PA 910/9-79-68
           United States
           Environmental Protection
           Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
          Air
October 1979
          Development of
          Motor Vehicle
          Emissions Inspection
          And Maintenance Programs
          For the State of Washington

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                                         GCA-TR-79-66-G
U.S. ENVIRONMENTAL PROTECTION AGENCY
          Region 10 Office
     Seattle, Washington  98101
      Contract No. 68-02-2539
         Task Order No. 11
           October 1979
        DEVELOPMENT OF MOTOR

  VEHICLE EMISSIONS INSPECTION AND

        MAINTENANCE PROGRAMS

    FOR THE STATE OF WASHINGTON

            Final Report
                 by

        Theodore P. Midurski
        Frederick M. Sellars
           GCA CORPORATION
       GCA/TECHNOLOGY DIVISION
       Bedford,  Massachusetts

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                                 DISCLAIMER
     This Final Report was furnished to the U.S.  Environmental Protection
Agency by GCA Corporation, GCA/Technology Division,  Bedford Massachusetts in
fulfillment of Contract No. 68-02-2539, Task Order No.  11.   The opinions, find-
ings, and conclusions expressed are those of the  authors and not necessarily
those of the U.S. Environmental Protection Agency or of the sponsoring organi-
zations.  Mention of company or product names is  not to be  considered as an
endorsement by either the U.S.  Environmental Protection Agency or any of the
sponsoring organizations.

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                                 ABSTRACT
     Recent ambient air quality data for the State of Washington indicate
that certain National Ambient Air Quality Standards will not be attained in
all areas of the State by 1982, even if all reasonably available control
technologies are applied.  In view of this, it is likely that the State will
request from U.S. EPA an extension of the compliance data beyond 1982.  In
order for this request to be considered, the State must, among other things,
have adopted a firm schedule for implementing a motor vehicle inspection and
maintenance (I/M) program in the highly urbanized nonattainment areas.
Currently the State, through its Department of Ecology, is developing a
set of control strategies, including I/M, for implementation in certain areas.
Technical assistance was provided to the Department of Ecology by GCA/Tech-
nology Division through a contract sponsored by Region  10 of U.S. EPA.  The
primary purpose of the assistance was to provide the Department of Ecology
with information regarding technical aspects of I/M on a quick response basis
to aid in the continuing process of program development.  This document pro-
vides a summary of the work performed by GCA under this contract.
                                  iii/iv

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                                  CONTENTS
Abstract	ill
Figures	vi
Tables	vi

     1.   Introduction	    1
               Background 	    1
     2.   Summary of Work Performed	    2
               Task 1 - Review Proposed SIP Revision for
                 the Puget Sound Region 	    2
               Task 2 - Assessment of the Impact of Varying
                 Stringency Factor and Vehicle Age Cutoff
                 on CO Emissions Reduction Potential  	 .....    4
               Task 3 - Examine and Summarize the Provisions
                 of Section 207 (b) of the Clean Air Act
                 Amendments of 1977	    9
               Task 4 - Assessment of Policies Regarding
                 Vehicle Exemptions and Waivers 	   11
               Task 5 - Analysis of Issues Related to
                 Geographic Coverage  	 	   16
               Task 6 - Review the Draft Request for Proposal
                 and Supporting Documentation .	18

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                                   FIGURES
Number
        Projected 1987 emission burden from affected vehicles
          as a function of stringency factor, for various age
          exemption cutoffs	 .
                                   TABLES

Number                                                                   Page

   1    Assumptions Used in Developing the Mobile Source
          Emissions Inventory for the Puget Sound Region  	  3
   2    Carbon Monoxide Emissions Reductions Achievable
          by 1987 (%),  for the Central Puget Sound Region
          for Affected  Vehicles Only as a Function of
          Stringency and Age Exemption	6
   3    Carbon Monoxide Emission Reductions Achievable
          by 1987 (%),  for the Central Puget Sound Region,
          for all Vehicles as a Function of Stringency
          and Age Exemptions	6
   A    Projected 1987  CO Emissions Reduction Per Inspected
          Vehicle (kg/day) for the Central Puget Sound
          Region, as a Function of Stringency and Age
          Exemption Cutoff   	 	  8
   5    Projected 1987  CO Emissions Reduction Per Failed
          Vehicle (kg/day), for the Central Puget Sound Region
          as a Function of Stringency and Age Exemption
          Cutoff	'8
   6    Emissions Profile for the Central Puget Sound Region -
          1987 Emissions (kg/day)	13
   7    Aggregated 1972-1977 FTP Emission Reductions as a
          Function of Repair Cost Ceiling  	 14
   8    I/M-Related CO Emissions Reduction Achievable by 1987
          (percent) for the Central Puget Sound Region, as a
          Function of Stringency Factor and Repair Cost Limit 	 15
   9    I/M-Related HC Emissions Reduction Achievable by 1987
          (percent) for the Central Puget Sound Region, as a
          Function of Stringency Factor and Repair Cost Limit 	 16
                                     vi

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                                  SECTION 1

                                 INTRODUCTION
BACKGROUND

     The 1977 Amendments to the Clean Air Act established the requirement for
all areas in the U.S. to be in compliance with the National Ambient Air Quality
Standards for carbon monoxide (CO) and photochemical oxidants (Ox) by
31 December 1982.  Further, these amendments required that State Implementation
Plans (SIP) be developed and submitted to the U.S. Environmental Protection
Agency indicating precisely what methods would be used to ensure compliance
by the }.982 mandatory attainment date.

     Several nonattainment areas have been identified in the State of Washington,
therefore the State, through its Department of Ecology, has been involved with
the development of a set of control strategies that will be applied in those
areas requiring such control.  One strategy that is currently proposed for
implementation is the establishment of a motor vehicle inspection and maintenance
(I/M) program for a portion of the Puget Sound Air Quality Control Region, and
possibly for the Spokane area as well.  The overall responsibility for develop-
ing the I/M program lies with the Department of Ecology.

     The initial effort undertaken by the Department of Ecology focused on
Identifying and assessing various technical issues that will ultimately define
the program format in terms of what vehicles will be included, how and where
the inspections will be performed, who will perform the inspections, how much
the inspections will cost, and others.  Technical assistance was provided to
the Department of Ecology by GCA/Technology Division through a contract sponsored
by the Region X Office of the U.S. Environmental Protection Agency.  Specific-
ally, this assistance involved responding to requests by the Department of
Ecology for information regarding technical aspects of I/M, both in a general
sense and as applied specifically to implementation in the State of Washington.
The primary purpose was to provide a quick response to the Department so that
the information could be used in the continuing process of program development.
In order to expedite this process, a technical memorandum was prepared for each
task performed; this resulted in a more or less continuous flow of information
to the Department throughout the contract period.

     The purpose of this document is to provide a summary of the work performed
by GCA under this contract.  In this connection, a summary of each task per-
formed is provided here .

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                                  SECTION 2

                          SUMMARY OF WORK PERFORMED
INTRODUCTION

     During the contract period the Department of Ecology identified a total of
six tasks related to the I/M development effort.  Again, these tasks were
accomplished in support of the overall process of developing the I/M program.
Information developed as a result of these tasks was used either directly in
the program planning effort, or as background data and therefore used in a
more indirect fashion.  The following paragraphs summarize the six tasks
performed.

TASK 1 ~ REVIEW PROPOSED SIP REVISION FOR THE PUGET SOUND REGION

     The objective of this task was to review the techniques used to develop
the mobile source emissions inventory for the Puget Sound region.  This review
indicated that the SAPOLLUT and MOBILE1 models were used to generate emissions
estimates based on the 1977, 1982, and 1990 highway networks.  This modeling
was conducted by the Department of Transportation.  The SAPOLLUT model was
modified by the Department of Transportation so that current emissions
factors could be used.  A number of assumptions were used in defining various
input parameters; these are summarized in Table 1.

     With regard to CO analysis in the Puget Sound SIP, SAPOLLUT was used to
generate total emissions produced in various area configurations, among which
were 2 km by 2 km UTM grid cells.  Selected grid cells, then, define the ac-
tivity centers that are considered CO hot spots.  It is noted that all hot
spots were designated as a result of long-term ambient monitoring activity;
the absence of a monitoring station in a particular area precludes that area
from consideration as a hot spot.  The measured air quality data were used as
the basis for determining the reduction in emissions necessary within the grid
cell in order to comply with the NAAQS; the actual reduction was derived using
a proportional rollback technique.

     Our primary comments concern two issues.  First, we are somewhat uncertain
about the appropriateness of basing CO emissions reduction requirements for an
area (i.e., the 4 km2 grid cells that define the hot spots) on the apparent
CO concentrations measured at only 1 or 2 sites within that area.  Our concern
is based on the fact that CO is an extremely localized pollutant, therefore,
hot spots should be considered in terms of individual intersections or street
links rather than a fairly large area (4 km2, for instance).  It is our opinion
that the areawide approach is not necessarily sensitive enough to adequately

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assess either the pervasiveness of individual hot spots, the root causes of the
high ambient CO levels, or particular measures that may be effective in reducing
CO emissions locally but not on an areawide basis (traffic signal improvements,
for example).  Currently, the SIP analyzes the impact of localized measures,
such as signal interconnection, from the standpoint of their impact on total
emissions produced in the grid cell.  This means that the importance of CO
emissions reductions realized from such a measure could be drastically under-
stated if the reduction was considered from the perspective of total emissions
produced in the grid cell.  Moreover, the direct impact of measures that affect
traffic flow are defined in terms of average travel speed.  Other critical
factors (again, relative to very localized areas such as individual intersec-
tions or street links), such as acceleration/deceleration time and rates, and
delay (idling) time, are not reflected realistically when considering areawide
CO production, owing primarily to the use of FTP-based emissions factors being
applied rather than a more site-specific technique such as applying the Modal
Analysis Model.

     TABLE 1.  ASSUMPTIONS USED IN DEVELOPING THE MOBILE SOURCE EMISSIONS
               INVENTORY FOR THE PUGET SOUND REGION
             Parameter
     Assumption used for CO inventory
Ambient Temperature
Vehicle Speed

Cold Starts


Hot Starts
Vehicle-type distribution

Vehicle age distribution
45ฐF

One speed assumed for all vehicles using
a specific link

20.6% of Daily VMT; additional cold mode
fraction included at origins and '
destinations.*
27.6% of Daily VMT

LDV = 83.3%; LDTj = 5.8%; LDT2 = 5.8%;
HDV-G = 4.5%; HDV-D = 3.1%; MC = 0.5%t

National average (as defined in MOBILE 1)
8-hour and 1-hour maximum emissions  60% and 10% of total daily emissions.
* "  t"^-l-*-k-1"' •     : ' ""- ••--•.-•••--
 Some question remains regarding the assumptions used for this additional
 component.
 It is noted that the total is 103%.  This is assumed to be a result of a
 typographical error in the report.

Source:  Attaining and Maintaining Air Quality Standards in the Central Puget
         Sound Region.  Puget Sound Air Pollution Control Agency.
         November 1978.

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     Further, it is not clear that the monitoring site is actually measuring
typical (average) ambient levels for the entire grid cell.  One certainly would
be tempted to ask if compliance at the monitoring site assures compliance else-
where in the grid cell (similarly, does the monitor actually measure atypically
high levels, with respect to the entire grid cell, because of unique traffic
characteristics on the surrounding streets).  These types of questions should
be considered prior to committing various control measures, primarily to assure
that the measures are:  (1) adequate, and (2) required.  It is our conclusion
that the answers to these questions can be formulated only after a comprehensive!
site-specific analysis is undertaken.

     The second area concerns the assumptions used in developing the CO emis-
sions inventory.  In general, we agree with most assumptions used, however, we
offer the following suggestions.  First, one set of assumptions regarding the
vehicle-type distribution is used for all functional classes of highway.  It
may be that a more precise estimate of the vehicle-type distribution as a func-
tion of roadway type (functional class) could be incorporated.  This is partic-
ularly important in assessing CO since very local traffic characteristics
dominate with respect to ambient levels at any particular site, and emissions
characteristics vary widely by vehicle type.  Vehicle-type distribution for
various cities around the United States indicate that substantial differences
can be expected among the different functional categories.

     It is also suggested that the cold-start percentage be considered as a
function of both general location (e.g., downtown zones, residential zones,
etc.) and time of day.  Again, since CO is of primary importance, it is appro-
priate that the analyses reflect both spatial and temporal variations in emis-
sions in as much detail as is practical.

TASK 2 - ASSESSMENT OF THE IMPACT OF VARYING STRINGENCY FACTOR AND VEHICLE
AGE CUTOFF ON CO EMISSIONS REDUCTION POTENTIAL

     This task involved a detailed assessment of the sensitivity of emissions
reduction potential as a function of the stringency factor used and the vehicle
model years included in an I/M program.  The objective was to provide suffi-
cient data for the DOE to select the optimum stringency level and policy con-
cerning vehicle exemptions.  The results of this task effort were reported in
Technical Memorandum No. 1, dated June 1979, entitled "Impact of Varying Strin-
gency Factor and Vehicle-Age Cutoff on CO Emission Reduction Potential from I/M."

     Motor vehicle emission inventories for CO were developed for several I/M
scenarios that could be implemented in the Central Puget Sound Region, utiliz-
ing EPA1s MOBILE1 computer model.  Included were estimates of the emissions
reductions achievable from the following I/M program configurations:

     •    No vehicle age exemptions, with stringency factors  (failure
          rates) of 10, 20, 30 and 40 percent.

     •    Vehicles older than 15 years exempt, with stringency factors
          of 10, 20, 30, and AO percent.

     •    Vehicles other than 12 years exempt, with stringency factors
          of 10, 20, 30, and 40 percent.

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     •    Vehicles older than 10 years exempt, with stringency factors
          of 10, 20, 30, and 40 percent.

     •    Vehicles older than 8 years exempt, with stringency factors
          of 10, 20, 30, and 40 percent.

Inventories were developed for 1987 indicating the impact that each program
scenario would have in terms of both emissions from the affected vehicle popu-
lation only (essentially light-duty cars and light-duty trucks), and emissions
from the entire vehicle fleet.  Summary  matrices of the emission reductions
achievable as a function of vehicle age exemption and stringency factor are
provided for affected vehicles only and all vehicles in Tables 2 and 3,
respectively.

     Of particular interest are the reductions shown in Table 2, those achiev-
able by affected vehicles for 1987.  As stated in the Federal Guidelines for
1/M programs, USEPA requires at least a 25 percent reduction in emissions in
1987 from light-duty vehicles (LDV's and LDT's) included in the program com-
pared to the emissions which would have been produced by these same vehicles
in the absence of I/M.  In Table 2 it is shown that even the minimum program
being analyzed here, (10 percent stringency, vehicles older than 8 years exempt),
will just meet the minimum reduction criteria.  The results given in Table 2
are graphically displayed in Figure 1.

     Increasing either the stringency factor or age exemption cutoff will in-
crease the emission reduction achievable.  It should be noted, however, that
the "law of diminishing returns" applies here.  The additional reduction
achievable by increasing the stringency factor from 20 to 30 percent is signif-
icantly less than that achieved by increasing the stringency level from 10 to
20 percent.  Similarly, the additional reduction achievable by increasing the
age exemption cutoff from 10 years to 12 years is significantly less than is
achievable by increasing the age exemption cutoff from 8 years to 10 years.

     Since the program scenarios evaluated reflect different numbers of in-
spected and failed vehicles, it is instructive to consider two additional
statistics - the emissions reduction achieved per inspected vehicle, and the
reduction achieved per failed vehicle.  Table 4 shows that the emission
reduction per inspected vehicle increases as the program is made more stringent,
in terms of both failure rate and age exemption criteria.  For any given age
exemption cutoff, increasing the failure rate will yield greater reductions
per inspected vehicle as the number of vehicles requiring maintenance increases
with a constant inspectable vehicle population.  Increasing the age exemption
cutoff while holding the failure rate constant will also yield increased reduc-
tions per inspected vehicle as older vehicles will tend to realize greater
benefits (in terms of emission reduction) from maintenance.  Thus, despite an
increased inspectable vehicle fleet, the emissions reduction per inspectable
vehicle also increases.  This may be better demonstrated in Table 5, emission
reductions per failed vehicle.

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TABLE 2.  CARBON MONOXIDE EMISSIONS REDUCTIONS ACHIEVABLE
          BY 1987 (%), FOR THE CENTRAL PUGET SOUND REGION
          FOR AFFECTED VEHICLES ONLY AS A FUNCTION OF
          STRINGENCY AND AGE EXEMPTION*

Exempt vehicles older thai

8
10
12
15
No age

years
years
years
years
exemptions
Stringency
i :
10
25
30
33
36
38

20
29
36
39
43
45

30
32
40
44
48
50
(%)

40
34
42
46
51
54

      Light-duty vehicles (LDV, LDT1, LDT2)'
     TABLE 3.  CARBON MONOXIDE EMISSION REDUCTIONS
               ACHIEVABLE BY 1987  (%), FOR THE
               CENTRAL PUGET SOUND REGION, FOR ALL
               VEHICLES AS A FUNCTION OF STRIN-
               GENCY AND AGE EXEMPTIONS
      Exempt vehicles older  than:
                                    Stringency  (%)
                                    10   20   30   40
                8 years
               10 years
               12 years
               15 years
           No age exemptions
19  22  24  25
23  27  30  32
25  30  33  35
27  32  36  38
28  34  38  41

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    600,000
    828,000
    480,000 -
 -  878,000
    500,000
 9 228,000


 I


     180,000





      78,000
(T) VEHICLES OLDER THAN tyrt EXEMPT

0 VEHICLES OLDER THAN lOyn EXEMPT

0 VEHICLES OLDER THAN IZyrt EXEMPT

0 VEHICLES OLDER THAN ISyn EXEMPT

[?) NO AGE EXEMPTIONS
                     	:	i_
IO             20
      STRINGENCY, ptrcซnt
                                                      30
                             40
Figure  1.   Projected  1987 CO emission burden from affected vehicles as
            a function of stringency  factor, for  various age  exemption
            cutoffs.

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TABLE 4.  PROJECTED 1987 CO EMISSIONS REDUCTION PER
          INSPECTED VEHICLE (kg/day) FOR THE CENTRAL
          PUGET SOUND REGION, AS A FUNCTION OF
          STRINGENCY AND AGE EXEMPTION CUTOFF

Exempt vehicles older than:
Stringency


10
8
.10
12
15
No age

years
years
years
years
exemptions

0.
0.
0.
0.
0.

106
111
112
117
121



20
0.
0.
0.
0.
0.

125
133
135
141
145



30
0.
0.
0.
0.
0.

135
146
150
157
162



40
0.
0.
0.
0.
0.

144
155
159
167
173
TABLE 5.  PROJECTED 1987 CO EMISSIONS REDUCTION PER
          FAILED VEHICLE (kg/day), FOR THE CENTRAL
          PUGET SOUND REGION, AS A FUNCTION OF
          STRINGENCY AND AGE EXEMPTION CUTOFF
	 — 	 — ' 	 	 - • 	 	 • 	 — 	 	 --.-___ -
Stringency factor (percent)
hxempl vehicles older than:
10
8
10
1.2
L5
No age exemptions
1
1
1
1
1
.060
.110
.120
.170
.210
20
0
0
0
0
0
.625
.665
.675
.705
.725
0
0
0
0
0
30
.450
.487
.500
.523
.540
40
0
0
0
0
0
.360
.388
.398
.413
.433

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     While increasing the age exemption cutoff will yield greater reductions
per failed vehicle, increasing the stringency factor will have the opposite
effect.  A low failure rate will identify only the "gross emitters," those
vehicles which stand to achieve the greatest emission reduction with main-
tenance.  By increasing the failure rate, total emission reductions and re-
ductions per inspected vehicle will increase; however, vehicles standing to
gain less emission reduction from required maintenance are now also failed,
thus lowering the average reduction per failed vehicle.

     The emission statistics reported above are based on the assumption that
all vehicles operating in the study area will be included in the I/M program
(with the exception of age waivers).  Since the State is considering an I/M
program that is limited to the most densely developed areas, the above assump-
tion will probably be invalid.  This does not reduce the value of the inven-
tories presented here, however, for two reasons:  first, the relative emission
reductions between scenarios are of more value in selecting an I/M program
than the actual magnitude of emission burden; secondly, the inventories pre-
sented here may be utilized in assessing the likely result of adding or elim-
inating certain areas to the program, given some indication of the magnitude
of VMT in the study Region generated by vehicles registered in the areas in
question.

TASK 3 - EXAMINE AND SUMMARIZE THE PROVISIONS OF SECTION 207(b)
OF THE CLEAN AIR ACT AMENDMENTS OF 1977  .

     Under this task the provisions of Section 207(b) were analyzed and an
explanatory document was developed and submitted to the State.  This document
provided discussion of several issues connected with Section 207, including:

     •    Background of emission control warranty, its purpose and
          justification;

     •    Emission control components covered and duration of coverage;

     •    Vehicles covered by warranty;

     •    Emission tests capable of activating the warranty and rela-
          tionship of these tests to I/M programs;

     •    Warranty claim procedures (manufacturer and vehicle owner
          responsibilities and obligations); and

     •    Summary of benefits of warranty.

     The U.S. Environmental Protection Agency considers the emissions per-
formance warranty, along with inspection/maintenance  (I/M), as primary strate-
gies for ensuring that in-use motor vehicles continue to meet the emission
standards for which they were designed.  The 207(b) warranty provisions and
I/M are directly related in that the claims under the 207(b) provisions can
only be made as a result of failing an emissions test conducted as part of an
I/M program.  The warranty, then, is an important safeguard for consumers
affected by I/M, and therefore is also an important inducement for manufacturers
to build long lasting, effective emission control systems and components.

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     Under provisions of the warranty, the vehicle owner is responsible for
performing routine maintenance on the control devices, while the manufacturer
is responsible for replacing or repairing components or systems that fail
within the warranty period if proper maintenance has been performed by the
vehicle owner

     During the initial period of 24,000 miles or 24 months the 207 (b) war-
ranty covers any system, assembly, or device, or component thereof which
affects emissions.  From this period until the warranty expires at 50,000 miles
or 5 years, the coverage is somewhat more limited.  It only includes "a cata-
lytic converter, thermal reactor or other component installed in or on a
vehicle for the sole or primary purpose of reducing emissions, which was not
in general use prior to the model year 1968."  This more limited coverage does
include modification to parts (other than calibration changes) made for the
sole or primary purpose of reducing motor vehicle emissions.

     The warranty will be applicable only to those vehicles manufactured in
the model year subsequent to EPA promulgation of the regulations establishing
the emission performance warranty.  EPA has developed short tests (discussed
below) for light-duty vehicles, and it has been indicated that the regulations
concerning these tests and the warranty will be promulgated prior to model year
1981.  It is expected, therefore, that 1981 and later model year light-duty
vehicles would be covered by these regulations.  EPA also anticipates that
appropriate short tests will eventually be developed for other types of
vehicles, so that the warranty provisions will eventually extend to include
all vehicle types.

     The following excerpt describes the warranty claims procedures in the
proposed regulations:

     "(a) A claim under the Emissions Performance Warranty may be raised
     immediately upon failure of an EPA-approved emission test if, as a
     result of that failure, an owner is required to take action of any
     kind in order to avoid imposition of a penalty or sanction.  An owner
     need not suffer the loss of the right to use a vehicle, be fined, incur
     repair expenses, or actually bear any penalty or sanction to satisfy
     the requirement of Section 85.2103(a)(3).  That requirement shall
     be met if a test failure sets a procedure in motion under which the
     owner will bear a penalty or sanction if a vehicle is not brought
     into conformity, or repaired to some specified extent."

     There are two important points to note here.  The first concerns the
definition of an EPA-approved test.  As required in Section 207(b), the U.S.
EPA has developed short tests for light-duty vehicles that correlates adequately
with the lengthy Federal Test Procedure (FTP).  These tests include:

     •    the idle test
     •    the Federal 3-mode
                                     10

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     •    the Clayton Key mode

     •    the Federal Short cycle

     •    the New York/New Jersey short cycle.

     It is anticipated that the tests will be approved prior to 1981.  Existing
inspection/maintenance programs around the country use both the idle and loaded
tests Which are essentially identical to the tests developed by EPA and there-
fore are capable of activating the warranty.

     The second point is that, in order to involve a claim under 207(b), a
vehicle owner need not actually suffer the penalty of a fine or denial of
registration but simply that the failure of the emission test sets in motion
a procedure under which he ultimately would be fined or otherwise penalized
if the vehicle was not subsequently repaired.

     Significant potential exists for motorists to expeirence difficulties
in obtaining warranty-related repairs on emissions control systems.  In view
of this, claim procedures have been included in the proposed rules that
require the manufacturer to prove that the owner does not meet the warranty
requirements if a warranty claim is challenged.  Under this proposal, the
manufacturer is required to inspect the vehicle to determine if there is
objective evidence that the owner had not performed the proper maintenance
of the emission-control devices as set forth in the owners manual (what con-
stitutes objective evidence will presumably be defined later, probably in
agreements between EPA and each auto company).  Finding objective evidence,
a manufacturer may then ask the owner to see his repair records or maintenance
logs (warranty book) to demonstrate that he was following proper maintenance
instructions.

     In summary, there are three basic areas where the warranty program would be
particularly effective.  First, it would provide an incentive for vehicle
owners to undertake proper, routine maintenance in order to meet warranty
requirements.  Second, the program would provide an incentive for motor vehicle
manufacturers to design and build vehicles with emission control systems and
devices capable of lasting for the useful life of the vehicle.  And, finally,
the warranty provisions may encourage states and localities to ensure the
quality of repair work through repair facility certification or licensing.

TASK 4 - ASSESSMENT OF POLICIES REGARDING VEHICLE EXEMPTIONS AND WAIVERS
                                                s
     The objective of this task was to assess the implications of various poli-
cies affecting the vehicle population included in the I/M program and the grant-
ing of waivers under certain circumstances.  The focus of the effort was to
define the impacts in terms of air quality benefits, consumer attitude, and
repair cost distribution; these issues were presented in Technical Memorandum
No. 3 - "Exemptions and Waivers,"  dated July 1979.

     One of the more crucial factors that determine the success or failure of
any I/M program concerns public acceptance.  In order for any I/M program to
be accepted by the public, it must be perceived as fair and equitable.  In
this regard, it is important that the program provide exemptions for certain


                                      11

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circumstances.  Issues such as vehicle age and repair costs for compliance,
and matters of practicality such as vehicles that present difficulties in the
actual performance of inspections, must be considered since arbitrarily includ-
ing all vehicles (in general or even within any particular category) may
jeopardize the success of the entire program.

     At this point, the term "exempt" will be defined to mean not affected by
the program.  An exempt vehicle, therefore, would not be required to become
involved in any facet of the I/M program.  "Waivers" are considered to be dif-
ferent from exemptions in that waivers apply to individual vehicles or subsets
of particular vehicle categories.

     Specific requirements for the implementation of motor vehicle I/M programs
were established under the Clean Air Act Amendments of 1977.  By mandate, only
light-duty vehicles (LDV) must be included in the program.

     The I/M program in Washington will exempt the following types of vehicles:

     •    New motor vehicles,

     •    Vehicles that are more than 14 years old,

     •    Electric vehicles,

     •    Motorcycles,

     •    Diesel vehicles,

     •    Farm vehicles, and

     •    Vehicles given special consideration by the Director of the
          Department of Ecology.

     The question of heavy-duty truck (gasoline or diesel-powered) exemptions
is -often controversial.  Many view trucks as "the real polluters," since,
occasionally, visible particulate emissions are emitted from these types of
vehicles (generally, diesel-powered trucks).  An examination of an emission
profile for the mobile sources in the Central Puget Sound Region, provided in
Table 6, shows that by 1987, 69.9 percent of the carbon monoxide emissions
and 81.4 percent of the hydrocarbon emissions will be generated by the light-
duty fleet while the heavy-duty diesel fleet will contribute only 2.4 percent
and 3.5 percent, respectively, to the total carbon monoxide and hydrocarbon
emissions within the region.  It is quite clear from Table 6 that exempting
heavy-duty, diesel-powered vehicles will probably be of minimal consequence
in terms of total emissions reduction.  On the other hand, it can be concluded
that - the contribution from heavy-duty, gasoline-powered vehicles is significant
enough to warrant these vehicles being included in the program.

     Several additional issues must be considered with regard to including
heavy-duty vehicles of any type in an I/M program.  One issue, for example,
concerns the need for information on the present state of routine maintenance
practices in the heavy-duty vehicle sector.  It is quite likely that there would
be a tendency for commercial fleet owners to maintain their vehicles more ade-
quately than do individual vehicles owners, primarily because the higher operat-
ing costs associated with an improperly-maintained vehicle are generally more

                                      12

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     TABLE 6.  EMISSIONS PROFILE FOR THE CENTRAL PUGET  SOUND REGION - 1987  EMISSIONS (kg/day)*

                 LDV"1"             HDV-G             HDV-D               MC             Total
Pollutant	
           kg/day (% total)  kg/day (% total)  kg/day  (%  total)   kg/day (total)   kg/day (% total)
   CO      461,980 (69.9)    182,013 (27.6)    15,899  (2.4)          711 (0.1)      660,603 (100)
            47,047 (81.4)      8,546 (14.8)     2,043  (3.5)          135 (0.2)       57,771 (100)

 Emissions in 1987, without I/M, T = 75ฐF.
Includes LDV's, LDTl's, LDT2's.
rReactive (nonmethane) hydrocarbons only.
Source:  GCA calculations, 1979.

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visible and considered more crucial to commercial fleet operators.  This could
mean that the actual potential for reducing emissions from heavy-duty vehicles
is somewhat less than might be indicated otherwise.

     A second issue concerns the fact that commercial vehicles typically
accumulate mileage at very high rates (it certainly would not be unusual for a
long haul unit to average over 100,000 miles annually, or for a delivery truck
to travel over 40,000 miles yearly).  One could question, then, the effective-
ness of an annual emissions inspection.  Related to this is the issue of where
the commercial vehicle travel occurs.  Long haul and certain private carrier
operations are likely to involve travel almost exclusively outside a relatively
small area (such as the Central Puget Sound Region)^ therefore, if I/M require-
ments were imposed, most of the benefits might be realized outside of the area.

     The basic inspection requirements for heavy-duty vehicles are different
from those for light-duty vehicles.  Larger inspection facilities and special
equipment are required for heavy-duty vehicles therefore the program cost is
increased.  All of these issues must be considered in the context of heavy-
duty vehicle exemption policies.

     Waivers are generally granted on the basis of costs associated with com-
plying with the standards.  Usually, states set specific limits, generally $50 to
$100, on the amount of money that has to be spent on necessary repairs before
a waiver is granted releasing the vehicle owner from compliance.

     Also, waivers can be granted to owners of either new vehicles being re-
gistered for the first time, or vehicles that, for some technical reason, cannot
be tested easily.  For instance, testing full-time, four-wheel drive vehicles
on a dynamometer (loaded-mode) may not be practical; a waiver could be granted
or an idle test could be prescribed for these special vehicles.

     The I/M Legislation for the State has established a mandatory repair cost
limit of $50.  Analyses were performed to determine the impact of this $50
repair limit on the expected emissions reduction achievable with the I/M pro-
gram.  The results of this analysis are summarized in Table 7.

     TABLE 7.  AGGREGATED 1972-1977 FTP EMISSION REDUCTIONS AS A FUNCTION
               OF REPAIR COST CEILING

                                    Percent reduction*
Cost
ceiling ($)
No limit
150
100
75
50
25
(Percent of total (Percent of total
FTP HC reduction potential) FTP CO reduction potential)
41
40
32
29
26
16
(100)
( 98)
( 78)
( 71)
( 63)
( 39)
43
42
41
38
34
27
(100)
( 98)
( 95)
( 88)
( 79)
( 63)

   Source:  GCA Calculations, 1979.
   *Assumes a 20 percent failure rate.
                                       14

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     As shown in Table 7, the establishment of a $50 repair cost ceiling
will result in the realization of only 63 percent of HC and 79 percent of
the CO emissions reduction possible without a repair cost limit.

     Table 8 describes the CO emission reductions associated with the I/M
program as a function of repair cost ceiling and stringency factor.  The
same analysis was performed for hydrocarbon emissions; this matrix is pro-
vided in Table 9.

     As shown in Table 8, the $50 repair cost ceiling will enable the State
to utilize a stringency factor as low as 10 percent and still assure more
than a 25 percent reduction in carbon monoxide emissions from the projected
1987 level without I/M.  However, hydrocarbon emissions reduction, as shown
in Table 9, requires both additional stringency and/or a higher repair cost
ceiling.  Even without a repair cost ceiling, a 10 percent stringency factor
will be best yield at 34 percent HC emission reduction.

      TABLE 8.  I/M-RELATED* CO EMISSIONS REDUCTION ACHIEVABLE BY 1987
                (PERCENT) FOR THE CENTRAL PUGET SOUND REGION, AS A
                FUNCTION OF STRINGENCY FACTOR AND REPAIR COST LIMIT
                  Repair cost ceiling ($)
  Stringency
  (percent)

10   20  30  40
No limit
150
100
75
50
25
36
35
34
32
28
23
43
42
41
38
34
27,
48
47
46
42
38
30
51
50
48
42
40
32
                   Light-duty vehicle (LDV, LDT1, LDT2)
                   emissions only, I/M begins in 1982,
                   vehicles older than 15 years exempt.

                  Source:  GCA Calculations, 1979.


     Currently it is proposed that the maximum failure rate for the program
be 30 percent.  Realistically, then, it can be expected that the actual
failure rate would be in the range of approximately 20 to 30 percent, which,
as indicated in Table 8, would likely achieve the minimum reduction with' a
$50 repair cost limit.  It must be remembered, however, that the repair costs
shown here are in constant 1978 dollars, therefore the real issue is the
types of repairs performed rather than merely repair costs.
                                     15

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                     TABLE 9.  I/M-RELATED  HC EMISSIONS
                               REDUCTION ACHIEVABLE BY
                               1987 (PERCENT) FOR THE
                               CENTRAL PUGET SOUND REGION,
                               AS A FUNCTION OF STRINGENCY
                               FACTOR AND REPAIR COST LIMIT
Repair cost ceiling
No limit
150
100
75
50
25
Stringency
,*. (percent)
10
34
33
27
24
22
13
20
41
40
32
29
26
16
30
44
43
35
31
28
17
40
48
47
38
34
31
19
                   *Light-duty vehicle (LDV, LDT1, LDT2)
                    exhaust emissions only.  I/M begins
                    in 1982, vehicles older than 15 years
                    exempt, nonmethane hydrocarbons only.
                   Source:  GCA Calculations.  1979.
     The reader is also cautioned that the data used to develop the above ana-
lysis were somewhat tentative, therefore the most appropriate conclusions are
those that consider the relative rather than absolute implications of repair
cost, stringency, and program effectiveness.

TASK 5 - ANALYSIS OF ISSUES RELATED TO GEOGRAPHIC COVERAGE

     This task required that detailed assessments be made of various proposals
for defining the geographic coverage of the I/M program.  Considered were
issues such as EPA requirements, regional travel patterns, public attitude,
enforcement, and specific boundary definitions.  The results of the assessment
were reported in Technical Memorandum No. 4 - "Geographic Coverage," dated
August 1979.

     There are several factors to be considered by the State when defining the
geographic coverage of the I/M program.  The urban areas with populations of
200,000 or more plus the adjacent fringe areas are the EPA-suggested minimum
boundaries.  For the Puget Sound Region, the urban plus fringe areas consti-
tute considerable portions of greater Seattle, Everett, and Tacoma.

     Since some flexibility in boundary definition has been provided in the
EPA policy guidance ("Boundaries of the area affected may be adjusted if an
equivalent emission reduction is achieved."), Washington should utilize this
flexibility to define boundaries that will:

                                      16

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     •    enable the program to achieve at least minimum
          reduction criteria;

     •    be logical in terms of equity;

     •    be enforceable; and

     •    be acceptable to the public.

     In addressing these issues several factors must be considered in addi-
tion to the formal urban area definitions.  These include:  travel patterns,
public reaction, enforcement considerations and the need to utilize some readily
identifiable means for defining the I/M area  (city or county lines, or ZIP code
zones, for instance).

     In order to calculate the potential emissions reduction within the non-
attainment area, the percentages of total VMT attributable to "affected" and
"nonaffected" vehicles must be considered.  If a significant portion of vehicles
from a non-I/M area travel to I/M areas, then it would be appropriate to con-
sider extending the I/M coverage to include those emission contributing areas.

     To identify specific "emission contributing areas," analyses should be
conducted using the region's transportation planning data base to identify
specific trip interchange characteristics.  These analyses would identify the
approximate fractions of VMT within the nonattainment area that are generated
by vehicles registered in each "emission contributing area."  With this
information, additional analyses can be conducted to determine the potential
impact (in terms of emissions reduction) of adding or eliminating each of the
areas.   The basis for determining the appropriateness of any coverage scenario
would be whether or not a 25 percent reduction in 1987 LDV CO and HC emissions
within the nonattainment area is achieved with the particular scenario.

     Since Washington has expressed the desire to minimize the geographic
coverage of the I/M program, the boundaries will likely be defined on a sub-
county level.   While any less-than-statewide program is bound to foster some
controversy owing to the public feeling of inequity, the problem will be com-
pounded if the boundaries are perceived as ambiguous,   For this reason,  the
minimum unit area considered in defining the boundaries should be a readily
recognizable entity such as a municipality or a ZIP code zone.   Further, a
specific rationale should be developed for including a particular area,  such
as the significant contribution of VMT in the nonattainment area,  considerable
growth potential, etc.   Serious public relations problems could arise if
residents of one portion of a municipality were required to participate in the
program, while the remaining residents were not.  This type of reaction could
also occur if one municipality is included in the program while a similar,
bordering municipality was not.

     A municipality, then, should be the absolute minimum unit area considered
in the boundary definition.   The I/M area should also be as contiguous as
practicable.  Finally,  the public should be well informed on the rationale
used in boundary selection.
                                      17

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     As indicated in Washington's I/M legislation, the program will be enforced
by requiring owners of affected vehicles to provide a certificate of compliance
as a prerequisite to annual motor vehicle registration.  In any program
involving less than statewide coverage, a means for identifying vehicles that
are covered by the program is imperative to enable enforcement of the regula-
tions.  This concept must be considered in defining the geographic coverage
of the program.  There are no significant problems associated with registration
enforcement, provided that the geographic boundaries are selected in a manner
that will enable easy identification of these vehicles based on the information
normally provided on the registration form.  To incorporate one portion of a
town in the program while excluding another portion of the same town, for
instance, may complicate the identification of covered vehicles.  Utilization
of an identifiable unit area, like ZIP code zones would facilitate the identi-
fication of those vehicles requiring certificates of compliance at registration
time.

TASK 6 - REVIEW THE DRAFT REQUEST FOR PROPOSAL AND SUPPORTING DOCUMENTATION

     Under this task the draft Request for Proposal (RFP) being prepared by
the Department of Ecology was reviewed.  Also, some of the technical support
documentation was reviewed, as well.
       t
     The draft RFP was found to be very similar in both scope and language to
the RFP used by the State of California to solicit bids for a contractor to
operate a network of centralized inspection lanes.  Generally, only minor com-,
ments or questions resulted from our review of both the RFP and the supporting
documents.  These were discussed with Department of Ecology officials at a
meeting held in Olympia on 30 August 1979; no documentation was prepared in
connection with this task.
                                      18

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                                  TECHNICAL REPORT DATA
                           (Please read instructions on the reverse before completing)
I REPORT NO.                   2.
   EPA 910/9-79-68	J	;	
 TITLE AND SUBTITLE  Development of Motor Vehicle  Emissions
   Inspection  and Maintenance Programs  for  the State
   of Washington
                                                          3. RECIPIENT'S ACCESSION>NO.
                                                          5. REPORT DATE
                                                                October 1979
                                                          6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)

    Theodore P. Midurski and  Frederick M. Sellars
                                                         8. PERFORMING ORGANIZATION REPORT NO.

                                                             GCA-TR-79-66-G
9. PERFORMING ORGANIZATION NAME AND ADDRESS
    GCA CORPORATION
    GCA/TECHNOLOGY DIVISION
    Bedford, Massachusetts 01730
                                                          10. PROGRAM ELEMENT NO.
                                                          11. CONTRACT/GRANT NO.

                                                           68-02-2539      TO No. 11
 12. SPONSORING AGENCY NAME AND ADDRESS
    U.S.  Environmental Protection Agency
    Region 10
    1200 Sixth Avenue
    Seattle, Washington  98101
                                                          13. TYPE OF REPORT AND PERIOD COVERED
                                                             Final  Report
                                                          14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
IB. ABSTRACT
           Recent ambient  air quality data for  the State of Washington  indicate that
    certain National Ambient Air Quality Standards will not be attained in  all areas
    of the State by  1982,  even if all reasonably  available control technologies are
    applied.  In view  of  this, it is likely  that  the State will request from EPA an
    extension of the compliance data beyond  1982.   In order for this request to be con-
    sidered, the State must, among other things,  have adopted a firm schedule for im-
    plementing a motor vehicle inspection and maintenance (I/M) program in  the highly
    urbanized nonattainment areas.  Currently the State, through its Department of
    Ecology, is developing a set of control  strategies, including I/M,  for  implementa-
    tion in certain  areas.  Technical assistance  was provided to the Department of
    Ecology by GCA/Technology Division  through  a  contract sponsored by  Region 10 of
    EPA.  The primary  purpose of the assistance was to provide the Department of
    Ecology with information regarding  technical  aspects of I/M on a quick  response
    basis to aid in  the continuing process of program development.  This document
    provides a summary of the work performed by GCA under this contract.
                               KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
    Automobile  engines
    Exhaust  detection
    Exhaust  emissions
                                             b.lDENTIFIERS/OPEN ENDED TERMS
                                              Automobile  Emissions
                                              Inspection/Maintenance
                                              Mobile  Source Control
                                                                       c.  COSATI Field/Group
 3. DISTRIBUTION STATEMENT

    Unlimited distribution
                                             19. SECURITY CLASS (ThisReport)
                                                UNCLASSIFIED
21. NO. OF PAGES

     24
                                             20. SECURITY CLASS (Thispage)
                                                 UNCLASSIFIEp
                                                                        22. PRICE
EPA Form 2220-1 (9-73)
                                             19

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