EPA-AA-IMS-81-17 Technical Report DISCUSSION OF THE SELECTION OF COVERAGE AND FREQUENCY ALTERNATIVES IN INSPECTION AND MAINTENANCE PROGRAMS Jane A. Armstrong August 1981 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 ------- Table of Contents Page 1.0 Introduction 2 2.0 Background 2 3.0 Geographic Coverage 3 4.0 Selection of Vehicle Classes Covered 4 5.0 .Selection of Model Year Covered (Age Exemptions) 9 6.0 Selections of Inspection Frequency 14 ------- 3. 3.0 GEOGRAPHIC COVERAGE The first decisions to be made in selecting the geographic area in which I/M will be implemented are whether the program should focus only upon maj.or urban areas, and then, if so, how far beyond the urbanized area boundary the inspection -requirement should extend. For the densely populated States in the Northeast, a logical choice is to make the I/M program statewide. This option has been selected by Massachusetts, Connecticut, Rhode Island, and New Jersey. Other states are at the opposite end of the spectrum with major urban centers isolated within hundreds of miles of sparsely populated desert or mountainous terrain. Here the choice to implement I/M only in the urbanized area is equally logical. For most states, however, the choice is not so simple and must include a consideration of pollutant transport, commuter VMT and ease of administration. Many of the vehicles which contribute to an urban nonattainment problem (whether CO or ozone) are not garaged in the urbanized area proper. Vehicles from suburban developments in nearby counties may have a large percentage of their VMT occurring during trips for work or recreation to the urban center. A serious problem of public perception arises when urban residents note that not only are they the ones who must .live with excessive pollution, but .also they must comply with vehicle inspection requirements while their suburban neighbors need not. Thus the coverage area should be large enough to encompass all areas which significantly contribute to the non-attainment problem. Enforcement considerations assume the most important .role in selection of the exact coverage area. Two types of enforcement systems are possible, each with unique implications for the decision. They are sticker systems and registration systems. Registration systems generally are easiest to enforce, since they require no extra effort on the part of the police. A certificate is issued to vehicles which have complied with I/M program 'requirements, and this certificate is then used to obtain vehicle registration. Selection of county boundaries as inspection program limits provides a simple mechanism for tying program enforcement to a vehicle registration system. However, if this leads to the inclusion of sparsely populated, rural areas, it is relatively easy to identify subject vehicles by zip codes, city names, or even street names, provided the registration system is computerized. However, as the coverage area is decreased the problems associated with public perception increase. State and county boundaries have been long established. If different boundaries are set for the I/M program, such as non-attainment area boundaries, program managers may have to answer complaints from vehicle owners who reside just within the program limits about the alleged inequity of the I/M re qui rement. In sticker enforcement systems, police officers issue citations to vehicles which should have compliance stickers but do not. The main difficulty inherent in a sticker system lies in distinguishing between a non-complying subject vehicle and a non-subject vehicle which is operating in rthe same area ------- This vehicle class includes nearly all pick-ups and vans (except box-type vans). Most are non-commercial vehicles. It should also be mentioned that the limits of 6000 pounds curb weight and 45 square feet frontal area are only used to refine the basic definition of 8500 pounds GVW. There are few vehicles below 8500 GVWR which do not meet the other criteria. Although current, this definition of LDT's has only been in effect since 1979. From the beginning of federal motor vehicle emissions standards (in 1968) through 1974, LDT's were lumped together with LDV's in one large class of vehicles under 6000 pounds GVW. From 1975 to 1979 LDT's were defined as "any motor vehicles rated at 6000 pounds GVW or less," with the same uses as are currently defined. Then, in 1979, some trucks previously classed as heavy-duty became part of the light-duty class. These are called LDT2's by EPA to distinguish them from vehicles in the original class (LDTl's). Light-Duty Diesel Trucks (Diesel LDT)^ - diesel-powered vehicles with the same characteristics as gasoline LDT's. This is a very small class of vehicles, currently less than 1% of the total LOT fleet. Heavy-Duty Gasoline Trucks (HDG) - any gasoline-powered motor vehicle rated at more than 8500 pounds GVW or that has a vehicle curb weight of more than 6000 pounds or that has a basic frontal area in excess of 45 square feet. These vehicles include large commercial trucks, recreational vehicles and schooltype buses. Prior to 1979, this class included vehicles rated at more than 6000 GVW (see LDT definition for further\explanation). Heavy-Duty Diesel Trucks (HDD) - diesel-powered vehicles with the same weight and frontal area limitations as HDG's. This class of vehicles consists primarily of heavy tractor rigs; transit buses are also in this class. Motorcycle (MC) - Any motor vehicle with a headlight, taillight, and stoplight and having: two wheels or three wheels and a curb mass less than or equal to 680 kilograms (1499 pounds). (40 CFR 86.402-78) The relative contributions of the various vehicle classes to total mobile source emissions based on national averages are detailed in Figures 4-1 to 4-4. Percentages are projected by HOBILE2 (EPA's mobile source emission factor computer model) and assume no I/M implementation. Note that for the light-duty classes, diesel and gasoline emissions are combined. The vast majority of vehicles in these classes are gasoline-powered, however. 4.2 Discussion The vehicle classes inspected, in existing I/M programs are shown in Table 4-1. In deciding which vehicle classes to include in an I/M program, a planner should focus on program effectiveness, ease of implementation and equity. Each vehicle class will be discussed separately below, but there are * two general considerations which should be mentioned first. ' ------- Table 4-1 Vehicle Classes Inspected in I/M Programs GLDV Diesel LDV GLDT Diesel LOT I1DG HDD MC New Jersey yes no 6000 Ibs. no no yes no Oregon yes yes 8500 Ibs. 8500 Ibs. yes no no Arizona yes yes 6000 Ibs. 6000 Ibs. yes yes yes Ca lif ornia yes no 8500 Ibs. no no no no Nevada yes no 6000 Ibs. no no no no Rhode Island yes no 8500 Ibs no no no no New York yes no 8500 Ibs no no no no Georgia yes no 6000 Ibs no no no no ------- HDD's - As with light-duty diesels, heavy-duty diesel trucks have no known potential for HC or CO emissions reductions through I/M. Again, data suggest that these vehicles do not deteriorate significantly over time in their exhaust emissions. Approximately 60 percent of HDD VMT is short-haul, and is accrued mostly in urban areas. Smoke reduction potential does exist, but the number of excessively smoking diesels has not been quantified by EPA. Smoke testing requires a loaded test using a dynamometer if it is to be meaningful, since the smoke level at idle is not a good indication o-f smoke levels under load. Arizona's mandatory smoke check for diesels is at idle, and very few fail. There are also many political and administrative problems involved in testing heavy-duty diesels. Most .HDD's are interstate vehicles, thus they would be exempt from testing in all but their home states. Even in-state trucks may be from an area where I/M is not required. Motorcycles - Motorcycles have good HC and CO emissions reduction potential per vehicle through I/M, but a combination of small numbers and their relatively low vehicle mileage makes the total reduction achievable very small. As shown in Figures 4-1 to 4-4, motorcycles account for a negligible fraction (less than.1%) of total mobile source emissions. 4.3 Recommendations For the present, EPA recommends testing gasoline light-duty vehicles and gasoline light-duty trucks. The efficacy of testing these vehicle classes has .been proven,- and it is relatively simple to test gasoline LDT's in addition to LDV s. Furthermore, there is a large emission reduction benefit to be obtained from testing these vehicles, as seen in Figures 4-1 to 4-4. Since most LDT's are used for personal transportation, a serious equity argument arises if this class is excluded. It is recommended that a definition of less" than 8500 pounds GVW be placed on LDT's if EPA's exact definition cannot be met using existing registration procedures. When more data are available on the emissions reduction potential of heavy-duty gas trucks, and states and local areas have overcome the start-up problems in inspecting LDV's and LDT's, they can evaluate the need for testing these vehicles, and add them if desired. In a centralized program it might be wise to design some of the inspection lanes to be wide and tall enough to accommodate these trucks. 5.0 SELECTION OF MODEL YEARS COVERED (AGE EXEMPTIONS) An I/M program may exempt older model year vehicles from program requirements. Such exemptions may be considered to be desirable for many reasons, some of which are discussed below. However, exemptions reduce .the effectiveness of an I/M program, so they involve a tradeoff. Olders cars have less sophisticated emissions controls than are currently available. Pre-1968 vehicles were not subject to Federal emission standards, although most domestic models have been equipped with PCV valves since 1963. ------- 11 FIXED MODEL TERR RDJUSTMENT FflCTORS 1 . 0 0. 9 0,8 . 0. 7 0. 6 0.5 0.3 0. 2 0. 1 0.0 o H- O UJ o HTDROCRRBONS ==«= CRRBON MONOXIDE 69 70 71 72 73 7U 75 76 77 OLDEST MODEL TERR INSPECTED 78 79 80 Figure 5-1 ------- 13 Table 5-1 Moving Model Year Exemption Adjustment Factors for January 1, 1988 Evaluation of an I/M Program Number of Adjustment Factors ** Model Years * HC CO 19 iToo iToo 18 .99 .99 17 .99 .99 16 .98 .98 15 .97 .97 14 .96 • .96 13 .94 .94 12 .93 .92 11 .90 .89 10 .87 .86 9 .82 .81 8. .78 .76 • 7 . .70 .68 6 .63 .60 5 .55 .53 * If AGE=CALENDAR YEAR - MODEL YEAR, cars with AGE greater than "Number of Model Years" are not inspected. ** Adjustment factors are relative to an I/M program that inspects all model year vehicles, which in MOBILE1 or MOBILE2 is the same as the most recent 19 model years. Care should be taken when running MOBILE1 or MOBILE2 to input the model year coverage so that at least 19 model years, ending with the model year that is the same as the evaluation year, are covered. 5.1 Recommendations EPA makes no recommendations as to whether to grant age exemptions. But, if a state desires them, for whatever reasons, EPA recommends: (1) exemption of pre-1968 vehicles altogether, and (2) exemption of cars with AGE.greater than 15 years. Exemption of these vehicles, while accomplishing many of the goals of. age waivers, preserves most of the program's effectiveness. (For all practical purposes, in calculating effectiveness, this program is the same as one with only a 15 model year moving exemption; Table 5-1 can be used to calculate sffectiveness). The following table illustrates which model years would -be '.ncluded in the recommended program for the calendar years 1980 through 1987. ------- 15 Change-of-Ovnership Change-of-owriership inspection is the term used to represent a program where inspection is required upon transfer of 'title of a used motor vehicle and also when a used motor vehicle is registered for the first time in a 'specific political jurisdiction. In the absence of an annual inspection requirement a change-of-ownership I/M program will provide only a fraction of the emission reductions benefit that an annual program will provide. This fraction will be equal to the percent of the local fleet which changes ownership each year (typically 20%). Most I/M program managers will be concerned with the impact of adding a change-of-ownership inspection to the annual cycle. The following discussion concerns the emission reduction impact associated with a combined program. The I/M benefits which are calculated by EPA's computer model MOBILE2 are based on the assumption that each vehicle is inspected on the anniversary of its initial sale to its first owner. This would be true if registrations were good for one year and vehicles never changed ownership, for example. In reality, vehicles change ownership and this may make annual inspection only on the anniversary of initial sale undesirable or impractical. To illustrate, consider a vehicle which has been inspected annually each April because it was first bought from a new car dealer in April 1979. If this vehicle changes ownership in September 1985, there are four possible schedules it may be required to follow as a result: (i) No -inspection in September 1985; inspection in each April thereafter. (ii) Inspection in September 1985 as a precondition to the change in ownership; inspection in April 1986 and each April thereafter. (iii) Inspection in September 1985; and each September thereafter. (iv) No inspection in September 1985; inspection in each September thereafter. Which of these schedules will apply depends on the individual state's systems of vehicle registration and I/M- enforcement. A state may already find itself locked into just one of the schedules under existing statute, with no latitude to choose another schedule via agency regulations. Or a state may be able to choose from among two or more of the schedules when the responsible agency promulgates regulations. Schedule (i) is exactly the schedule assumed in the MOBILE2 model, so no adjustments to MOBILE2 benefits are needed. This schedule would be observed in a state where the registration cycle is tied to the vehicle (either by relating to the date of initial purchase or to a vehicle identifier such as the VIN) and there is no change-of-ownership inspection. ------- 17 Random Roadside Checks Due to limited resources, random roadside checks are not usually extensive enough to yield any significant emission reduction from the vehicles, that are failed by the checks and forced to get repairs. The emission benefit resulting from a roadside check program, if any, presumably comes from its deterrent effect. Because they fear being failed in a roadside check, owners might take better care of their vehicles and refrain from misadjusting them between regular inspections. The magnitude of this tendency depends on the likelihood of being caught and the "penalty" an owner suffers for failing a roadside check. This penalty can range from merely being required to get the failed vehicle repaired and reinspected to having to pay a fine. It is unlikely that any state would establish a fine so large that enough owners would continue to get precautionary repairs to result in the required reductions from a roadside check program alone. Therefore, a random roadside check program by itself is not a substitute for regular, periodic inspections. Random roadside checks could be added, however, to an annual I/M program. There are many possible reasons why. a vehicle which passed its regular inspection might fail '& subsequent roadside check. Natural deterioration in the engine since the last inspection is one possibility. In a decentralized program, the garage may have incorrectly certified the vehicle as passing its last inspection. Or, the owner or a mechanic may have tampered or misadjusted the car since the last inspection. Penalizing owners who fail roadside checks is fair only if the owner is responsible (e.g., if the owner misadjusted the vehicle or • asked a mechanic to do so). Since it would be impossible to determine when owners are responsible for the failures, no fine would be completely fair. EPA therefore recommends that roadside check data only be used for program assessment and that no penalties be imposed as a result of roadside check failures. Random roadside checks can have indirect benefits in addition to the small direct benefits that come from repair of vehicles which fail the checks and from the mild deterrent effect. Roadside checks can be used to monitor program operation and pinpoint problems that need special corrective attention. For example in a decentralized program, roadside checks showing that recently inspected cars have a much higher failure rate than being reported by licensed garages for regular inspections would indicate widespread error by garages in inspecting cars. Or, it might be found that cars recently inspected at specific garages have a much higher roadside failure rate than other cars. Either situation means the state should increase its garage surveillance and quality assurance programs. Inspection Window Under any inspection schedule, there is a window in time within which each vehicle must pass inspection. Most states with operating I/M programs define this period as two or three months prior to the compliance deadline, which provides sufficient time for owners to obtain any needed repairs. 6.3 Recommendations The recommended program consists of annual, staggered inspections. The recommended inspection window is 2 or 3 months prior to registration ------- |