IMS-002/QA-1
     Questions and Answers Concerning the
Technical Details of Inspection and Maintenance
                  April, 1979
       Inspection and Maintenance 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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                      Questions and Answers Concerning the
                 Technical Details of Inspection and Maintenance
1.   BENEFITS
    a) Air Quality - One question often asked is, will I/M programs really help
       to solve the CO and oxidant problems?  New Jersey has concluded that an
       annual reduction in average statewide CO concentrations of 3 percent is
       due to I/M.  Is other information available on measurable air quality
       benefits?  Will there be any observable oxidant benefits from I/M in the
       near future?

            Air quality data now available strongly suggest inspection and
            maintenance programs will result in improved air quality.

            A recent study of seven years of carbon monoxide (CO) data in New
            Jersey has led researchers to conclude that the I/M program, which
            began in 1974, and the increasingly stringent new car emission
            standards are together responsible for a 28 percent decrease in
            ambient carbon monoxide levels.   I/M was shown to increase the rate
            of improvement of ambient CO levels.  The University of Wisconsin
            statisticians found that the improvement in air quality occurred
            independent of year-to-year weather patterns and at a time when
            traffic volume was increasing.

            There is strong evidence that the general strategy of controlling
            automotive emissions is effective in reducing ozone levels.
            Officials from the South Coast Air Quality Management District
            attribute most of the credit for a decreasing trend in ozone levels
            in the Los Angeles Air Basin to controls on auto emissions.  The
            area's mean ozone concentration has fallen steadily from a high of
            0.228 ppm in 1956 to 0.125 in 1975.  In addition, the area has not
            experienced a Stage III ozone alert (0.50 ppm) since 1973.

            At this time, there are not studies which specifically relate the
            effects of tailpipe emission reductions resulting from I/M to
            reductions in ozone levels.  This is due to the complication of
            factors affecting oxidant levels such as meteorology, pollutant
            transport, and the impact of stationary hydrocarbon sources.
            Several more years of ozone data in I/M areas will be required
            before this analysis can be made.

     b) Emission Reductions: (FTP) - Arizona, New Jersey and Oregon have reported
       substantial reductions in idle emissions.  Arizona has also found reduc-
       tions in the two cruise modes for which it tests.  How do these results
       compare to reductions over the entire driving cycle?

            It is reasonable to expect HC and CO emission reductions at idle to
            carry over to a typical urban driving cycle since urban driving
            contains a significant portion of idle mode operation.  Data from
            the Portland Study substantiate this expected carry over in emis-
            sion reductions from the idle test to the Federal Test Procedure.
            As the table below indicates, the vehicles which failed the Oregon
            state inspection test (an idle test plus a brief physical inspec-
            tion) realize significant emission reductions over the entire
            Federal Test Procedure (FTP) driving cycle as well as at idle.

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                                  -2-
Initial Emission Reductions -
Vehicles Failing Portland Short Test
1975-77 Models

Idle HC
Idle CO
FTP HC
FTP CO

(ppm)
(gpm)
(gpm)
Initial
325
3.09
2.87
40.87
After Maint.
0
1
19
80
.17
.60
.36
% Change
-75.4
-94.5
-44.3
-52.6
1972-74
Initial
3
4
55
328
.20
.04
.30
Models
After Maint.
0
3
34
189
.72
.02
.41
% Change
-42
-77
-25
-37
.4
.5
.2
.8
        Data on loaded test FTP reductions  occurring  as  a result of I/M
        maintenance are not available from  an operating  I/M program, since
        no I/M program currently uses a loaded test to pass or fail cars.
        (Arizona performs the loaded test,  but a vehicle is passed or
        failed only on the basis of the idle  portion  of  the test.)  EPA's
        surveillance programs show a relationship  between high loaded mode
        emission values and high FTP emissions.  Thus, one would expect to
        see emission reductions over the full FTP  as  a result of performing
        maintenance which reduces emissions over the  loaded test.

c) Emission Reductions; (Failure Rate)  - Is there  a relationship between
   the failure rate in existing programs and  the emission reductions they
   achieve?

        The Portland study data for 1975-1977 model year cars have been
        analyzed to help determine the effect of failure rate on I/M pro-
        gram effectiveness and average cost of maintenance.  The results of
        the analysis are summarized in the  table below.   The 31% failure
        rate case is based upon an application of  the idle HC and idle CO
        cutpoints used by the Oregon State  inspection test.  The other five
        cases (27% to 6% failure rate)  were derived by moving cutpoints for
        idle HC and CO progressively higher in a systematic manner, thus
        simulating less stringent programs.
I/M Reductions and Costs
Failed Cars


Failure
Rate
31%
27%
22%
17%
11%
6%


Fleet %
FTP HC
27%
25%
24%
21%
16%
12%


Reductions
FTP CO
35%
33%
29%
27%
18%
12%
FTP
Before
Maint.
Level
2.67
2.85
3.10
3.26
3.73
4.66
HC
% Reduct.
due to
Maint.
42%
46%
49%
53%
63%
66%
FTP CO
Before
Maint.
Level
38.57
40.71
43.36
47.73
50.75
61.39
% Reduct.
due to
Maint.
50%
54%
56%
60%
65%
62%
Average
Maint.
Cost
$22
$22
$23
$25
$27
$34

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                                 -3-

      I/M Reductions due to Maintenance  for Various Failure Rates*
                                ftCBUCTIOHfi
 12
                             NC MEOUCTIOH
                             CO fttOUCTlON
                                  16            24
                            PfllLURC  RflTC
                        FNILBO CUM NfOlCT)OH9
                                                                  16  2
a
^«
h-
U.
  46
                                  16
                                     flflTC
  *Based on EPA's Portland Study data,  1975  to  1977 models.

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                                -4-

     Emission reductions for each failure rate have also been plotted in
     the following figures.   The top figure gives fleetwide reductions
     while the bottom figure gives reductions for the failed fleet.  As
     would be expected,  fleetwide emission reductions increase with
     increasing failure  rate while emission reductions per failed car
     decrease with increasing failure rate.  This phenomenon supports
     the argument that as fewer cars are failed, those failing are the
     highest emitters.  The data also show that repair cost is mildly
     affected by failure rate.

d) Emission Reductions;   (Appendix N) - Are the Appendix N reductions
proven in the field?

     EPA's Portland Study is the first complete evaluation of an operating
     mandatory inspection and maintenance program.  Based on the data
     now available (emissions measured over nine months following inspec-
     tion and repair, then extrapolated to one year as shown in the
     attached graphs), the emission reductions being experienced in
     Portland are greater than  those predicted bv Appendix N.   ("This
     comparison is based on a fleet of 1975-77 models undergoing I/M in
     which the 1975 models had one inspection and the 1976-77 models no
     inspections prior to entering the study.)  The results are shown
     below.
            Preliminary Comparison of Portland I/M Effectiveness
                           to Appendix N Estimates

                                        Fleet Reductions
                                        HC             CO

                Portland Study          16%            35%
                Appendix N              13%            25%
     The above values for Portland may change slightly as the fourth
     quarter deterioration data become available, thus the comparison
     has been labeled preliminary.

e) Emission Reductions; (Waivers) - Is program effectiveness compromised by
such factors as waivers?

     This question will be answered in two parts:  1) waivers based on
     the age of vehicle; 2) waivers based on the cost of repair of
     failed vehicles.

     AGE WAIVERS;  Given a typical I/M program with 30% stringency, no
     mechanic training, implemented in 1982 and evaluated in 1987, the
     reduction in HC and CO due to I/M is estimated to be 28% and 30%
     respectively.  The effect of exempting any group of vehicles from
     the I/M process is shown in the following figure and summarized
     below.

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                                -5-

HC  EMISSION  LEVEL  ESTIMflTES FOR  PORTLRND flND  EUGENE  (75-77)
 2.00
-1.55
o
 1.00
 0.55
 0.0
flPPENDIX  N  BENEFIT 13X

PORILflNO  BENEFIT  j j. '/,
                                           '—• extrapolated
                                   _ PORTLflND
                                   .. EUGENE
       20000     24000     28000     32000
                             MILEflGE
                                    36000
40000
 CO EMISSION  LEVEL  ESTIMflTES FOR  PORTLRND  flNO EUGENE
    30
    25
    20
    10
         flPPENDIX N BENEFIT

         PORTLflNO BENEFIT
                                            — extrapolated
                                            	 PORTLflNO
                                            	 EUGENE
       20000     24000     28000     32000     36000
                             MILEflGE
                                              40000
                            19 MDMTHS

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                           -6-
Effect of Age
Exempted Model
Years
None
pre '68
pre '75
pre '80
Emission
HC
28
28
24
15
Exemptions
Reduction, %
CO
30
30
25
9
% Fleet VMT Exempted
(1987)
0
.4
4.8
25.0
These data show a negligible effect on I/M effectiveness of exempting
pre-1968 vehicles while program effectiveness is reduced signifi-
cantly for the other exemptions shown.  For the pre-1980 exemption
in this scenario, the 25% emission reduction by 1987 (minimal
program requirement) is not achievable.

COST CEILINGS;  Portland data have been analyzed to help determine
the effect of cost ceilings on I/M program effectiveness.  The
results of the analysis are summarized in the table below.  For
maintenance cost ceilings from $25 to $150, failed vehicles with
repair costs above that ceiling were identified.  For example, 4%
of the 94 1972-74 model year vehicles in the sample requiring
maintenance had reported maintenance costs greater than $150 and
32% of these 94 vehicles had reported maintenance costs greater
than $25.  HC and CO emission reductions were calculated for each
cost ceiling.  It was assumed that vehicles above the cost ceiling
received no maintenance and their emission levels thus remained
unchanged.  If an I/M program requires that maintenance expen-
ditures up to the cost ceiling be performed, the iiftpact on program
effectiveness, presented below would be less.
    1972-74 Model Year Failed Cars     1975-77 Model Year Failed Cars
                       % Reduction
Reduction
Cost
Ceiling
No Limit
150
100
75
50
25
% within
Cost Limit
100%
96
91
89
83
68

FTP HC
25
24
14
9
9
6

FTP CO
37
36
35
30
28
22
% within
Cost Limit
100%
100
96
94
88
74

FTP HC
40
40
36
36
31
20

FTP CO
48
48
46
46
40
31
The data have been smoothed and plotted in the following figures.
For newer cars, cost ceilings above $75 have only a minimal effect
on fleetwide emission reductions.  For older cars, the ceiling must
be in the $100 - $150 range or greater or avoid a reduction in
program effectiveness.

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                                -7-
           I/M FLEET EMISSION REDUCTION WITH AGE WAIVERS*
     1982-1987 I/H  PROGRflM, 30% SF,  NO MPCH  TRfllNJNG
  10,.
  35 .
  30
a
UJ
or
  20
Q

Ul
  10
      All vehicles**
Excluding

pre-1975
                                                         HC  REDUCTION


                                                         CO  REDUCTION
Excluding

pre-1980
 *1982-1987 I/M program, 30% stringency factor, no mechanic training.

 **Benefit when excluding pre-1968s  is the same as benefit for all vehicles.

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                                  -8-
                   I/M Reductions with Cost Ceilings
tie ,
        0
                   CMS Lift TIM FIVf TIMO 04.1
                     (1975-77 models in Portland)
                                                NC KCOUCTIM
                                                CO HfOlfCTJO*
5@          168
      coir UNIT  tfi
150
                                                                 «*  3
                                                                     g
                                                                     r»
                                            24  5
                                                                 16
200
                   CUM flVC  TIM! OLD MO OLOC»
                      (1972-74 models in Portland)
                                                NC  MCMICTIM
                                                CO  MC8IICTIM
                                                                 25 0
                     50          100           150
                            COST  LIMIT (t)
                                       MO LIMIT

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                                -9-

f) Emission Reductions - Is program effectiveness compromised by such
factors as private garage reinspection?

     Centralized, garage based, and centralized with garage retest
     authority programs have the same potential for emission reductions.
     Where private repair facilities become involved with testing or
     retesting for compliance, the potential for more variable test
     results or fraud exist.  To overcome this, the state must establish
     a strong quality control and enforcement program.  Periodic inspec-
     tions of repair facility equipment and personnel skills, indepen-
     dent testing of vehicles recently repaired, and a good data col-
     lection system in which repair facility test results can be com-
     pared and matched to other data surveys can assure that program
     effectiveness is not reduced.

g) Emission Reductions: (Ambient Effects) - Is program effectiveness
compromised by such factors as high or low ambient temperatures?

     The I/M benefits as set forth in MOBILE1 are based on emission
     levels and reductions as measured by the Federal Test Procedure.
     This test is run at ambient temperature ranging from 20 to 30°C (68
     to 86°F).  The test is divided into portions which represent cold
     start, hot start, and stabilized, warmed-up operation.  In areas
     with high or low ambient temperatures, the percentages of cold
     start, hot start, and stabilized operation will be different than
     assumed under FTP conditions (21% VMT cold start, 52% VMT stabilized,
     and 27% VMT hot start operation).  For areas with higher than FTP
     temperatures, more stabilized and hot start operation and less
     cold start operation will exist.  Since high temperature (up to
     about 100°F) does not significantly affect emissions during any
     mode  of operation, the reductions due to I/M at high temperatures
     should be greater than reductions seen at 75°F.  The' reductions at 75°F
     (absolute and percentagewise) are given below.
Reductions due to I/M During
Stabilized/Hot Start Operation
(1975-77


Cold Start
Stabilized
Hot Start
Overall
Model Year Failed
Absolute
HC
0.80
1.39
0.80
1.27
Cars in Portland)
Reduction (gm/mi) %
CO HC
10.44 23%
26.89 55%
10.35 41%
21.51 44%
75°

Reduction
CO
23%
67%
46%
53%
     For areas with cold temperatures, there will be more cold start
     operation, less hot start, and perhaps less stabilized.  Since cold
     temperature has been shown to affect emissions during cold start

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                                -10-

     operatlon,  I/M's  effect  at  cold  temperatures  (particularly
     with respect  to CO,  since HC  is  not a problem below about 50°F)
     is not  adequately indicated by Portland data  alone.   Although
     data at cold  temperatures are limited, all available data have been
     collected  on  1975-77 model  year  cars:  cars have  been classified
     as "as-received"  and as  "tune-up."  The as-received cars have been
     used to reflect CO emission levels of failed  vehicles.   Since these
     cars were  in  various states of tune, they likely  underestimate the
     emissions  of  those vehicles which would have  failed an I/M test.
     The results of comparing cold start emissions for the "as-received"
     and "tuned-up" fleets  are presented below, and  indicate, based
     on these limited  data, that I/M  will have a substantial effect
     on CO emissions at least to temperatures  as low as 20°F.
Estimated CO Reductions Due to I/M
During Cold Start Operation
(1975-77 Model Year Cars)
Absolute Reduction(gm/mi)
20° 23
30° 37
60° 27
75° (Portland) 10



% Reduction
13%
26%
35%
23%
h) Emission Reductions - Is program effectiveness compromised by such
factors as a high volume of transient,  non-inspected vehicles in a
region?

     I/M's effectiveness is based on the population of inspected vehi-
     cles.  Therefore, if 10% of the vehicles in a region are transient
     and non-inspected, the corresponding fraction of miles traveled by
     these vehicles should be included in the 'without I/M' emission
     inventory calculation, and should be represented in the 'with I/M'
     emission inventory calculation with unchanged emission levels.  The
     resulting calculation will determine any reduction in air quality
     benefit from I/M.  As I/M programs become more widespread (over
     50 programs are expected to be in operation by 1983) , more of the
     transient vehicles will have been inspected in the home state,
     thus the impact of transient vehicles will be reduced.

i) Fuel Economy - Can any fuel economy benefits be expected from I/M, and
if so, how much?  Earlier studies have shown savings would average 3 to
5 percent for serviced vehicles.  Now it appears that the average
mechanic will not adjust a failed car to achieve any fuel benefit.  What
happened to the previous assertion?

     The fuel economy benefit associated with the typical repairs
     performed as a result of an I/M program depends on the skill of the
     mechanic and the type of vehicle.  Numerous studies have shown that
     maintenance performed to manufacturer's specifications can result

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                                -11-

     in a 3 to 4 percent fuel economy improvement for current technology
     vehicles.  EPA's study of the Portland I/M program, however, has
     indicated that a fuel economy benefit is not being realized.  It is
     believed that the lack of training specific to proper emission
     control maintenance is a factor.  Thus for an area which does not
     have widespread mechanic training specific to emission control
     maintenance, no fuel economy benefit is expected for current
     technology cars.  For areas with trained mechanics, a fuel economy
     improvement of 3 to 4 percent for repaired cars can be expected.

     For future technology cars, the situation is expected to be some-
     what different.  Beginning with model year 1981 (1980 in California),
     passenger cars will commonly utilize mini-computer controlled fuel
     and ignition systems.  Failures associated with these systems are
     likely to cause significant fuel economy penalties.  While the
     frequency of failures is not currently known, the per-vehicle fuel
     economy improvement due to repair, based on tests of several
     prototype vehicles, is expected to be 10 to 20 percent.

j) Maintenance Costs - Will overall maintenance costs be reduced with I/M?

     We do not have data available upon which to incorporate emission
     oriented maintenance performed in the absence of I/M into a net I/M
     cost estimate.  Some emission maintenance now occurs;  an example
     is replacement of spark plugs.  We can not, however, conclude
     overall vehicle maintenance will be reduced as a result of I/M.

     Two qualitative arguments shed light on this question.  First, I/M
     has the objective of increasing the maintenance performed on the
     fleet, thus it can be argued I/M will increase maintenance costs.
     From the opposite point of view, the idle test acts as an indicator
     of the need for maintenance and provides diagnostics.  Thus it can
     also be argued that with properly trained service personnel,
     unnecessary maintenance will be reduced and the quality of maintenance
     performed will increase.  Since these are only qualitative argu-
     ments, we have chosen to consider the cost of inspection and repair
     as additional costs of maintenance.

     Put into perspective, the average cost to the motorist for I/M is
     between $10 to $15 per year.  This compares to a Motor and Equipment
     Manufacturers Association estimate of $215 of general maintenance and
     repairs performed each year per vehicle.  Thus the increase in
     maintenance cost, in the extreme, is less than 10 percent.

k) Vehicle/Engine Life - Will the useful life of the engine or entire
vehicle be enhanced by I/M?

     There are no hard data to quantify whether vehicle/engine life
     increases due to I/M related maintenance.  It is highly unlikely
     that proper maintenance will decrease engine life.  In some areas
     experience and technical judgment indicate that engine or component

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                                -12-

     life may be extended due to proper  maintenance.   Examples are
     carburetor adjustments reducing carbon buildup,  valve adjustments
     extending valve life,  and ignition  maintenance preventing misfires
     which may damage the catalyst.

1) Loaded/Idle Tests - What actual benefits can be derived from loaded
testing?  Are they worth the extra time  and cost?  Do you recommend
loaded or idle testing?

     An evaluation of the idle vs. loaded test involves two aspects:  1)
     the ability of each test to identify the worst polluting vehicles,
     and 2) the emission reduction achieved when failed cars are repaired
     to meet the short test standards.   Although EPA is still evaluating
     the loaded vs. idle test, it is clear from the Portland study that
     the idle test does an excellent job of screening the worst emitters
     of HC and CO.  Maintenance performed by the mechanics in the
     Portland area appears to be effective in reducing FTP as well as
     idle emissions.  High emitters of NOx are not successfully iden-
     tified by the idle test.

     The benefit of the loaded test for  areas with only HC and/or CO air
     quality problems centers around the more complete diagnostics
     available from this test.  Although the idle test detects most
     failures associated with current technology cars, some carburetor
     and high speed ignition failures can only be detected with the
     loaded mode test.  (Loaded mode testing is expected to be more
     valuable for the electronic controlled advanced technology vehicles
     of the early 1980's.  It is also expected, however, that non-loaded
     diagnostic methods will be available as an alternative.)  Repair of
     these defects will result in an increased HC and CO emission reduc-
     tion.  The CARB Riverside program indicated that mechanics were not
     able to translate the diagnostics into larger emission reductions
     or more efficient repairs.  Thus to realize additional HC and CO
     benefits, proper mechanic training appears to be necessary.
     Another potential consumer benefit may be a reduction in unnecessary
     repairs resulting from the better diagnostics.

     For areas which have NOx problems,  there are two possible alter-
     natives for using I/M as a control strategy.  One is to add a
     physical inspection of the EGR system to an idle test regime.  The
     other is to perform a loaded mode test.  The idea behind the phy-
     sical inspection of the EGR system is to identify only the cars
     which have obviously malperforming EGR systems and require main-
     tenance just on this group.  The other approach is to measure the
     NOx exhaust emissions at a high speed/load condition and establish
     pass/fail criteria based on these measurements.

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                               -13-

    A comparison of  these  two  approaches  from  the  standpoint  of  effec-
    tiveness and cost  is currently underway.   Some preliminary infor-
    mation on  the  loaded test, based  on the Portland  study, is avail-
    able.  These results indicate that at least  the high speed mode of
    the  Federal Three-Mode test  is capable of  identifying the worst NOx
    emitters.  The following table presents the  FTP NOx  levels of
    Portland area  vehicles passing and failing the high  speed test for
    NOx.  These data show  the  failed  cars had  emission levels 60%
    higher than those  passing  the loaded  test.   (The  high speed  cut-
    points used were 2430  ppm  for 1975-76 models and  2165 ppm for  1977
    models.)
                Effectiveness  of  the Loaded Test in
                    Detecting  High NOx Emitters
             (High Speed Mode  of  Federal 3-Mode Test)

                                        Loaded Short Test Failure Rate
                                        10%          20%           30%

          FTP emissions, passed cars   2.40 gpm     2.28 gpm      2.05 gpm
          FTP emissions, failed cars   3.96         3.67          3.47
     No I/M program currently requires maintenance to be performed in
     response to loaded test standards.   Therefore,  no appropriate after
     maintenance data on failed vehicles exist.   However, data from
     EPA1 s Restorative Maintenance program indicates that FTP NOx
     emissions on 1975-76 model year cars with EGR system or related
     failures are reduced to approximately 2.6 gpm as a result of
     maintenance.   This after maintenance level was  applied to the
     Portland area 1975-76 models which were failed  by the loaded test.
     For 1977 models where the federal exhaust emission standard for NOx
     is more stringent, it was assumed that failed vehicles could be
     maintained to levels which are below their standard by the same
     percentage as 1975-76s are below theirs;  thus  to 1.68 gpm.  The
     following table provides the estimates of NOx emission reductions
     which would be achieved using the assumed post-maintenance levels
     for each failure rate, and shows that fleet NOx reductions of 6 to
     13% are possible.

     The incremental cost of a loaded mode inspection over an idle
     inspection includes a higher inspection fee (estimated to be a
     maximum of $1.35 extra) and the NOx related repair cost, estimated
     at $7.50.*  The average additional per vehicle cost of the NOx
     inspection and repair is shown in the following table.  (All cost
     has been attributed to the NOx reduction;  the repair cost has been
     averaged over the entire fleet.)  In addition,  the NOx cost-effectivness
     is calculated (10,000 miles per year assumed).   The cost-effectiveness
     is in the range of other NOx control strategies.
*This estimate comes from the Restorative Maintenance Program and
represents primarily the average cost of repairing malperforming EGR
systems.

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                          -14-
Estimated FTP NOX Emission Reductions
(Loaded Test, 1975-77 Models)
FTP NOx Emissions
of Passed Cars
FTP NOx Emissions
of Failed Cars
Before Maintenance
Assumed Post-Maintenance
FTP Emission Levels
for Failed Cars
Fleet FTP Emissions
Before Maintenance
(N = 230)
Fleet FTP Emissions
After Maintenance
% Reduction in NOx
Loaded Short
10%
2.40
3.96
2.38
2.55
2.40
5.9%
due to Maintenance
Test Failure Rate
20%
2.28
3.67
2.36
2.55
2.29
10.2%

30%
2.16
3.44
2.34
2.55
2.22
12.9%
          Estimated Cost and Cost-Effectiveness
               for NOx Emission Reduction
           (Loaded Mode Test, 1975-77 Models)

                                   Loaded Short Test Failure Rate
                                   10%            20%         30%

     Cost per inspected vehicle   $2.20          $2.85       $3.60
     Cost-effectiveness, $/ton    $1270          $994        $990
The effectiveness and cost of an EGR inspection for NOx is pre-
sented below for comparison.  The results show that the reductions
achieved and cost-effectiveness are similar to the 10% stringency
loaded mode test.  Actual EGR inspection effectivness may be some-
what less because of the difficulty of observing the EGR on some
vehicles (e.g., it is sometimes located behind the air cleaner).
           Estimated Cost and Cost-Effectiveness
                for NOx Emission Reduction
             (EGR Inspection, 1975-77 Models)

           % vehicles failing inspection           13%
           FTP NOx Emissions:  Passed cars         2.38 gpm
           FTP NOx Emissions:  Failed cars         3.46 gpm
           Assumed Post-maintenance level          2.32 gpm
           % NOx reduction:  Failed cars           33%
           % NOx reduction:  Fleet                 6%
           Cost of inspection repair:  Fleet avg.  $2.00
           Cost-effectiveness                      $1210/ton NOx

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                                -15-

     To summarize, further analysis is being performed  to evaluate  the
     loaded vs. idle I/M test.  Preliminary analysis indicates  that an
     idle  test  is an adequate I/M test for areas which  require  control
     only  of HC and CO.  NOx problems cannot be addressed by an idle  I/M
     test.  Both a loaded test and the physical inspection of the EGR
     system are considered to be viable alternatives for controlling  NOx
     through I/M.  We are not yet ready to recommend one procedure  for
     NOx over the other, but further information will be forthcoming.

m) Appendix N - Are the credits in Appendix N valid?  What reasons are
there for  the delay in the revised version?  Is there sufficient tech-
nical documentation now or will there be in the future  to justify the
credits?

     Appendix N reflects EPA's best judgment of the benefits associated
     with  an inspection and maintenance program.  Appendix N, as
     contained  in the computer program MOBILE1, is based on a careful
     review of  available I/M data and on engineering judgment.  EPA
     sees  no need for revision now.

      Later this year,  as  the Portland  study  is  completed,
     and test results from prototype advanced technology vehicles
     become available, EPA will revisit Appendix N and  make any needed
     adjustments.  The adequacy of 1979 SIP revisions with respect to
     the 25% emission reduction requirements in EPA's I/M policy
      (July 17,  1978) will be judged according to MOBILE1 credits.

n) Heavy Duty I/M - What emission reductions  can be expected for I/M of
heavy duty vehicles at various stringency levels?

     There are no appropriate data to evaluate this question quanti-
     tatively at the present time.   Based on engineering arguments,  one
     could expect that emission oriented tune-ups would result in
     similar emission reductions on heavy duty trucks as occur on
     lighter duty vehicles.

     Although no quantitative estimates of heavy duty vehicle I/M's
     effectiveness are available,  several states either are considering
     implementing or already have implemented a heavy duty vehicle I/M
     program.   New Jersey is now conducting a voluntary I/M program for
     heavy duty vehicles and expects to set idle emission,  smoke and
     noise standards and require compliance in the very near future.
     Arizona presently requires inspection of approximately 130,000
     heavy duty vehicles.   The failure rate for HDVs is slightly higher
     than  the 16% failure rate for LDVs.   Oregon is presently inspecting
     approximately 1,000 heavy duty vehicles per month with a failure
     rate  of about 50%.  All three of these programs are based upon the
     idle  test procedure.   None has yet reported any estimate of effec-
     tiveness.  As data become available, it will be disseminated.

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                           -16-

In the 1977 Clean Air Act amendments,  Congress established new
vehicle emission standards for trucks  which reflect the same emission
reductions from uncontrolled levels as passenger cars.   EPA has
been developing an improved test procedure to complement these
standards, which will go into effect in 1983.  Included in this
procedure is an idle test and emission standard which will facilitate
establishing warranty provisions and cutpoints for heavy duty
vehicles.  Since the technology that will be used on these vehicles
will be similar to that used on current passenger cars, I/M will
be necessary to assure appropriate maintenance is performed and
tampering and misfueling are discouraged.

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                                -17-
2.   COSTS
  a) Repairs - How do repair costs vary with stringency and test mode?
     Will the loaded test reduce repair costs?  If so, why are the average
     repair costs lower in New Jersey than in Arizona?

          As briefly discussed in the response to question "Emission
          Reductions: (Failure Rate)," costs appear to vary with stringency
          factor.  For the Portland sample of failed cars, average repair
          costs tend to increase with lower stringency programs.  Average
          costs of repairs for failed vehicles range from approximately $20
          to $35 for stringencies of 30% to 6% respectively.  This suggests
          that the worst emitters (those identified by low stringency pro-
          grams) tend also to have the highest repair costs.

          The only available data on loaded test repair costs come from the
          California Air Resources Board's Riverside Pilot I/M Program.*
          CARB selected two samples of pre-75 model year vehicles;  one
          sample was subjected to an idle test, the other to a loaded test.
          The intent was to determine the costs and effectiveness for the two
          tests.  The average repair costs were slightly higher for the
          loaded test than for the idle test ($23 vs. $21), with emission
          reductions on HC, CO, and NOx insignificantly different for the two
          tests.  The mechanics who were performing maintenance on the loaded
          test failures had not been specifically trained in loaded test
          diagnostics.  Therefore, although the potential for additional
          benefit and lower repair costs may exist for the loaded test,
          CARB's study suggests that mechanic training is essential for its
          realization.

          Our latest information indicates that both New Jersey's and Arizona's
          average costs of repair are low:  $16 and $23, respectively.  It
          does not seem unreasonable that repair costs should be higher in
          areas where a loaded test regime is used simply because more
          problems can potentially be diagnosed and fixed.  Typically, the
          necessary repairs performed in response to failing the idle test
          (both N.J. and Arizona pass or fail cars on the basis of an idle
          test) involve simple adjustments or replacement of relatively
          inexpensive parts such as spark plugs or wires.  Thus, the addi-
          tional diagnostic information provided by the loaded test would not
          be expected to affect repair costs one way or the other for these
          typical cars.  For cars which have atypical problems, the use of
          the loaded test diagnostics may result in more appropriate and
          perhaps more costly repairs than would be performed in the absence
          of the diagnostic information.  This may imply a higher average
          cost of repair for the loaded test regime.
     ^Vehicle Inspection and Maintenance - The California Program, G. Rubenstein,
     R. Ingels, R. Weis, and A. Wong, SAE Paper 760557, June 1976.

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                                    -18-


b)  Costs;  (Mechanic Training) - Does mechanic training have a positive
    effect  on repair costs?

         The primary purpose of automotive exhaust emission oriented mecha-
         nic training programs is to improve the skills of mechanics in
         performing emission related repairs.  Successful training programs
         provide mechanics with the ability to more rapidly and effectively
         diagnose  and repair defects which cause high emission levels.   This
         results in lower costs.  However, the knowledge acquired during
         emission  related training may  cause mechanics to do more repairs
         than they might otherwise do in an attempt to achieve even greater
         emission  reductions.  Since the costs of these two effects tend to
         offset each other, the net result may be little or no change  in
         average repair  costs.  Of course, both effects would have a ten-
         dency  to  increase emission reductions and thus program benefits.

c)  Costs - What are the average repair - not inspection - costs  for private
    garage  test systems?

         The  only  garage based I/M programs in operation are  in Nevada and
         Rhode  Island.   Rhode Island just began mandatory repair,  thus no
         repair cost data are now available.  Nevada's program  includes
         setting  certain parameters  to  manufacturer specification on all
         inspected vehicles, thus data  from this program are  not  applicable
         to the typical  garage I/M program.  However, the repairs required
         to pass  an  exhaust emission test are the same whether  the  test is
         performed in  a  private  garage  or in a centralized inspection  lane.
         Therefore,  one  would expect the average cost of repairs  in a  garage
         based  program to be about  the  same as that of a lane program,
         somewhere between  $16 and  $32  per  failed vehicle.

d)  Costs - Will  repair  costs decrease  after programs have been  in operation
    for several years?

         The  key  to  emission reductions and therefore overall I/M program
         effectiveness is  the ability of the automotive  service  industry to
         provide  proper  emission related repairs.   It is reasonable  to
         expect that once mechanics have gained  some  experience  with  I/M
         programs they should be able  to repair  the  failed vehicles more
         efficiently and with reduced  costs.  Very  little  data  exist  to
         quantify this effect however.   Survey data  from New Jersey and
         Arizona indicate  that  the  I/M programs  in  those  states  have  expe-
         rienced little or  no  change in repair costs  over  the past several
         years.  These surveys  are  not  conclusive,  however,  and the true
         answer to this question will  have  to wait  until more quantitative
         data are available.

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                                 -19-

e) Cost Analysis;  (Cost Effectiveness)  - What are the results of the
   various cost-benefit analyses performed on I/M?  How are the results
   affected by varying the assumption of test mode,  stringency and other
   factors?

        Several cost-benefit analyses on 1/M have been performed by EPA to
        date.   Analyses have been based on 1) Portland data, 2) MOBILE1-
        Appendix N estimates, and 3) a combination of Portland data and
        MOBILEl-Appendix N estimates.  The best currently available esti-
        mate of I/M's cost-effectiveness in Portland is based on the 1977
        model year vehicle fleet.  These vehicles were on the average one
        year old when first inspected and maintained.  They had received no
        inspections prior to entering EPA's Portland Study.  Thus, I/M's
        effectiveness on these vehicles is relatively easy to track com-
        pared with earlier model year cars, some of which had been inspected
        prior to entering the EPA study.

        A complete year's worth of emission deterioration data is not
        available yet, so the observations on nine months of emission
        testing have been smoothed and extrapolated to the full year.  1977
        model year vehicles in Portland and Eugene were taken as the I/M
        and non-I/M fleets respectively.  Both fleets were weighted to
        better represent the Portland area fleet of 1977 models. (Plots of
        deterioration for1975^77vehicles were provided in response to a
        previous question.) It should be noted that the initial emission
        levels (prior to maintenance) in Portland and Eugene were approx-
        imately the same for both HC and CO, suggesting that Eugene vehi-
        cles provide a good estimate of Portland area vehicles' emissions
        in the absence of I/M.  By calculating the areas under the Portland
        and Eugene curves respectively, estimates of grams (tons) of HC and
        CO eliminated per vehicle over the year following I/M were obtained.
        (It was assumed that each fleet traveled 15,000 miles in the year
        following the initial test.)  The average per vehicle cost of I/M
        was estimated by applying Portland's $5 inspection fee to all cars,
        and an average $20 repair cost to the 30% failed cars.  This cost
        ($5 x .7 +$25 x .3) averages  $H  per inspected vehicle.  The
        effectiveness and cost per vehicle, and the combined cost-effectiveness
        estimates are tabulated below.

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                        -20-
              I/M's Effectiveness and Costs
    1977 Model Year Cars Based on Portland Sudy Data

                                   Effectiveness
                              HC                  CO

Tons per vehicle
without I/M                .03291              .44973

Tons per vehicle
with I/M                   .02366              .29612

Tons eliminated
per vehicle                .00925              .15361

                          Costs

          Inspection fee = $5/vehicle

          Repair Cost = $20 /failed vehicle

          Average* Cost of I/M per vehicle  (30% failure rate) =
           $11 /vehicle

                   Cost-Effectiveness
     (attributing one half of cost to each pollutant)

          HC:   $11 /2/0.00925 tons =  $595/ton
          CO:   $11 /2/0.15361 tons =  $36/ton
 The  comparable calculations  (for catalyst-equipped vehicles  following
 their  first inspection based on MOBILEI-Appendix N estimates are
 provided below.  Appendix N  is understating the benefit  seen in
 Portland for 1977 models.  Since costs are assumed to be the same
 as in  the Portland  scenario, the resulting cost-effectiveness
 estimate is numerically higher than that of the Portland fleet.

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                          -21-
               I/M's Effectiveness and Costs
1977 Model Year Cars in the Year Following First Inspection
              MOBILE1 - Appendix N Estimates
                                    Effectiveness
 Tons per vehicle
 without I/M

 Tons per vehicle
 with I/M

 Tons eliminated
 per vehicle
    HC


 .02728


 .02373


 .00355

Costs
                                                    CO
.41584
.30208
.11376
           Inspection fee = $5/vehicle

           Repair Cost = $20/failed vehicle

           Average Cost of IM per vehicle (30% failure rate) =
            $11 /vehicle

                    Cost-Effectiveness
      (attributing one half of cost to each pollutant)

           HC:    $11/2/0.00355 tons = $1549/ton
           CO:    $11/2/0.11376 tons = $48/ton
 EPA's best estimate of the range of I/M cost-effectiveness for the
 first year is $600 - $1500 per ton HC and $30 - $50 per ton CO for
 the split costs case.

 The  calculation of  cost-effectiveness estimates relies on  two
 inputs:   cost  and  effectiveness.   Thus,  any  factor which affects
 cost or  effectiveness could potentially  affect the cost-effectiveness
 ratio.   Such factors  include  test  mode,  stringency of program, cost
 or age waivers, emission  deterioration with  and without I/M,
 mechanic training  programs, and  type of  program (centralized or
 decentralized).  Although, as  alluded to in  previous responses, the
 effects  of  some of  these  factors  on costs and  effectiveness have
 been investigated,  no comprehensive quantitative summary of the
 sensitivity of cost-effectiveness  to these various factors is
 available now.

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                                -22-

f) Cost Analysis; (Indirect Costs)  - Why are indirect consumer costs, such
as time and travel for inspection and repairs,  usually neglected in
these analyses?

     The indirect consumer costs listed in the question have histori-
     cally not been included in cost-effectiveness analyses.  One reason
     is it is difficult to reach agreement as to their quantification.
     Also, no attempt to remove the costs of emission related repairs
     which may have been done in the absence of I/M has been made, and
     possible indirect benefits such as lower long term maintenance
     costs or longer engine life have not been included.  These cost
     reducing considerations tend to offset the inconvenience factors
     described in the question.  Thus, to keep the cost and cost-effectiveness
     analyses as quantitative and straightforward as possible, only the
     direct I/M cost and benefits have been used.

g) Comparing Systems - Too often EPA reports fail to point out the fact
that New Jersey's system is an old, well-established program.  The $2.50
test fee does not include a retest nor does it pay for initial capital
costs as other programs must.  Negating these factors, how do the
various systems' costs compare?  How do capital and manpower costs
differ between the three types of systems?

     Table A presents an example which compares typical per vehicle
     program costs for an idle emissions inspection with an initial auto
     population of 400,000.  The following assumptions are made:

                    program length           5 years
                    annual interest on
                      borrowed capital       12%
                    annual inflation         7.5%
                    annual population growth 5%
                    contractor's net return
                      on investment          8%
                    depreciation periods:
                         land                no depreciation
                         construction        20 years
                         other capital
                           investments       5 years  (length of program)

     For  the centralized programs,  each of the eight  required facilities
     in this example  includes  three lanes, each lane  performing 26,000
     four- to  five-minute inspections annually (including retests).   For
     the  decentralized program, each of 640 private garage  stations
     performs  approximately 700 ten-minute inspections annually.  One
     challenge lane,  similar in nature to the lanes used for the cen-
     tralized  programs, is assumed  to be sufficient to provide referee
     facilities  for 5% of the vehicles in the decentralized program.

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                                -23-

     Table A shows that the fee for the various program types is in
     the range of 7 to 9 dollars, with the decentralized program the
     most expensive.  Assumptions other than those shown, such as
     adding a program to an existing safety inspection, may affect
     these results.  Also of interest is the greater percentage of fee
     attributed to initial costs of a centralized program.  This suggests
     that after the initial costs have been paid for, the fee difference
     between the centralized and decentralized program will increase.

     Table B compares state personnel requirements for the same three
     programs.  Program design, engineering and evaluation, and public
     information functions are not included among these requirements.
     Noteworthy is the larger number of state employees required to
     monitor a decentralized program compared to the contractor cen-
     tralized program.

h) Economic and Social Impact - What effect does I/M have on the under-
privileged?  Have waiver systems or free repairs ever been considered?
What effect does I/M have on the repair industry?

     Based upon census data, people in the low income groups tend to
     drive cars that are on the average five to seven years old.
     Depreciation, gasoline, repairs, insurance, etc. on a car in this
     age range average from $1200 to $1500 per year.  Typical costs for
     a vehicle of this age failing an I/M test would be about $20.  Some
     of that maintenance cost would be incurred without an I/M program.
     The net cost of an I/M program would therefore be about $12 to $15
     or approximately 1% of the cost of owning and operating a vehicle
     of that age.

     Several states have considered methods of reducing this financial
     burden on the underprivileged.  Arizona, for example, has placed a
     limit of $75 on the cost of repairs resulting from failing an
     inspection test.  (See question dealing with the effect of such
     waivers on the program's effectivness.)  The limit in California is
     $50, with a provision to extend it to $75.  New Jersey and Oregon,
     on the other hand, consider the cost of repairs as a necessary cost
     associated with the privilege of driving on the state roads and
     place no limits on repair costs.

     Those agencies presently conducting I/M programs report no notice-
     able change in the service industry as a result of implementing
     their programs.  As I/M programs have started up, there have been
     no reports of shortages of mechanics, or facilities to perform the
     necessary maintenance.  The number of vehicles on the road per
     mechanic has steadily risen over the past two decades to about 235
     cars per mechanic currently.  While the situation has been called
     critical by at least one industry official, it appears that the
     current repair force can handle extra I/M related repairs.  One
     recent survey indicates that over 80% of repair facilities which
     perform tune-ups could handle at least an extra 10% workload in
     this area, and about one-half of these shops could handle a 30% or
     higher increase in tune-up work.  New Jersey estimates the extra
     work is, on the average, less than 5% of the repair facilities'
     workload and that there is no trouble absorbing the work.

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                               -24-
                              TABLE A
                     Inspection Fee Breakdown
 (Costs  to state  for contractor and decentralized programs  indicated  in  parentheses)

                      State           Contractor              Decentralized


                    INITIAL COSTS  (annualized)


 Facility Investment Costs

     Land               .30                .30                      	
                                                                 (.02)

     Construction       .61                .61                      	
     Other  Investment
     (training,  equipment,  site  prep,  etc.)
                                                                 (.04)
.62
Administrative Startup Costs
.25
TOTAL Annualized Initial Costs
1.78
ANNUAL COSTS
Facility Operating Costs
Personnel 3.11
(inspector's time
and overhead)
Other Operating Costs
(equip, maint. , .88
support services, etc.)
Administrative Operating Costs
1.10
TOTAL Annual Operating Costs
5.09
.62
.21
(.10)
1.74
(.10)
(with inflation)
2.42
1.44
.70
(.46)
4.56
(.46)
.89
(.03)
(.22)
.39
(.31)

4.65*
(.19)
.88
(.05)
(1.57)
5.53
(1.81)
ANNUAL INSPECTION FEE
TOTAL Program Cost
to State 6.87
Contractor's net return
6.30
(.56)
.50
6.42
2.12
 TOTAL Inspection Fee    6.37            7.36                    8.54

"Assumes the mechanic performs inspection.

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                                                                -25-

                                                               TABLB B
                                                    5JL?.!:e  Personnel' Utilization*
Person-years.  For training and hiring categories,  these,  figures  represent total person-years nf ti:;rlnlnp
time for personnel not considered  full time staff until program is in actual operation.
                                                                                      State
                                                                                                       Contractor
Personnel Area
Start-Up Personnel
Program Administrators (including contract monitor)
Technical Officers (e.g., mechanic training, building,
quality control, etc.)
Data Analysis/Statistical Staff
Secretarial/Clerical Staff
Training and Hiring of Field Facility Staff (including challenge lane)
Training and Hiring of Field Facility Monitors (or station examiners)

Annual Operating Personnel (present dollars)
Program Administration (Including contract monitor)
Technical Officers (mechanical training, qual. cnll., etc)
Data Analysis/Statistical Staff
Secretarial/Clerical Staff
Field Facility Staff (incl. challenge facilities)
Field Facility Monitors (or station examiner)

(3)

(3)
(1)
(3)
(1.6)
"
(11)

(3)
(7)
(2)
(3)
(91)
—

CO

(.1)
(1)
(1)
-
(0.03)
(6)

(3)
(1)
(1)
(1)
-
(1.)

(2)

(2)
(2)
(3)
(0.1)
(0.2)
(9.3)

(2)
(2)
(2)
(3)
(5)
(10)
                                   TOTAL
                                                                                      U06)
(7)
(24)
*These estimates are provided for illustrative purposes only.  The  ar.tual  number  of  state  personnel will vary depending on the intensity
of efforts in each area.  Public information and program design,  engineering  and  evaluation  efforts are not ahovn.

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                                -26-

i) COWPS Report - What is EPA's response to the Council on Wage and Price
Stability's assessments of the ozone standard and the cost-effectiveness
of I/M?  From whence did EPA's cost vs.  stringency calculations come?
Was this based on restorative maintenance data or I/M data?  What cost-
effectiveness can now be claimed considering the questionable fuel
savings and all indirect and direct consumer costs?  Will EPA revise its
cost estimates?

     The Council on Wage and Price Stability's assessment of I/M's cost-
     effectiveness for ozone was in error due to the fact that repair
     costs were attributed to all vehicles, not just those which failed
     the I/M test.  EPA has pointed this out to COWPS and has provided
     them with our cost-effectiveness analysis.  EPA's best estimate for
     first year cost-effectiveness is $600 to $1500 per ton HC.  This
     range reflects the higher than expected benefits occurring in the
     Portland study.  The details of this calculation are presented in
     response to the "Cost Analyses: (Cost-Effectiveness)" question.  No
     fuel economy benefit is assumed.  As discussed in a previous
     question, neither indirect costs or health and welfare benefits are
     included in these calculations.

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                                      -27-

3.   IMPLEMENTATION

      a)  Funding - Will funds be available for any of the following:  mechanics'
      training, public information programs, construction of I/M facilities,
      preliminary or continuing studies, pilot programs or introductory full-
      scale mandatory inspection/maintenance programs, or the administrative
      costs associated with I/M?

           Funds are available through the EPA regional offices to help
           support the implementation tasks listed above.  Once mandatory
           inspection begins, the program should be self-supporting from the
           inspection fees collected.

           Funds were made available in FY78 to support I/M studies in many
           states.  In FY79 over $5 million has been allocated to support
           state I/M activities.  In the FY80 budget EPA has proposed
           additional funds be made available for the states implementing I/M.
           Other grant funds may also be available from the Regional offices.
           Priority in distributing funds will be given to those states with
           or making progress towards obtaining enabling legislation.

      b) Delays - How many states plan to request extension beyond June 1979 to
      obtain legislation?  On what basis will EPA make decisions on the requests?

           At this time two states have requested an extension in obtaining
           legislation to beyond July 1, 1979.  These requests have been
           denied.  The Clean Air Act, as amended in 1977, requires proof of
           legal authority to implement the elements of the non-attainment
           plans  (Section 172(b)(10)), including inspection maintenance.  In
           the absence of such proof, a SIP cannot be fully approved.  To
           facilitate submittal and review of the SIPs, and in recognition of
           the fact that most legislatures will not meet until after the
           January 1, 1979 SIP submittal deadline, EPA will accept, in lieu of
           certification of legislative authority, a commitment by the governor
           to a schedule for  implementing I/M.  A required date in that schedule
           is certification of adequate legal authority by July 1, 1979;  at
           that time evidence of legal authority must be submitted to EPA.

           The Costle and Hawkins policy memos of February 24, 1978, July 17,
           1978, and February 21, 1979 detail limited exceptional cases in
           which an extension from EPA in certifying legal authority is possible.
           These are:

                a)  There was insufficient opportunity to conduct necessary
                technical analyses and/or

                b)  The legislature has had no opportunity to consider any
                necessary enabling legislation for inspection/maintenance
                between enactment of the 1977 Amendments to the Act and
                June 30, 1979.

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                                -28-

     Regarding the first point,  the large  amount of information avail-
     able from contractor studies,  EPA,  and  operating I/M programs
     coupled with the 18 months  which have passed since the Clean Air
     Act Amendments indicate that extensions on this basis will not be
     needed.  On the second point,  the state must show there has been
     insufficient opportunity to consider  legislation since passage of
     the 1977 amendments to the  Clean Air  Act.   EPA will grant no
     extension if the legislature has had  an opportunity to consider
     enabling legislation but has not given  such legislation serious
     consideration.  In any case, an extension will not be considered by
     EPA until after June 1, 1979.

c) Delays - What will be EPA's response to delays in implementation?
Can the definition of "as expeditiously as practicable" be widened to
accept an implementation schedule that would initiate a mandatory inspection/
voluntary maintenance program two and one-half years after legislation?
This would run for one year to fine-tune the entire I/M program - including
standards, mechanics training, and administrative processes.  After that
year, mandatory maintenance would be required.

     The Act requires I/M to be  implemented  as expeditiously as practicable.
     EPA policy has recently extended the date for mandatory inspection
     and repair to beginning no  later than 1981 for decentralized programs
     and no later than 1982 for  centralized  programs.  In general, SIP
     schedules should reflect realistic intermediate milestones which
     can accomodate unanticipated delays while achieving the deadline
     for mandatory repair.

d) Public Information - What assistance is available for public information
programs?  Arizona's experience is known,  but how have other states
handled the public education problem?

     An understanding by the public and other affected groups of the
     need for and operation of I/M is essential to the success of the
     program.  For this reason a public information program is a
     required element of the SIP I/M implementation schedule.  Assis-
     tance for States pursuing I/M public information programs is
     available in the form of grants from U.S. EPA Regional Offices and
     a multi-media package on I/M developed by EPA and the American Lung
     Association.  I/M information materials which are available include:

          Film - "On the Road to Clean Air" - this 17-minute color film
          covers the purpose and need for I/M programs, the benefits and
          costs and how a program operates.   Available from your local
          ALA chapter or from EPA Regional Offices on a free-loan basis.

          Publications - "Information Document on Automobile Emissions
          Inspection and Maintenance Programs" - EPA-400/2-78-001 (February
          1978), a report produced pursuant to Section 108 of the Clean
          Air Act which presents substantial information on all aspects
          of inspection/maintenance programs.  Available from EPA, (I/M
          Staff, 2565 Plymouth Road, Ann Arbor, MI 48105).

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                           -29-

     "Motor  Vehicle Emissions;   Inspection/Maintenance Kit," - EPA-
     460/3-78-013  (September,  1978).   A loose-leaf binder containing
     information on benefits,  legislation,  public awareness, and an
     extensive section on cost estimation.

     "Tuning Down  Auto Air Pollution" - a 16-page booklet which
     discusses the need for I/M programs, the benefits and costs
     and how a program works.   Available from EPA.

     "Get a  Check-up for your  Car?" - a leaflet on the need for
     keeping cars  well maintained to cut pollution along with
     pointers on what can go wrong with your engine and what to do
     about it.  Available in English and Spanish from your local
     ALA chapter or EPA regional office.

     "Do Your Own    Car" - a leaflet which explains pollution
     control systems and gives the reasons why motorists should not
     tamper  with those devices.  Available from EPA.

     "The Health Effects of Air Pollution" - a 16-page pamphlet
     which discusses the various air pollutants and the effects
     they have on  health.  Available from EPA.

     "I/M Update"  - a bi-monthly information service for the exchange
     of news and ideas on I/M  implementation.  Available from EPA.

     Materials for the Mass Media - American Lung Association (ALA)
     TV spot - a 60-second television presentation which emphasizes
     the need for  regular car  maintenance to minimize auto-related
     air pollution.  Produced  in cooperation with the ALA and Car
     Care Council.  Available  from ALA and EPA.

     ALA radio spots - four 30-second presentations, including one
     in Spanish, which stress  the connection between air pollution
     and the automobile.  Available from ALA and EPA.

In California, Hamilton Test Systems is obligated by contract to
design and operate a public information and education campaign,
under the direction and review of the California Air Resources
Board.  Funds have been budgeted throughout the five-year lifespan
of the contract.  Initially these funds will be used to produce
material for many  communications media, including brochures, fact
sheets, newsletters, slide and film presentations, pamphlets,
billboards and announcements for radio and television.

Portland, Oregon has utilized  mobile vans with emission analyzers
for demonstrations at major shopping centers and other key activity
centers.  Oregon found that bumper stickers were one of the most
successful public  information  tactics.

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                                -30-

     In New Jersey,  posters  were circulated in large volume around the
     state.   Each new car dealer and garage that purchased an emission
     analyzer was contacted  and the state  compiled lists of approved
     analyzers and garages which owned them.   The dealers and garages
     displayed signs indicating they had the analyzers.

     Two program elements stand out as being widely used as I/M public
     information techniques.   One is the use of radio and television
     spot announcements and  newspaper advertisements.  A second technique
     that is key to reaching the individual motorist is preparing an
     informational pamphlet  and mailing it to all vehicle owners, usually
     along with motor vehicle registration forms.  Both California and
     Arizona have indicated  costs for these elements to be approximately
     $0.12 per vehicle.

     States with existing I/M programs have indicated that as the public
     becomes used to the program there may be somewhat less need for an
     intensive public information effort.   There would still be a need
     to inform motorists of  any significant changes in program operations
     or other modifications  of program elements such as waivers, exemp-
     tions, repair cost ceiling, inspection fees, or registration pro-
     cedures.  This could entail periodic mailing or possibly some media
     announcements.   The public should also be made aware of the status
     of the program in terms of emissions reductions achieved.

e) Emission Control Devices  (Catalysts) - Cars with fouled catalysts can
pass current I/M standards.   They pollute more than they should, but is
there any reasonable test that can spot this?

     There are a number of possible causes for catalyst failures among
     in-use vehicles.  Poisoning by lead deposits as a result of improper
     use of leaded fuel is thought to be the most common, but plugging
     or fouling with other substances, deliberate removal or tampering,
     and thermal damage as a result of other neglected engine malper-
     formances are also possible.  Whatever the cause of the failure, a
     vehicle with a failed catalyst will pollute more than it should and
     will fail to meet the Federal HC and CO emission standards, as
     measured by the lengthy Federal Test Procedure.  The vehicle will
     also emit more than a similar vehicle in good condition when tested
     using any of the  I/M-type short tests.  This includes the idle
     test, the short test currently used to pass and fail vehicles in
     all of the I/M programs now in operation.  Despite that fact that
     emissions increase at idle, it is possible for a vehicle with an
     inoperative or failed catalyst to pass current I/M idle standards.

     There are a number of contributing factors that make this possible.
     Current I/M idle  standards have been set fairly loosely relative to
     what vehicles in  good condition are capable of achieving.  This
     keeps the number  of failing vehicles manageable in terms of the
     capacity of the repair industry to fix them and the capacity of
     the I/M program to reinspect them, while achieving significant air
     quality benefit.  It tends to result in vehicles being failed only

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                           -31-

if their problems are easily and inexpensively repaired, as observed
in the Portland study.  It also helps ensure that very few vehicles
which would actually be found to have low emissions on the Federal
Test Procedure are  mistakenly failed and maintained unnecessarily.
Such mistakes are inevitable when using the idle test or any other
short test to pass and fail vehicles, since these tests repeat only
a portion of the Federal Test Procedure;  the number of such
mistakes becomes very small when the idle standards are set rela-
tively loosely.

On the other hand, relatively loose idle standards allow some
vehicles which actually have problems which make them pollute more
than they ideally should to pass the idle test.  Vehicles with
catalyst failures may be among these, in part because the catalyst
failure does not cause idle emissions to exceed the relatively
loose idle standards and in part because it is sometimes possible
to counteract the idle emissions increase due to catalyst failure
by adjusting certain engine parameters to nonrecommended settings.
Such maladjustments do not reduce emissions on the Federal Test
Procedure enough to compensate for the catalyst failure, and there-
fore only camouflage the catalyst failure.

Catalyst failures are only one of several types of problems which
cause cars to pollute more than they should but without causing
them to fail current idle test I/M standards.  Mild forms of car-
buretor maladjustment, choke maladjustment, and EGR problems are
the most common of the other problems with similar effects.  Taken
together and compared to the problems which currently account for
most idle test failures, catalyst failures and problems with similar
effects are important but not the major item of concern.  The problems
which currently account for most idle test failures are more common
and more severe, taken together.  As a result the vehicles which do
fail idle standards are responsible for most of the "excess" HC
and CO emissions of the in-use fleet of catalyst-equipped cars.

Even though an I/M program using an idle test and standards like
those used in current programs will not spot all vehicles with
failed catalysts, it can over time reduce the number of such
vehicles on the road, relative to what this number would be without
I/M.  Drivers can be expected to be more reticent about deliberately
destroying or removing their vehicles' catalysts, for fear of
decreasing their chances of passing the I/M test.  (EPA is inves-
tigating tampering rates in New Jersey which does not actually
inspect for tampering in its I/M program, to compare them with
tampering rates in non-I/M areas to see if this expectation is
borne out.)  Drivers may also be more reluctant about improperly
using leaded fuel.  And any I/M program raises the public's con-
sciousness of motor vehicle emissions and their relationship to air
pollution;  this alone may reduce the frequency of tampering and
misfueling.

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                                -32-

     As stated above and as implied by the question, the problem of
     identifying failed catalysts is an important one, even though not
     a critical one from the standpoint of I/M's effectiveness, and one
     which EPA is currently pursuing.   It is possible that loaded-mode
     I/M tests would be more successful in spotting failed catalysts.
     It is also possible that a simple idle test conducted at a higher
     engine speed (as in the Two-Speed Idle Test) would be better.  A
     visual inspection certainly would be able to detect vehicles whose
     owners have removed the catalyst (about one-half of one percent of
     all 1975 and later model year cars), and this can give some improve-
     ment to air quality.  Finally, EPA is investigating other simple
     tests to detect failed catalysts which could be adapted to an I/M program.

f) Emission Control Devices (Fuel Switching) - Is there any way for EPA,
perhaps in concert with the Department of Energy, to initiate a change
in the gasoline pricing policy to make leaded gas equal, if not greater,
in cost than unleaded gasoline?

     EPA shares the questioner's concern about the incentive for mis-
     fueling catalyst vehicles created by gasoline price differentials,
     particularly in light of the potential impact of price deregulation
     on those differentials.  EPA itself does not have any statutory
     authority which would allow it to change gasoline pricing policy.
     EPA has been discussing this issue with the Department of Energy
     (DOE), which does have this authority, and with other executive
     branch offices.  An agreement has been reached.  Under the agreement,
     DOE will propose a rulemaking which would limit the retail price
     differential between leaded and unleaded gasoline.  The Notice of
     Proposed Rulemaking is expected at about the end of March, 1979.
     DOE will propose limiting the price differential to approximately
     its current level, a move which would prevent misfueling from
     becoming more prevalent after gasoline prices are deregulated.  DOE
     will invite public comments on whether some other maximum limit on
     the differential should be adopted instead, and on the regulatory
     mechanism for enforcing the limit  (i.e., on whether a "trigger
     level" should be established which would have to be exceeded before
     regulations took effect or whether they should be in effect con-
     tinuously) .  EPA hopes that State air agencies will participate in
     this rulemaking by submitting comments to the public docket.

     Vehicle drivers and service station operators are the ones who
     choose  to misfuel.  Their choices are capable of being influenced
     by  factors  other than price differential.  EPA is conducting a
     public  awareness campaign to  inform these persons of the harm
     resulting from misfueling,  in an  effort to dissuade them.  State
     agencies can  contribute by  running similar campaigns.  It should
     also be noted  that  the existence  of an I/M program can be a deter-
     rent  to misfueling because  it raises people's awareness of motor
     vehicle pollution and  also  causes  them to think  ahead about their
     vehicles' ability to pass the next inspection.   In addition, a
      State  can check  for tampering  to  the fuel filler neck restrictor as
     part  of  the I/M  inspection.   This would provide  a strong incentive
     not to tamper with  the restrictor  and  thus would reduce the inci-
      dence  of misfueling.

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                                -33-

g) Emission Control Devices (Physical Inspection) - Is a test for tam-
pering by checking the functioning of emission control devices worth-
while from both a cost and an emission benefit standpoint?

     A recent survey performed in conjunction with six state safety
     inspection programs has shown approximately 20% of all 49-state
     cars now on the road have been grossly tampered.  The EGR system,
     which primarily affects NOx emissions, is the most common target
     for tampering, with a tampering rate of about 18%.  Other forms of
     tampering have rates of at most a few percent.  (These rates include
     cases where a malfunction may have occurred naturally but is equi-
     valent to one caused deliberately.)  The survey data show that
     tampered vehicles tend to have higher than average idle emissions
     and thus tend to fail an idle test more frequently.  For example,
     45% of the tampered vehicles in the survey failed a set of idle
     standards (the New Jersey Phase III standards), while only 35% of
     all the vehicles in the survey failed.  (A smaller sample of
     California cars also showed about 20% gross tampering, but for
     presently unexplained reasons the portion of the tampered cars
     which would fail I/M standards is lower, about 10%.)  The higher
     idle emissions of tampered vehicles are due in part to the effect
     of the tampering itself and in part to the fact that tampered
     vehicles tend to be misadjusted as well.  The net effect is that a
     sizable fraction of tampered vehicles will be sent to get repairs
     even in an I/M program that does not inspect for tampering.  Some
     of these will have the tampering corrected;  a state can increase
     the number through mechanics' training and/or regulations governing
     repair practices.

     EPA has not yet analyzed the available survey data to see whether
     a loaded mode test would identify a larger fraction of the tampered
     vehicles than does the idle test.  Engineering considerations alone
     suggest that it would, at least for emission control system elements
     which affect exhaust emissions.  (Positive crankcase ventillation
     (PCV) and evaporative emission controls do not always have an
     effect on exhaust emissions.)

     For  a  state  to be  certain  of  identifying  cases of  tampering and
     getting  them repaired, there  is no substitute  for  a tampering
     inspection.   The Portland,  Oregon I/M program has  found  the
     inclusion  of a tampering inspection to be workable.


     Any  I/M program can be expected to be a deterrent  to tampering.  An
     I/M program  that includes a tampering inspection presents a par-
     ticularly strong deterrent.  The survey mentioned above  showed that
     tampering sharply increases with vehicle age.  If an I/M program
     prevents this increase it will achieve additional emission reduc-
     tions at low cost.

     The  table shown below represents a very preliminary estimate of how
     much the fleet-average emissions of 1975 and later cars would be
     reduced if vehicles with the listed types of tampering were repaired.
     A more definitive analysis  and quantification is now underway.

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                                 -34-

         Preliminary Estimate of Fleet Emission Reductions
     (1975 and Newer Cars)  Resulting from Tampering Inspections
             (Base Emissions:  1.7 gpm HC,  25 gpm CO)

Component           Approximate       Approximate Fleet Emission Reductions
or System         Tampering Rate*        HC_           CO            NOx

PCV                    2.5%             1.4%          0              0

Air Pump               1.3%             0.8%          1.5%           0

Catalyst Removed       0.8%             0.7%          0.5%           0

Evaporative
Emissions Canister     1.3%             0.6%          0              0

Fuel Tank Cap
and Seal               0.7%             0.2%          0              0

EGR                    13%               0          uncertain      5-18%
*The "tampering" rates listed here include some malfunctions, such as
those due to inadequate maintenance, which are not due to tampering but
which may be detectable in a tampering inspection.  Tampering rates
are based on all in-use passenger cars of 1975 and newer model years (as
measured in the Mobile Source Enforcement Division 1978 Tampering Study),
not just those actually equipped with the particular emission control
component or system.

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                                     -35-
        EPA1s preliminary appraisal is that inspecting the listed components
        would have a cost-effectivness for HC and CO that is competitive
        with the idle inspection itself.   The same is true for a NOx/EGR
        inspection, as is described in question 1L: "Load/Idle Test."


h) Mechanics Training - What success has  been achieved with mechanics
   training programs?  Why were the Colorado State workbooks aimed prin-
   cipally at emission control devices while most repairs do not consider
   these?  Will EPA structure programs to consider this problem and the
   changes envisioned in future emission  controls and engines?

        Reports from I/M programs in which mechanic training has been
        implemented indicate considerable success.  In Phoenix a 2-hour
        training program conducted at automobile dealerships and independent
        garages was aimed at improving mechanics' ability to perform common
        emission related repairs such as  setting the idle air/fuel ratio.
        The Arizona motor vehicle inspection program staff has reported
        noticeable improvement in idle emission reductions resulting from
        this training.  They found fewer  cases of vehicles continuing to
        fail the emission standards after maintenance and a generally
        better acceptance of the program  by the service industry.

        The Colorado State University (C.S.U.) training materials were
        aimed principally at emission control devices in order to fill a.
        void in the existing training programs.  These materials were
        prepared to supplement the training in basic automotive repair
        being conducted in vocational training schools.  At the time they
        were developed by C.S.U., basic training materials were available
        to cover most common engine repairs, but none were available to
        cover the newly introduced emission controls.  Incorporation of the
        new materials into existing training programs for new mechanics was
        part of a long range program to upgrade emission related maintenance.

        In order to improve the emission  repair skills of practicing mechanics
        and produce a more immediate benefit, C.S.U. is now working on a
        new short course which will cover the detection, causes and cor-
        rections of HC and CO failures, infrared gas analyzer operation,
        diagnostic procedures, and EGR operational checks.  This course
        will be pilot tested in Denver starting March, 1979.  EPA will have
        these materials updated and/or modified as necessary for future
        emission control systems and repair procedures.

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                                    -36-
j) New Car Testing and Cars of the Future - Some states are considering
  testing new cars after their sale.  Would EPA consider testing all
  vehicles at the assembly plant with a short test as in I/M?  States
  could then decide on the necessity of post-sale tests.  What will be the
  effect on I/M - both its operation and effectiveness - of EPA's proposal
  that new cars meet emission standards over the entire range of timing
  and carburetion adjustments?  Will an engine parameter check be necessary
  with these vehicles?

       Data needed to respond to the first part of this question have not
       been received in time to be included in this letter.  A response
       will follow later.

       On January 12, 1979, EPA promulgated regulations which will require
       that automobiles are capable of meeting federal emission standards
       anywhere within the range of adjustments available on certain
       components.  The devices which limit the adjustability of a compo-
       nent must be tamperproof.  Components affected by these regulations,
       and the model year to which the regulation applies, are:  idle
       mixture adjustment (1981); choke (1981); idle speed (1982); initial
       spark timing (1982).  The inclusion of these components in the
       regulations was in direct response to the results of the restorative
       maintenance testing performed by EPA, in which these parameters
       were most frequently fqund to be maladjusted.

       For cars using current technology emission controls in 1981 and
       later model years, failures of an I/M test are expected to decrease
       due to these regulations.  In 1981, however, emission control
       technology for most cars is expected to change significantly.  This
       new technology is expected to have different maintenance require-
       ments which will minimize the need to periodically adjust common
       tune-up parameters.  Maintenance for this new technology is expected
       to involve periodic replacement of oxygen sensors and repair of
       input sensors to the electronic control system,  items not commonly
       found on current technology systems.  I/M will help assure these
       new maintenance and repair requirements are met, for it is expected
       in many cases that the driver will not perceive  a need to take
       corrective actions  (e.g., driveability may remain good).  In addi-
       tion, the emissions in the failed modes are expected to be at least
       as high as those seen on today's maladjusted vehicles.  Thus while
       it is hoped the failure rate will decrease, it is expected that  the
       amount of excess emissions per failed vehicle will  increase relative
       to the lower federal emission standards.

       These factors,  combined with the widespread occurrence of  tampering
       and misfueling, establish a need for I/M programs for new technology

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                                     -37-
        vehicles into the 1980's.  And of course, the current fleet of
        cars, for which maladjustments are widespread, will remain in the
        fleet for .10 years or more, and I/M is the only strategy to control
        their excess emissions.

        An engine parameter check may also be a valuable tool in assessing
        the operation of the new electronic control systems.  On some
        vehicles this may be as simple as checking a diagnostic light on
        the instrument panel.  An emission check, however, is expected to
        continue as the primary indicator of the total vehicle's emission
        performance.

j) Warranty - When will final warranty rules be promulgated?  Will the New
   Jersey type of idle test be sufficient to invoke the warranty provision
   of the Clean Air Act?  Would a private garage inspection system be.
   acceptable under warranty rules?  How will enforcement be carried out?

        Final emission performance warranty regulations and idle test
        standards will be promulgated this year, effective beginning with
        1980 or 1981 model year vehicles.  This warranty will be available
        to owners whose vehicles fail the Federal warranty idle test standard.
        Further, by law the warranty will be available only if some penalty
        or sanction is imposed; a non-mandatory program will not be suf-
        ficient.  Either a centralized (inspection lane) or decentralized
        (private garage) program will be acceptable.  EPA will not normally
        be involved in the day-to-day operation of these regulations.
        However, failure of a manufacturer to comply will be a "prohibited
        act" as specified in Section 203 of the Clean Air Act; civil pen-
        alties up to $10,000 are possible.  If problems arise, EPA will
        take appropriate enforcement.

k) EPA Reports and Rules - What is the cause of the delay in the publication
   of the Oregon study, Appendix N, and the warranty rules?

        The Oregon I/M study will not be complete until early 1980.  To
        deal with the need for information on the preliminary results of
        the study, a series of interim reports have been planned.  The
        first preliminary report, dealing with the initial effects of
        maintenance was published in May 1978.  The second preliminary
        report, which analyzes the deterioration over the first six months
        after maintenance, is now available.  Additional reports are planned
        as the study progresses; all reports are available through the EPA
        regional offices.

        Modifications based on comments to the proposed Appendix N (FR2422177)
        have been incorporated into the computer program MOBILE1, which is

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                                      -38-
        being widely used  to  calculate  emission  inventories and I/M credits
        for the January, 1979 SIP  submittals.  This  computer program con-
        tains EPA's best estimate  of  the  benefits  of I/M.   Appendix N has
        not been finalized in order to  allow  for modeling  changes which
        will best reflect  the incoming  data from the Portland study and
        testing of advanced prototype vehicles.  A final Appendix N will be
        promulgated late this year.

        Warranty coverage  under section 207(b) will  be promulgated prior to
        the widespread initiation  of  I/M  programs, a prerequisite for its
        application.   The  enforcement provisions are being reproposed in
        response to the change in  warranty provisions in  the 1977 Clean Air
        Act Amendments. The  enforcement  and  short test regulations will be
        promulgated for the 1981 model  year with a good chance of them
        being applicable to model  year  1980 as well.

1) EPA Reports and Rules - Why is  inconsistent information regarding fuel
   economy benefits of I/M being given  out?

        Every attempt is made to inform the EPA  Regions and the States of
        the latest information on  I/M benefits.  In  the case of fuel economy
        benefits, the Portland study  presented preliminary data which
        conflicted with the other  fuel  economy studies.  In the interim
        while this apparent discrepancy was under  investigation, some
        inconsistency in  interpreting the various  studies  was sure to
        occur.  As set forth  in a  previous question, the  fuel economy
        benefit of I/M is  now better  understood  and  quantified, and a
        report detailing  the  fuel  economy analysis will be distributed to
        the Regions and States in  April.* •

m) EPA Reports and Rules - Can't reports  such as the EPA  information docu-
   ment be updated periodically to reflect new information and correct
   erroneous data?

        As new information on I/M becomes available, it will be distributed
        to EPA Regions and to the  states.  The form  this  information may
        take will vary from updates of  existing  reports (such as the Portland
        Study) to new technical support reports.  The recently distributed
        information kit,  in looseleaf format, will be used to update
        information whenever  possible.   To obtain  the latest information
        available on any I/M-related  topic,  a request may also be addressed
        to the Ann Arbor I/M Staff.

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                                      -39-
        It  is  impossible  to update each document each time a piece of data
        changes.   The approach EPA is taking is to publish changing data
        whenever  it  may impact on conclusions concerning I/M.  In the
        example given in the question,  the New Jersey cost estimate did
        decrease  based on a newer study, however the range of repair costs
        quoted by EPA ($16 to $32 per failed vehicle) was still valid.

n) Information Center - Would EPA consider funding or lending assistance to
   establishment  of  a better I/M information network among the states.  All
   affected states should be kept up-to-date on recent reports, legislation,
   and other information.  Some states have expressed interest in obtaining
   copies of current enabling legislation and study efforts by other states.
   If  your office could compile this information and provide it for distri-
   bution through the regions, it would be of much help.  EPA should be
   sure to make its  reports and summaries sufficiently detailed to withstand
   the numerous challenges faced on the state level.

        It is  our view that a satisfactory system for distributing reports
        to the states exists.  As information and reports such as the
        Portland  Study become available, they will be distributed to the
        EPA regions, who will send the information to the states.  Likewise,
        questions concerning I/M should be addressed by the state to the
        Regions,  who will assure the appropriate answer or information is
        obtained.

        A newsletter, entitled I/M Update will be issued bi-monthly and
        will be used to disseminate information on recent developments in
        I/M.  A list of older studies on I/M is included in the I/M infor-
        mation document.   Specific to the question, copies of enabling
        legislation and a list of study reports on I/M options will be available
        from the  regional offices.
* US. GOVERNMENT PRINTING OFFICE: 1979- 650-029/0041

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