sometimes indicate a problem
with the competence of mechanics and, thus, a need for more
mechanic training. Poor analyzer quality control practices
in repair garages can also cause waiver rates to be high
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because a mechanic, relying on an inaccurate analyzer, may
inadequately repair the vehicle before it is submitted for
retesting. There may also be problems, in some cases, with
the procedures used in issuing waivers or in the criteria on
which waivers are based. Sometimes, for instance, the waiver
repair cost limit may be too low, or there may not be a
provision to prevent tampered vehicles from receiving waivers.
In addition to the primary issues noted above, EPA has
also noted several lesser problems in evaluating the
operating I/M programs. In some cases, minor problems have
been noted with analyzer maintenance and quality control
procedures, especially in the area of finding and repairing
system leaks. There have also been some reported problems
with data collection, both in manual and automatic data
collection systems.
Current EPA I/M Projects
Current EPA projects related to I/M programs can be
broadly divided into three catagories:
1. Projects related to 1981 and newer vehicles.
2. Projects related to optimizing the quality of I/M
programs.
3. Projects related to misfueling and tampering.
EPA presently has several I/M projects under way which
relate to 1981 and newer vehicles. The overall purpose of
these projects is to determine how the new technology 1981
and newer vehicles behave in use and in I/M programs. Since
these vehicles will comprise a large fraction of the fleet by
1987, information from these projects will help in
identifying how to optimize I/M effectiveness.
In one project, inspection data over several years from
the Arizona and Seattle, Washington I/M programs are being
analyzed. These I/M data are being analyzed for failure
rates of the 1981 and newer vehicles overall as well as by
make, manufacturer, model year, engine family, and fuel
control system. In addition, vehicles which fail in one year
are being tracked through later years to determine whether
there are recurring problems with the same vehicles.
Another project involves analyses of data collected in
the New York City taxi I/M program. Taxis in New York City
are required to undergo emissions inspections thrice annually
because of their rapid mileage accumulation rates. This
data, therefore, will provide some insight into the in-use
performance of 1981 and newer vehicles at high mileage levels.
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EPA is also conducting a test program in the Washington,
D.C. area to study how 1981 and newer vehicles behave in an
I/M situation. This project is similar to the Portland study
which was conducted in the late 1970 "s and examined
pre-catalyst and oxidation catalyst vehicles. Vehicles (1981
and newer only) which fail the District of Columbia's I/M
test are being recruited for the program. Emissions from
these vehicles are then tested (using the Federal Test
Procedure) both before and after repair in order to determine
the amount of emissions reductions resulting from the
repairs. Information from this project will enable EPA to
better judge the effectiveness of I/M for the new technology
vehicles.
Other EPA projects deal with optimizing the quality of
I/M programs. The overall purpose of these projects is to
enable States to design and operate the most effective and
cost-effective programs possible. Information from these
projects can be used to evaluate overall I/M programs as well
as parts of programs. In addition, the strong and weak
points of each program can be identified and then shared
among all I/M program managers in order to allow the States
to learn from each others' successes and mistakes. Last
November, EPA held the first national I/M quality assurance
(QA) workshop in order to provide a forum to discuss I/M QA
issues. This workshop was very successful and EPA plans to
schedule similar workshops in the future.
One particular project which involves QA in I/M program
is the development of the National Air Audit System (NAAS).
The NAAS is a cooperative effort of EPA and the States in
developing a formal process whereby overall air quality
programs are evaluated to assure that the commitments in the
State Implementation Plans (SIP's) are being met. I/M
program audits, are an integral part of many SIP's and,
therefore, of the NAAS. The Office of Mobile Sources is
currently in the process of developing guidelines for
conducting I/M audits for inclusion in the NAAS in fiscal
year 1985. EPA views the I/M portion of the NAAS as
particularly important to the State air agencies. In most
cases, the responsibility for the I/M program in a State is
shared among several agencies with the air agency often
having primarily SIP oversight responsibilties and less
responsibility for the operating program. In these cases,
the I/M audit will provide an opportunity and process for the
air agency to review I/M program operations along with EPA.
EPA is also currently involved with several projects
regarding misfueling and tampering. The overall purpose of
these projects is to learn more about the effects of
misfueling and tampering on in-use emissions. Information
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from these projects will enable EPA to better determine the
relationship between the frequency of misfueling and
emissions deterioration, the high altitude effects of
tampering and misfueling, the extent of performance problems
related to tampering and misfueling, and the differences in
non-methane and methane fractions in misfueled vehicles. In
addition, these projects may assist in developing procedures
for determining whether in-use catalytic converters are still
active and for regenerating inactive catalytic converters.
Special Aspects of I/M
Three additional I/M aspects are currently receiving
special attention:
1. I/M for heavy-duty vehicles.
2. Emissions performance [207(b)] warranty.
3. High altitude problems.
I/M for heavy-duty vehicles (HDV) is not a new idea.
The Portland, Oregon and Arizona I/M programs have been
inspecting HDV since they began the mid-1970's. However,
because the I/M requirement only involves light-duty
vehicles, HDV have been excluded from many I/M programs.
Nevertheless, some States have already included HDV (or at
least some of them) in their I/M programs, including
Connecticut, Maryland, Pennsylvania, Kentucky (Louisville),
North Carolina, Indiana, Colorado, Utah, Arizona, California,
Oregon, and Washington. HDV have been included historically
because of equity reasons, but some States, notably New York
and New Jersey, are currently considering HDV I/M as an
additional source of emissions reductions in order to reach
attainment by 1987.
The emission performance [207(b)] warranty program is
also currently receiving special attention from both the
States and EPA. Now that many States have already
successfully implemented their I/M programs, they are
interested in ensuring that their programs qualify for 207(b)
coverage. Also EPA is in the process of finalizing a
rulemaking on 207(b) (currently in steering committee review)
which establishes special short tests for Ford vehicles and
provides some flexibility regarding the 207(b) quality
control requirements. On the latter, the new rulemaking will
allow EPA to approve alternate I/M quality control procedures
when a State can demonstrate that their overall quality
control program is at least as effective as that required by
the 207(b) regulations.
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After the rulemaking is published, EPA is planning to
undertake an initiative on 207 (b). In that process, EPA will
be developing some information documents about the 207(b)
warranty and its benefits and offering to assist States, as
may be necessary, in determining what, if any, changes may be
needed in their I/M programs in order to meet the warranty
requirements.
High altitude areas are also currently receiving some
special attention from EPA. In an effort to increase the
effectiveness of I/M repairs at high altitude, EPA is in the
process of developing a manual which will include the high
altitude performance adjustments developed by the automobile
manufacturer for light-duty vehicles, light-duty trucks, and
heavy-duty vehicles. The manual is being designed in a
format that is usable by repair mechanics in repairing
vehicles and by I/M officials in handling waivers or
resolving complaints. It is hoped that the manual will be
available by the early summer.
Another current high altitude effort involves developing
a way to identify low altitude vehicles being sold improperly
in high altitude areas. It is anticipated that EPA will try
to set up a referral system with the I/M programs operating
at high altitude in order to identify such cases.
Conclusion
This paper has summarized the national implementation
status of I/M programs, described the current issues in
operating programs, and briefly explained current EPA I/M
projects and other I/M aspects receiving special attention.
In summary, there are currently twenty-one operating I/M
programs with another seven scheduled to be implemented by
August 1984. EPA is continuing to provide technical support
to State and local agencies which are implementing and
operating I/M programs. EPA's major role on I/M at this time
is to assist the States in optimizing the quality of their
I/M programs.
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