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

-------