United States Environmental Protection Agency

         Office of Air and Radiation
    MOTOR VEHICLE TAMPERING SURVEY - 1984

                September 1985
                 Robert Greco
    FIELD OPERATIONS AND SUPPORT DIVISION
           OFFICE OF MOBILE SOURCES
               Washington, D.C.

-------
United States Environmental Protection Agency

         Office of Air and Radiation
    MOTOR VEHICLE TAMPERING SURVEY -  1984

                September 1985
                 Robert Greco
    FIELD OPERATIONS AND SUPPORT DIVISION
           OFFICE OF MOBILE SOURCES
               Washington, D.C.

-------
                      TABLE OF CONTENTS
EXECUTIVE SUMMARY 	 	  1

  Introduction 	  1
  Conclusions  	  3

BACKGROUND 	  8

SURVEY METHODS 	 12

  Site Descriptions  	 14

RESULTS 	 20

  Vehicle Tampering 	 20
    Site and Aggregate Totals 	 20
    Tampering Trends 1978-1985 	 22
    Types of Tampering 	 26
    Vehicle Characteristics and Tampering 	 31
      Vehicle Type  	 31
      Vehicle Age 	 31
      Manufacturer  	 40
    Effect of I/M Programs on Tampering  	 43
    Effect of Antitampering Programs on Tampering 	 47
    Effectiveness of I/M-only vs. I/M + ATP 	 51
    I/M Programs and Geographic Bias 	 53
    Correlation Between Tampering and Idle Emissions ... 54

  Fuel Switching 	 60
    Fuel Switching Indicators and Overlap 	 60
    Fuel Switching Rates  	 61
    Fuel Switching by Vehicle Type 	 67
    Fuel Switching and Vehicle Age 	 67
    Catalyst Tampering and Fuel Switching 	 67
    Gasoline Lead Concentrations	 . 69

APPENDICES

    A.  Relevant Portions of Clean Air Act 	 73
    B.  Survey and Data Recording Procedures 	 74
    C.  Emission Cutpoints for I/M Areas 	 88
                             -11-

-------
                       LIST OF. FIGURES
 1.  Component specific tampering rates:
     1978-1984 surveys  	  4

 2.  Overall and Catalyst tampering by vehicle model
     year - 1984 survey  	  7

 3.  Breakdown of surveyed vehicles by condition and
     extent of tampering 	 21

 4.  Cumulative tampering prevalence as a function of
     vehicle age for the 1978-1984 surveys 	 36

 5.  Cumulative catalyst tampering rates as a function
     of vehicle age for the 1978-1984 surveys 	 37

 6.  Comparison of catalyst and overall tampering rates
     with vehicle age as a function of survey year 	 39

 7.  Tampering rates by manufacturer - 1984 survey 	 41

 8.  Tampering prevalence by manufacturer for the
     1978-1984 surveys 	 42

 9.  Comparison of data from 1984 survey sites that had
     been surveyed previously (Figs. 9(a) and (b)) 	 52

10.  Distribution of survey sample among tampering,  fuel
     switching, and idle test categories 	 55

11.  Overlap of tampering and carburetor misadjustment
     among conventionally carbureted vehicles - 1984
     survey	 57

12.  Overlap of fuel switching indicators among unleaded
     vehicles - 1984 survey 	 62

13.  Overlap of catalyst tampering and fuel switching
     among catalyst-equipped vehicles - 1984 survey 	 70

14.  Lead concentrations in fuel sampled from misfueled
     vehicles 	 71
                            -111-

-------
                        LIST OF TABLES
 1.  Tampering Prevalence by Vehicle Type for
     Critical Control Components 	  7

 2.  1984 Tampering Survey Summary 	 23

 3.  Classification of Vehicle Condition by Survey
     Site 	 24

 4.  Trends in Vehicle Condition Classification 	 25

 5.  Comparison of 1984 Survey Sample to Actual
     Nationwide Vehicle Fleet 	 25

 6.  Prevalence of Tampering by Component and Survey
     Year 	 27

 7.  Component-Specific Tampering Rates (percent)  by
     Survey Location - 1984 Survey 	 29

 8.  Prevalence of Arguable Tampering by Component
     and Survey Year 	 30

 9.  Tampering Prevalence (and Sample Size) by Model
     Year and Vehicle Age at Time of Survey 	 32

10.  Percentage of Catalyst Removal (and Sample Size)
     among Catalyst-Equipped Vehicles by Model Year
     and Vehicle Age at Time of Survey 	 33

11.  Tampering Prevalence in I/M and non-I/M Areas 	 45

12.  Tampering and Fuel Switching Prevalence by Vehicle
     Type in I/M and non-I/M Areas 	 46

13.  Catalytic Converter Tampering Prevalence by Vehicle
     Type in I/M and non-I/M Areas - 1984 Survey 	 48

14.  Tampering Rates (percent) for Components
     Checked in I/M + ATP Areas - 1984 Survey 	 50

15.  Idle Test Failure Rates (percent) by
     Pollutant and Vehicle Condition 	 58
                             -iv-

-------
16.  Mean Idle Emissions by Vehicle Condition 	 58.

17.  Fuel Switching Rates among Unleaded Vehicles by
     Site and Indicator - 1984 Survey 	 63

18.  Fuel Switching Prevalence among Unleaded Vehicles
     in I/M and non-I/M Areas 	 65

19.  Fuel Switching Rates among Unleaded Vehicles by
     Indicator and Survey Year 	 65

20.  Combined Tampering and Fuel Switching
     Rates - 1984 Survey 	 66

21.  Percentage of Fuel Switching (and Sample Size)
     among Unleaded Vehicles by Model Year and Vehicle
     Age at Time of Survey 	 68
                             -v-

-------
                       EXECUTIVE  SUMMARY

                          INTRODUCTION

     Under  the direction  of  the  Field Operations  and Support

Division  (FOSD) of  the Environmental Protection Agency (EPA),

contract  personnel  from Colorado State University (CSU)

conducted a  survey  of  light-duty motor vehicle  tampering  in

14  cities between April and  October, 1984.  The areas surveyed

and  the total number of vehicles inspected  are  listed below.

     Bakersfield, CA                320
     Reno, NV                       83
     Dallas, TX                     268
     Birmingham, AL                 300
     Washington, DC                 300
     Cincinnati, OH                 325
     New  Jersey                     270
     New  York, NY                   308
     Boston, MA                     286
     Tampa,  FL                      327
     St.  Louis, MO                  314
     Portland, OR (two weeks)       603
     El Paso, TX                    334
     Milwaukee, WI                  388

     TOTAL                        4,426 vehicles

The  objectives of this  survey were:

     1. T-O—make local  measurements  of the types and  extent  of

        tampering and  fuel switching.

     2. To extend and  update the knowledge  gained from earlier

        surveys on:

        a. The rates of overall  and component-specific

           tampering and  fuel switching.

        b. The distribution  of tampering by vehicle  age,

           type, manufacturer, and  other variables of

           interest.

-------
                             -2-

        c. The correlation between tampering and vehicle

           idle emissions.

        d. The effect of vehicle inspection and maintenance

           (I/M) programs and antitampering programs  (ATPs)

           on tampering and fuel switching.

     To achieve these objectives, the inspection teams

visually examined emission control devices and measured the

idle hydrocarbon (HC) and carbon monoxide (CO) emissions of

each vehicle.  To provide information on fuel switching, the

inspectors sampled gasoline from the tanks of vehicles  (for

later laboratory lead analysis), tested for lead deposits  in

tailpipes using Plumbtesmo® test paper, and checked the

integrity of the fuel filler inlet restrictors.  Four cate-

gories were used to summarize the condition of the inspected

vehicles:

     1. Tampered - at least one control device removed  or
        rendered inoperative

     2. Arguably Tampered - possible but not clear-cut
        tampering

     3. Malfunctioning

     4. Okay - all control devices present and apparently
        operating properly

These brief but thorough inspections were performed with the

consent of the vehicle owners in a variety of settings more

fully detailed elsewhere in this report.

-------
                              -3-




                         CONCLUSIONS



     The surveyed vehicles were classified as  follows:




tampered -  22%; arguably tampered - 29%; malfunctioning  -  4%;




okay - 46%  (overall survey averages).  The 22%  tampering rate




is less than  the 26%  rate found in 1983  but greater  than the



rates from  the other  large surveys of  1978, 1979,  and  1982.



Since these surveys encompass different  sites with different



vehicle age distributions, truck proportions, and  other



characteristics, direct comparisons between surveys  should  be



made cautiously.  This survey is also  heavily weighted with



I/M + ATP areas, as is detailed later  in this  report.  The



overall tampering rate for 1984 increases to 26% when  the data



is weighted for the proportion of the  national  vehicle fleet



covered by  I/M-only programs and I/M + ATPs.  The  tampering



rate for areas without an I/M program was 31%,  while the rates




for I/M-only and I/M  + ATP areas were  17% and 11%, respectively.




     The component-specific rates for selected  critical



components are shown  in Figure 1.  The results  shown have not



been weighted to compensate for I/M program representation;



these rates probably  underestimate the actual nationwide rates.



The tampering rates for catalytic converters and filler  inlet




restrictors have increased steadily since 1978, while  the



rates for other components fluctuated over the  years.  The



increasing  tampering  rates for catalytic converters  and  inlet




restrictors may be partly due to the increasing age  of the

-------
                                 -4-
ComponQnt or SystQm
Catalytic ConvertQr
 Evaporative System
    Air Pump System
   Inlet Restrictor
         PCV System
         EGR System
1978

1979

1981

1982

1983

1984
                                                          132
                                                         132
                            Tamporing RatQ  C%)
            Figure 1.  ComponQnt-specific tampering rates:
                      1978 - 1984  surveys.

-------
                             -5-

vehicles surveyed.  Areas with I/M programs had a 3% catalyst

removal rate, while non-I/M areas had an 11% rate.  Catalytic

converter removal increases HC and CO emissions by an average

of 475% and 425%, respectively.!  For vehicles equipped with

three-way catalysts, substantial increases in NOX emissions

would also be expected to occur.

     The fuel inlet restrictor and the exhaust gas recirculation

(EGR) system were the most frequently tampered components (10%).

EGR system tampering can increase NOX emissions by an average

of 175%.  The EGR tampering rates in I/M and non-I/M areas were

7% and 14%, respectively.

Fuel Switching

     Fuel switching, defined as the presence of any of the

three indicators^, was found in 14% of the unleaded vehicles

in the 1984 survey.  This is the same rate found in the 1983

survey.  The weighted fuel switching rate was 16%.  The fuel

switching rates in non-I/M,  I/M-only, and I/M + ATP areas
were 19%, 10%, and 8%, respectively.  The pattern of overlap

among the three indicators is discussed in detail later in

this report.  While the emissions impact of fuel switching

depends upon its duration and certain vehicle characteristics,

emission increases of 475% for HC and 425% for CO can easily

occur.
1  The emissions increases mentioned in this report are from a
study of three-way catalyst vehicles presented in Anti-Tampering
and Anti-Misfueling Programs to Reduce In-Use Emissions from
Motor Vehicles, EPA-AA-TTS-83-10, December 31, 1983.

2  The three fuel switching indicators are: a tampered fuel
filler inlet restrictor, a positive Plumbtesmo® tailpipe test,
and a gasoline lead concentration of more than 0.05 grams
per gallon.

-------
                              -6-



Aqe of Vehicle



     A vehicle's age is clearly related to the probability



that it has been tampered, as has also been shown  in previous



surveys.  This is evident in Figure 2, which shows  the  rates



by model year for both overall tampering and catalyst removal.




Fluctuations in age-specific rates might be expected for




very old (1975) vehicles because of the smaller sample  size




for that model year.  These age-specific rates are  investigated



more thoroughly later in this report.




Vehicle Types



     The tampering rates for light-duty trucks was  equal  to or




higher than for automobiles in every tampering category,  as




shown in Table 1.  The difference in catalytic converter



tampering is particularly striking --  nearly three  times  as



prevalent for light-duty trucks as for passenger cars (14%




vs 5%).



I/M programs and tampering



     The tampering rates in non-I/M areas were at  least double




those in I/M areas for every critical  component.  Those areas




with I/M plus antitampering programs had lower tampering



rates than the I/M-only areas.  The deterrent effect of I/M



programs, however, cannot be easily separated from  the geograph-




ical influences on tampering rates. The differences in



program status of the various I/M areas must be considered



as well.  These aspects are discussed  more thoroughly later




in this report.

-------
                                   -7-
Tampering Rate (Z)
      50
       10 -
                                                                     Overall
                                                                    Tampering
                                                                    Catalyst
                                                                    Tampering
          1984    1983  1982   1981   1980   1979   1978   1977   1976   1975
                              Vehicle Model Year

                 Figure 2.   Overall and catalyst tampering  by
                            vehicle model year - 1984 survey.
                                TABLE 1

              Tampering  Prevalence by  Vehicle Type  for
                     Critical Control Components
                                        Tampering Rate (%)
Component /System
Catalytic Converter
Filler Neck Restrictor
AIR System
PCV System
Evaporative Control
System
EGR System
OVERALL
Trucks
14
14
12
3
5
10
27
Cars
5
9
7
2
2
10
21
Overall
7
10
7
2
3
10
22
        Fuel Switching
19
13
14

-------
                              -8-






                           BACKGROUND






     Motor vehicle emissions  in urban areas account for nearly




90% of the total carbon monoxide (CO) and airborne lead, over




30% of the hydrocarbons (HC) ,  and nearly 40% of the oxides of




nitrogen (NOX) emitted into the atmosphere.  As a result, a major




focus of the nation's efforts  to achieve compliance with clean




air standards has been the control of emissions from mobile




sources.  In order to meet required emission standards, vehicle




manufacturers have,  since  1968,  installed a variety of pollution




control devices on new vehicles.




     The 1977 amendments to the Clean Air Act (sections




203 (a) (3) (A) and (B), found in Appendix  A)  make it illegal for




automobile dealers,  repair and service facilities, and fleet




operators.to disconnect or render inoperative emission control




devices or elements  of design.  Regulations issued under section




211 (c) of the Act (40 CFR  Part 80)  prohibit retailers and




wholesale purchaser-consumers  from introducing or allowing the




introduction of leaded gasoline into vehicles labeled "unleaded




gasoline only".  The EPA's Field Operations and Support Division




(FOSD), formerly the Mobile Source Enforcement Division (MSED),




is responsible for enforcing  the tampering  and misfueling




provisions of the Act.

-------
                              -9-

     Before 1978, the EPA had data suggesting that tampering

with emission control devices and misfueling of "unleaded only"

vehicles with leaded gasoline was occurring.  Variability in

the inspection procedures, however, prevented an accurate

assessment of the nature and extent of the tampering.  As a

result, the Agency began conducting nationwide tampering

surveys of light-duty motor vehicles in 1978 to determine the

rates and types of tampering and fuel switching.  These surveys

were conducted in 19781, 19792, 19813, 19824, and 19835,

either by FOSD directly or by EPA's National Enforcement

Investigations Center (NEIC) under the direction of FOSD.

Consistent inspection procedures were used throughout these

surveys to permit comparisons and identification of trends.
   Motor Vehicle Tampering Survey (1978), U.S. Environmental
   Protection Agency, Mobile Source Enforcement Division,
   November 1978.
2  Motor Vehicle Tampering Survey (1979), U.S. Environmental
   Protection Agency, National Enforcement Investigations
   Center, May 1980, EPA-330/1-80-001.

3  Motor Vehicle Tampering Survey - 1981, Chattanooga, Tennessee
   and Houston, Texas,  U.S. Environmental Protection Agency,
   National Enforcement Investigations  Center, March 1982,
   EPA-330/1-82-001.

4  Motor Vehicle Tampering Survey - 1982, U.S. Environmental
   Protection Agency, National Enforcement Investigations
   Center, April 1983,  EPA-330/1-83-001.

5  Motor Vehicle Tampering Survey - 1983, U.S. Environmental
   Protection Agency, Field Operations  and Support Division,
   August 1984, EPA-460/1-84-001.

-------
                            -10-




     Th e uses for the tampering surveys  have evolved since the



first survey was conducted in 1978.   In  1983,  the tampering



survey results for some locations were used to calculate credits



for State Implementation Plans (SIPs), the measures taken by



State and local governments to achieve ambient air quality




standards by reducing mobile source  emissions.  Data from the



surveys is also used in the default  database for the Agency's




mobile source computer model (MOBILES) to estimate both the



emissions loading impact and the reductions that may be achieved




by various control programs.  Sites  for  the surveys are chosen



in light of the need for data on specific areas considering




programs, as well as the continuing  need to monitor the types



and extent of tampering and fuel switching nationwide.



     The 1984 tampering survey was conducted for FOSD by the



National Center for Vehicle Emissions Control  and Safety,



Colorado State University (CSU).  The inspection procedures



used were consistent with those of previous surveys.  The



objectives of this survey were:



     1.  To make local measurements  of the types and extent of



         tampering and fuel switching.




     2.  To extend and update the knowledge gained from earlier



         surveys on:

-------
                     -11-



a.  the rates of overall and component-specific



    tampering and fuel switching.



b.  the distribution of tampering by vehicle age,



    type,  manufacturer, and other variables of



    interest.



c.  the correlation between tampering and vehicle



    idle emissions.



d.  the effect of vehicle inspection and maintenance



    (I/M)  programs and antitampering programs (ATPs)



    on tampering and fuel-switching rates.

-------
                           -12-


                         SURVEY METHODS


     The 1984 tampering survey was conducted in 14 cities between

April and October,  1984.   A goal of inspecting 300 vehicles in

each location was established to ensure a statistically meaning-

ful database; 4,426 total vehicles were actually inspected.

The mix of vehicles inspected was assumed to be a self-weighting

sample, and no attempt was made to approximate the national

vehicle mix.

     Each inspection team consisted of  at least four members:

three CSU personnel, one  or two EPA representatives, and fre-

quently a state or  local  agency representative.  The CSU personnel,

assisted by the state or  local person,  performed the actual

inspections, while  the EPA representative(s)  supervised the survey.

Each vehicle inspection included the following:

     1.  basic vehicle identification data recorded (year,

         make, model)

     2.  all emission control systems checked

     3.  idle HC and CO emissions measured

     4.  fuel sample collected from unleaded-only vehicles for

         lead analysis.

     5.  tailpipe tested  for  lead deposits using Plumbtesmo®^

         test paper

     6.  integrity  of fuel inlet restrictor  checked
6  Plumbtesmo® is a registered  trademark,  and  appears hereafter
without the ®.  It is manufactured  by Machery-Nagel,  Duren, W.
Germany, and marketed by Gallard-Schlesinger Chemical Corp.,
Carle Place, New York.

-------
                             -13-



Th e inspection and recording procedures are detailed in



Appendix B.  The survey database has been reviewed by CSU,




EPA, and the automotive manufacturers to ensure its accuracy.



     The survey included only 1975 and newer light-duty cars



and trucks fueled with gasoline.  For the purposes of the




tampering surveys, a vehicle is considered to be "unleaded"



if a dash label, tank label, or filler inlet restrictor



is observed at the time of the inspection.  A vehicle's



designation as "unleaded" or "leaded" may be changed upon




subsequent review of the data.  Fuel switching rates are



thus calculated based only on the unleaded vehicles surveyed.



Similarly, tampering rates for specific components are based



only on the vehicles originally equipped with the component.



     The inspections were performed with the consent of the




vehicle owners at either roadside pullovers or inspection



stations.  The survey was designed to minimize the refusal



rate of potential survey participants.  A high refusal rate  -



increases the uncertainty in the data gathered,  and indivi-



duals who have tampered with or misfueled their vehicles are



less likely to allow their vehicles to be surveyed.  The



overall refusal rate was relatively low (8%), but some



survey sites had very high refusal rates (see below).   The



tampering and misfueling rates at these particular locations



might be significantly higher than reported here.  A brief



description of each survey site follows.

-------
                             -14-

Bakersfield, California -  Roadside Pullovers

Dates:               April 2-5, 1984
Vehicles Surveyed:      320
Fuel Samples:           184
Refusal Rate:             2%
Tampering Rate:          31%
Misfueling Rate:         14%

     The California Highway Patrol provided an officer to

stop potential survey participants, and the inspectors

solicited permission to conduct the inspections.  Locations

for pullovers were changed daily.


Reno, Nevada - Inspection Stations

Dates:               April 9-13,  1984
Vehicles Surveyed:       83
Fuel Samples:            37
Refusal Rate:             6%
Tampering Rate:          31%
Misfueling rate          22%

     The Reno survey was conducted at the Reno DMV office and

at privately-owned I/M inspection stations.  Low vehicle

volume at the I/M stations during the middle of the month led

to the small survey sample.


Dallas, Texas - Roadside Pullovers

Dates:               April 30 - May 4, 1984
Vehicles Surveyed:      268
Fuel Samples:           204
Refusal Rate:            29%
Tampering Rate:          28%
Misfueling Rate:         18%

-------
                             -15-

     Th e Texas Department of .Public Safety  (TOPS) provided

officers to stop potential survey participants.  The survey

was conducted in conjunction with a TOPS driver's license and

insurance card check, which could have increased the refusal

rate.  Survey locations were changed daily.


Birmingham, Alabama - Roadside Pullovers

Dates:               May 7-11, 1984
Vehicles Surveyed:      300
Fuel Samples:           162
Refusal Rate:             4%
Tampering Rate:          32%
Misfueling Rate:         25%

     Roadside pullovers were conducted with the help of local

law enforcement officers of municipalities in the Birmingham

area.  Inspection locations were changed daily and included

Birmingham (three days), Hoover, and Homewood.


Washington, D.C. - Inspection Stations

Dates:               May 14 - 18, 1984
Vehicles Surveyed:      300      	
Fuel Samples:           213
Refusal Rate:            12%
Tampering Rate:          23%
Misfueling Rate:         10%

     The Washington, D.C.  survey was conducted at two

centralized I/M stations (three days at one location and two

days at the other).

-------
                             -16-

Cincinnati, Ohio - Roadside Pullovers

Dates:               May 21-25,  1984
Vehicles Surveyed:      325
Fuel Samples:           273
Refusal Rate:            12%
Tampering Rate:          28%
Misfueling Rate:         12%

     The roadside pullovers were conducted with the help of

Ohio State Highway Patrol officers throughout the greater

Cincinnati area.  Some participants actually sought out the

survey as a result of extensive  press coverage both prior

to and during the survey,  possibly resulting in an

underestimation of tampering and misfueling rates.



New Jersey - Roadside Pullovers  and Inspection Stations

Dates:               June 18-22, 1984
Vehicles Surveyed:      270
Fuel Samples:           155
Refusal Rate:             3%
Tampering Rate:          16%
Misfueling Rate:          8%

     The New Jersey survey was conducted,  in conjunction with

a Department of Motor Vehicles'  police pullover, over four days

in the northeastern part of the  state.   On the remaining day,

the survey was conducted at a State inspection station in

Newark.

-------
                             -17-

New York City, New York - Roadside Pullovers

Dates:               June 25-29, 1984 '
Vehicles Surveyed:      308
Fuel Samples:           187
Refusal Rate:             6%
Tampering Rate:          16%
Misfueling Rate:         13%

     The New York City survey was conducted with the help of

the New York Police Department at five different locations in

the borough of Queens.



Boston, Massachusetts - Roadside Pullovers

Dates:               July 9-13, 1984
Vehicles Surveyed:      286
Fuel Samples:           208
Refusal Rate:             5%
Tampering Rate:          15%
Misfueling Rate:          9%

     The Boston survey was conducted with the help of the

Massachusetts Registry of Motor Vehicles Police at five

locations in the greater Boston area.
Tampa, Florida - Roadside Pullovers

Dates:               July 23-27, 1984
Vehicles Surveyed:      327
Fuel Samples:           280
Refusal Rate:             3%
Tampering Rate:          38%
Misfueling Rate:         23%

     The Tampa survey was conducted with the help of the

Florida State Police at five locations in the greater Tampa

area.

-------
                             -18-

St. Louis, Missouri - Roadside Pullovers

Dates:               July 30 - August 3, 1984
Vehicles Surveyed:      314
Fuel Samples:           264
Refusal Rate:            13%
Tampering Rate:          14%
Misfueling Rate:         10%

     The St. Louis survey was conducted with the help of  the

Missouri State Highway Patrol at five locations in the greater

St. Louis area.
Portland, Oregon - Inspection Stations and Roadside Pullovers

Dates:               August 14-24, 1984
Vehicles Surveyed:      394/209?
Fuel Samples:           245/148
Refusal Rate:            3%/0%
Tampering Rate:         10%/4%
Misfueling Rate:         8%/l%

   •  The Portland survey lasted two weeks and was divided

into two parts .  Seven days were used to survey vehicles at

inspection stations in the Portland area (four different

locations).  The remaining two days were used to survey

vehicles by roadside pullover,  with the assistance of state

and local police.


El Paso, Texas - Roadside Pullovers

Dates:               September 10-14,  1984
Vehicles Surveyed:      334
Fuel Samples:           259
Refusal Rate:            6%
Tampering Rate:         30%
Misfueling Rate:        23%
7  Inspection Stations/Roadside  Pullovers

-------
                             -19-

     Th e El Paso survey was conducted with the help of the

El Paso Police Department at five different locations in the

greater El Paso area.  A number of vehicles registered in

Mexico were also surveyed,  but have not been included in El

Paso's rates.



Milwaukee, Wisconsin - Inspection Stations

Dates:               October 1-5, 1984
Vehicles Surveyed:      388
Fuel Samples:           295
Refusal Rate:           26%
Tampering Rate:         11%
Misfueling Rate:         7%

     The Milwaukee survey was conducted at four centralized

I/M stations in the Milwaukee area.  The vehicles were surveyed

at the exit of the inspection station on four days, and at the

entrance to the station on one day.  The refusal rate was

significantly lower when the vehicles were surveyed at the

entrance to the station.

-------
                            -20-

                            RESULTS

A. VEHICLE TAMPERING

1. Site and Aggregate Totals

     The vehicles surveyed have been classified into four

categories established by previous surveys: tampered,

arguably tampered,  malfunctioning,  and okay.   Each vehicle

was classified by the worst state of any component in the

vehicle.  For example,  a vehicle would be classified as

"tampered" if any one component had been tampered, even if

all other components were functioning properly.  A vehicle

classified as "okay" must have all observed components

functioning properly!.   -p^e criteria used for component

classification are presented in Appendix B.

     The proportion of inspected vehicles with at least one

tampered component was 22%.  More than half of the vehicles

surveyed displayed some form of malfunction,  arguable

tampering, or clear tampering of emission control components

The specific distribution of surveyed vehicles among these

categories is depicted in Figure 3.

     The frequency distribution of tampering instances for

those vehicles classified as "tampered" is also shown in

Figure 3.  Nearly half of the tampered vehicles had multiple

components tampered, and 13% had four or more instances of

tampering.
1  An "okay" vehicle,  however,  may still  be classified as
fuel switched (see section B.I.,  Fuel  Switching Indicators
and Overlap of this report).

-------
                 Arguably Tampered
Malfunctioning
                                           Tampered
               Okay
                                                              four or  more  (13%)
                                                              three (10%)

                                                            -two (24%)
                                                                      rone  (53%)
Condition of  Surveyed Vehicles
                                                  Number  of Tampered Components
                     Figure 3.  Breakdown of surveyed  vehicles by
                               condition and extent of  tampering.

-------
                            -22-




     Tables 2 and 3 summarize the 1984 survey data by site.




Table 2 is a general survey summary,  while Table 3 shows




the vehicle condition classification by site.  Unlike the




1983 survey, the overall tampering rates in 1984 vary




considerably from site to site.   This can be attributed to




the variety of I/M-only and I/M  + ATPs covered by this




survey.




     Table 2 also contains the refusal rate at each survey




site.  While the overall refusal rate for the survey was




relatively low (8%), five survey sites had refusal rates




exceeding 10%.  The actual tampering rates at these sites




were probably higher than is reported here,  since individuals




who tamper with or misfuel their vehicles are less likely




to allow their vehicles to be .surveyed.






2.  Tampering Trends 1978-1984






     Table 4 shows the overall rates  found in each of the




past five surveys.  The percentage of okay vehicles in




1984 (46%) is higher than in any previous survey.  It also




appears that the tampering rate  has declined to 22% from




the 26% rate found in 1983.   Such direct comparisons between




survey years, however, are not entirely appropriate.  The




surveys, for example,  covered different sites,  and had




different age and car/truck distributions.  More importantly,




because of the 1984 survey's specific goals,  it greatly




overrepresents the percentage of the  national vehicle




fleet under I/M + ATP (see Table 5).   I/M +  ATP areas

-------
                                 -23-
                              TABLE  2

                    1984 Tampering  Survey  Summary
Survey Number of
Location Vehicles
Bakersfield, CA
Reno, NV
Dallas, TX
Birmingham, AL
Washington, DC
Cincinnati, OH
New Jersey
New York, NY
Boston, MA
Tampa , FL
St. Louis, MO
Portland, OR***
Portland, OR
El Paso, TX
Milwaukee, WI
320
83
268
300
300
325
270
308
286
327
314
394
209
334
388
Tampering
Rate (%)
31
31
28
32
23
28
16
16
15
38
14
10
4
30
11
Misfueling Survey
Rate (%) Type*
14
22
18
25
10
12
8
13
9
23
10
8
1
23
7
R
D
R
R
C
R
R, C**
R
R
R
R
C
R
R
C
Refusal
Rate (%)
2
6
29
4
12
12
3
6
5
3
13
3
0
6
26
TOTAL
4,426
22
14
  *R = roadside pullovers, C  =  centralized  I/M  stations,
   D = decentralized I/M stations
 **four days  roadside, one day  centralized  I/M  station
***
   survey was conducted for two weeks  in Portland

-------
                               -24-
                             TABLE 3

        Classification of Vehicle Condition by Survey Site


                  Tampered    Arguably     Malfunctioning   Okay
Survey Site
Bakersfield, CA
Reno, NV
Dallas, TX*
Birmingham, AL
Washington, DC
Cincinnati, OH
New Jersey
New York, NY
Boston, MA
Tampa , FL
St. Louis, MO
Portland, OR**
Portland, OR***
El Paso, TX
Milwaukee, WI
(%)
31
31
28
32
23
28
16
16
15
38
14
10
4
30
11
Tampered (%")
11
18
26
20
34
22
23
25
19
35
25
47
33
31
43
(%)
3
0
7
6
5
6
3
3
12
1
6
2
2
1
2
(%)
54
51
39
41
37
44
59
56
54
26
56
40
61
37
45
OVERALL              22           29                4          46
  *The rates do not total  100%  for some sites because of rounding
 **I/M Stations
***Roadside Pullovers

-------
                            -25-
                           TABLE 4

          Trends  in Vehicle Condition Classification
Survey
Year
1978
1979
1981*
1982
1983
1984
Tampered
(%)
19
18
14
17
25
22
Arguably
Tampered(%)
48
47
45
38
30
29
Ma If unct ioning
(%)
2
2
3
1
3
4
Okay
(%)
31
33
38
44
42
46
 *Because the 1981  survey involved only two sites  and a very
  limited sample  size,  these  results  may exhibit more variance
  than the other  larger surveys.
                           TABLE  5

    Comparison of  1984  Survey  Sample to Actual  Nationwide
                        Vehicle Fleet
    Program
     Type

    non-I/M

    I/M only

    I/M + ATP
Percentage within    Approx. Percentage of
Survey Sample (%)    Nationwide Fleet (%)**
       42

       31

       27
66

27

 7
**  Based on 1980  population  data from the U.S.  Census  Bureau,

-------
                             -26-






comprised 27% of the survey sample  (half of which came from



Portland alone), while only approximately 7% of the national



vehicle fleet were under such programs.   Since vehicles in



I/M and I/M + ATP areas traditionally have lower tampering



rates, the 1984 survey probably underestimates the extent of



tampering nationwide.




     This discrepancy can be compensated for by applying a




weighting factor to the tampering rates  found under each




program type.  This causes the  overall 1984 tampering rate



to increase from 22% to 26%. Applying weighting factors to



all the previous surveys would  be difficult,  since some




surveys contained no I/M areas.  For the sake of clarity,



only the actual, unweighted rates found  during the surveys



will be reported.  Useful comparisons, however, can still




be made between program types within a given year (e.g., I/M



vs. non-I/M) or between the same program type in different



years (e.g., non-I/M in 1983 and 1984).






3.  Types of Tampering






     The tampering rates for specific emission control




components and systems for the  various survey years are



presented in Table 6.  The component-specific tampering




rates for the 1984 survey are presented  by survey site in

-------
                            -27-
                         TABLE 6

   Prevalence of Tampering by Component, and Survey Year


                                 Survey Year
Component /System
Catalytic Converter
Filler Neck
Restrictor
Air Pump System
Air Pump Belt
Air Pump/Valve
Aspirator**
PCV System
Evaporative
Control System
EGR System
EGR Control Valve
EGR Sensor
Heated Air Intake
Vacuum Spark
1978
1%
3

7
6
3
***
3
3
13
12
5
1
11
1979
1%
4

5
4
2
2
3
2
10
5
7
1
2
1981*
4%
6

4
4
4
0
2
2
5
5
5
0
1
1982
4%
6

5
5
4
1
3
2
10
7
7
1
0
1983
7%
7

7
7
3
1
5
5
13
9
12
1
1
1984
7%
10

7
7
4
1
2
3
. 10
7
6
1
5
  Retard

  Idle Stop             1100
  Solenoid
  *The 1981 survey was of limited scope,  covering only two
   sites and 399 vehicles.

 **Vehicles with aspirated air systems are not equipped with
   other listed air-injection components, nor do conventional
   systems include aspirators.

***Aspirators were not checked during the 1978 survey.

-------
                             -28-






Table 7.  The arguable tampering percentages by component



for the 1978-1984 surveys are presented in Table 8.  Only



those vehicles originally equipped with a particular



component are considered when computing the tampering or



arguable tampering rate for that component.  The heated



air intake was the only component that could be classified



as either tampered or arguably tampered,  based on its



condition in a surveyed vehicle (see Appendix B).



     Table 6 shows that tampering with the filler inlet




restrictor and vacuum spark retard has increased since the



1983 survey.  Tampering rates for other components have



remained unchanged or have declined since the 1983 survey,




but have generally remained higher than the rates found in



1982 and earlier surveys.  As was mentioned previously,



the 1984 data underestimates the nationwide tampering




rates because of the overrepresentation of I/M •+• ATP



areas in the survey.



     Table 7 shows the wide variation in tampering rates




for any given component from site to site.  Inlet restrictor




tampering, for example,  ranged from 1% in Portland (roadside



check) to 19% in Birmingham.  This range is partly due to




the effectiveness of I/M and antitampering programs,  as



will be investigated later in this report.

-------
                                              TABLE  7


           Cortponent-Specific Tarrpering Rates  (percent) by Survey Location - 1984 Survey




                                Emission Control Component or System
Survey
Location
Bakersfield, CA
Reno, NV
Dallas, TX
Birmingham, AL
Washington, DC
Cincinnati, OH
New Jersey
New York, NY
Boston, MA
Tampa, FL
St. Louis, MO
Portland, OR*
Portland, OR**
El Paso, TX
Milwaukee, WI
OVERALL
Catalytic
Converter
. 8
13
10
16
1
8
5
4
3
13
5
2
1
11
2
7
Inlet
Restrictor
11
15
12
19
9
8
5
2
5
17
7
6
1
17
5
10
Air Purrp
System
10
12
8
14
7
8
3
6
4
14
5
1
0
16
3
7
PCV
System
3
4
5
1
1
3
1
0
2
1
1
1
0
7
1
2
EGR Evaporative
System System
18
20
9
14
14
17
11
10
4
17
4
3
2
11
3
10
4
6
5
5
1
3
1
1
3
6
1
1
0
5
1
3
Any
Component
31
31
28
32
23
28
16
16
15
38
14
10
4
30
11
22
                                                                                                           I
                                                                                                           NJ
 *I/M Stations
**Roadside Pullovers

-------
                     -30-
                   TABLE 8

Prevalence of Arguable Tampering by Component
               and Survey Year
Survey
Year
1978
1979
1981
1982
1983
1984
Limiter
Cap
65%
62
83
54
54
49
Fuel Tank
Cap
0%
1
1
2
3
1
Tank
Label
5%
4
4
4
9
12
Dash
Label
1%
1
0
1
1
3
Heated Air
Intake
9%
8
9
6
14
8







-------
                             -31-
     Table 8 shows that idle limiter caps remain the item



arguably tampered most frequently  (49%).  The arguable



tampering rate for limiter caps, however, was lower in




1984 than in any previous survey.  The tank label and dash



label were removed more in 1984 than in previous surveys,




and the heated air intake showed a lower but still significant



arguable tampering rate.






4.   Vehicle Characteristics and Tampering




     The next section of this report investigates the impact



on tampering of three vehicle characteristics: type (car



or truck), age, and manufacturer.



     Vehicle Type.  The tampering prevalence for light duty




trucks was higher than for automobiles, as was mentioned



previously (Table 1).  The tampering rate for each emissions




component on trucks was equal to or greater than on passenger




cars, continuing the pattern observed in previous surveys.



The catalytic converter tampering rate for trucks was nearly



three times that for automobiles (14% vs. 5%).  The fuel



switching rate for trucks (19%) was also considerably higher



than for automobiles (13%).




     Vehicle Age.  Table 9 correlates vehicle age and model



year with tampering prevalence for the 1978-1984 surveys.



Catalytic converter removal rates are similarly related to



vehicle age and model year in Table 10.  The results from



any given survey are entered diagonally in each table.

-------
                                                TABLE 9


             Tampering Percentage (and Sample Size) by Model Year and Vehicle Age at Time of Survey
Model
Year
First
Second
 Third
Fourth
                                              Year of Vehicle Life
 Fifth    Sixth    Seventh   Eighth
                              Ninth
                              Tenth
1984


1983


1982


1981


1980


1979


1978


1977


1976


1975


1974


1973
1(462)


7(182)


1(250)


2(57)





6(371)


7(298)
 4(471)


 4(226)


 7(448)


 5(63)





14(502)


10(457)
 7(466)


13(206)


 9(454)


 9(59)





15(476)


18(395)
15(458)


15(211)


18(477)


15(79)





19(374)


22(274)
18(516)


31(288)


21(430)


21(66)





22(271)


33(276)
28(503)


39(238)


26(316)


29(52)





27(242)


32(253)
34(559)


44(190)


26(317)


32(22)





36(251)
                                                                     41(408)


                                                                     40(171)


                                                                     37(183)
                                                                      39(385)


                                                                      55(89)   46(197)
                                                    OJ
                                                    to
                                                     I

-------
                                                  TABLE 10

                              Percentage of Catalyst Removal (and Sample Size)
              among Catalyst-equipped Vehicles by Model Year and Vehicle Age at Time of Survey
MDdel
Year
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
First
0(462)*
1(179)
0(250)
0(57)

0(326)
0(291)



Second

2(471)
1(225)
2(441)
2(61)

0(445)
1(417)


Third


2(465)
5(204)
2(428)
4(55)

1(417)
2(377)

Year of Vehicle Life
Fourth Fifth Sixth Seventh Eighth Ninth Tenth



6(457)
3(200) 6(487)
6(429) 12(252) 10(455)
0(71) 4(362) 8(213) 8(486)
2(59) 2(271) 11(166) 14(357)
2(305) 10(48) 6(257) 12(139) 12(314)
2(242) 2(204) 26(19) 12(139) 23(75) 16(174)
*Tampering rates have been rounded to the nearest whole percent.   A zero does not necessarily indicate
 a total absence of tampering,  but rather a level of tampering that rounded to zero.

-------
                             -34-
Th e results in Tables 9 and.1O indicate that vehicle tampering



rates increase directly with vehicle age.  Examining Table



9 diagonally (by survey)  shows a fairly linear increase in



the tampering rate with vehicle age for each survey.  In



the 1984 survey, for example,  the tampering rate increases




from 1% for first year vehicles to 46% among the 1975



vehicles surveyed.  Table 10  shows a similar,  though less




pronounced, increase in catalyst removal.  Examining these




tables in this manner has the  advantage of comparing data



collected during one survey in one set of locations, but



ignores the possible effects  of model year differences



(i.e., technology) on tampering.



     Two additional ways  of analyzing Tables 9 and 10 address



the impact of model year  on tampering rates.  Analyzing the



tables horizontally (holding  the model year constant)



provides a look at the tampering rates over time for the




vehicles of a particular  model year.  This approach shows



the same distinct increase in tampering with vehicle age



for all model years since 1975.   (The 1974 and 1973 data




sets are too small to permit any conclusions.)  For example,



the tampering incidence for 1979 vehicles increased from 6%



in their first year to 28% by their sixth year of use.




This increase in tampering with vehicle age also seems to




lessen once the vehicles  of a model year are five years old



or more, with.the tampering rates leveling off at higher

-------
                             -35-
levels in older model years. -This type of analysis involves



observations made from different survey sites at different




times; nevertheless/ the relationship between tampering rate



and vehicle age is readily apparent.




     Tables 9 and 10 can also be analyzed vertically (holding



vehicle age constant), which provides a look at the tampering




rates for different model year vehicles of the same age.




This approach suggests that improvements in automotive



technology, such as closed loop emission control systems,



have not significantly affected overall tampering rates.




A 1983 vehicle,  for example, was as tamper-prone as a



1978 vehicle when both were new (first year of use).  A



similar vertical analysis of Table 10 shows that catalytic



converters are as susceptible to tampering on new vehicles



as on older ones at a given vehicle age.  Analyzing Tables 9



and 10 vertically introduces the same variability as the



horizontal analysis, which might obscure any slight decrease



in tampering resulting from improved technology.



     The influence of vehicle age on tampering can



be more clearly seen when the data in Tables 9 and 10 is



presented graphically.  Figures 4 and 5 plot the overall



and catalyst tampering rate, respectively, as a function of




vehicle age for the 1978-1984 surveys.  This is equivalent



to the diagonal method of analysis used for Tables 9 and 10



that was outlined previously.  Figure 4 demonstrates that

-------
60
50 -
40 -
30 -
20 -
10 -
 0
Rate (%) S

0
-
0 *
• ° i * *
8 X
0 D
a £
DN^ "A*
1 [ *«T»S
o 8 *
© a $
£ , 	
urvey Year
1984
*
1983
O
1982
a
1981
A
1979
O
1978
a

31 23456789 10 11
                         Vehicle Age  (years)

               Figure  4.  Cumulative tampering prevalence as  a
                         function of vehicle age for the
                         1978 -  1984 surveys.
                                                                                      I
                                                                                      OJ

-------
60
50 -
40 -
30 -
20 -
10 -
 0
RatQ (%) S
•
-
•
-
.
_
A
0
• *
0 A 0 Q *
Q >l<
urvey Year
1984
*
1983
0
1982
D
1981
A
1979
O
1978
D
] 1 2 3 4 5 6 7 89 10 11
                         Vohiclg Ago  (ygars)

              Figure 5.   Cumulative  catalyst tampering rate as
                         a function  of  vehicle age for the
                         1978 - 1984 surveys.
i
co

-------
                             -38-
the relationship between tampering rate and vehicle age is



not only linear, but has remained nearly constant since the



first survey in 1978.  The strong correlation is obvious




despite the different sizes,  vehicle compositions, and



locations of the surveys.   In Figure 5 the catalyst tampering



rate remains negligible for the first two to three years




of a vehicle's life, and then increases thereafter.



This delay in catalyst tampering is understandable, since



the catalytic converters on all new vehicles are warranted




for 5 years/50,000 miles by the manufacturer, providing an



incentive to maintain the catalysts on vehicles still



under warranty.



     If the relationship between vehicle age and tampering



has not changed markedly,  what accounts for the general



increase in overall tampering from earlier surveys?  Figure



6 charts both the overall and catalyst tampering rate and



compares these to the proportion of surveyed vehicles five




years old or more in each survey.  Figure 6 shows that the




proportion of older vehicles  surveyed has increased steadily



from 27% in 1978 to 58% in the 1984 survey sample.  Since




the 1981-1984 surveys covered 1975 and newer vehicles,  each




successive survey reflects the increasing age of the



catalyst-equipped vehicle population.   (The 1981 survey




covered vehicles up to seven years old, while the 1984




survey included vehicles up to ten years old.)

-------
Percent
  60
  50
  40
  30
  20
  10
5-Year Old or More
 Vehicles Surveyed
         o

  Tampering Rate
                                                                  Catalyst Tampering  i
                                                                         Rate
                                                                                      u>
                                                                                      VO
      1978      1979     1980     1981      1982      1983     1984

                             Survey Year

                 Figure 6.   Comparison of catalyst and  overall
                            tampering rates with vehicle  age as
                            a function of survey year.

-------
                            -40-




The increase in the proportion of older vehicles surveyed



coincides with increases  in the overall and catalyst tampering



rate.  Thus, the vehicles comprising the survey sample are



older in each successive  survey,  and as such are more



likely to have been tampered with,  causing the overall



tampering rate to increase.






Manufacturer.  Figure 7 presents the 1984 tampering rates



for each major manufacturer.  Since the number of vehicles



surveyed for each individual foreign manufacturer is small,




foreign vehicles have been combined into two groups, European



and Japanese.  As in previous surveys,  the tampering rate



is higher among domestic  than foreign manufacturers.



     Figure 8 shows the trend in tampering rates for each




manufacturer over time.  The American vehicles are at or



consistently above the overall tampering rate, while the




European and Japanese vehicles have a tampering incidence



consistently lower than the overall rate.



     A number of factors  might explain the discrepancy in




tampering rates among manufacturers.  Differences in design



may make some vehicles more tamper-prone than others.




Changing market share history results in different age




distributions for vehicles of different makes, and vehicle




age is clearly related to tampering prevalence.  Tampering




rates probably vary with  geographic location and socioeconomic

-------
                         -41-
       American Motors
       General  Motors
                      9%
TampQring RatQ (%)
     Figure 7.   Tampering rates by manufacturer
                          1984 survey.

-------
Tamponing Rato  ("A
        40
        30  -
        20  -
         10 -
         0
                                     Manufacturor
                       Figure  8.  TampQring prevalence by manufacturer
                                 for the 1978 -  1984 surveys.

-------
                             -43-
background, so the owner demographics for different makes

may affect the likelihood of tampering.  Finally, certain

types of vehicles (trucks,; for instance) are more likely
                          i
to be tampered, and thus manufacturers with production

concentrated in these types can be expected to have higher

tampering rates.


5.  Effect of I/M Programs on Tampering

     Inspection and maintenance (I/M) programs require

vehicles to meet specific idle emission standards.  Vehicles

registered in these areas are required to be periodically

tested to assure that they comply with the specific idle

emission cutpoints established by these jurisdictions.  In

addition to reducing emission levels by stimulating better

owner maintenance, I/M programs may deter some tampering

with emission control components.   Data from previous surveys

has tended to support this proposition, since tampering in

I/M areas has been lower than in non-I/M areas.

     Some I/M areas have also instituted antitampering

programs (ATPs), which involve periodic vehicle inspections

to check the integrity of specific emission control components.

Antitampering programs vary greatly in the components inspect-

ed and the vehicle model years covered, so that a vehicle which

would be inspected in one program area might not be inspected

in a different program area.  Successful antitampering programs

-------
                            -44-




should directly deter tampering with the components and



model years covered by the program,  and may have an indirect



deterrent effect on the rest of the  vehicle population.



     The 1984 survey encompassed six non-I/M areas, five



I/M-only areas, and three I/M + ATP  areas.   The proportion




of the survey sample covered under each program type was



discussed earlier (Table 5).



     Table 11 compares the tampering rates  in non-I/M,




I/M-only, and I/M + ATP areas.   The  tampering rates in



non-I/M areas were significantly higher than the rates in




I/M-only areas, which were in turn higher than the rates



in I/M + ATP areas.   This is the same relationship found



in previous surveys, although the degree of program



effectiveness in 1984 exceeds that of earlier surveys.



Table 11 also shows that the tampering rate in non-I/M



areas has increased by over 50% since the first survey in



1978.



     The component-specific tampering rates for cars and



trucks in each program area are presented in Table 12.  The




tampering rates in non-I/M areas were greater than in I/M-only




areas for every component in both cars and  trucks.  Except




for the PCV system in trucks,  the I/M-only  rates exceeded



the I/M + ATP rates in every case as well.   It should be




noted that certain I/M areas have weight limits that exclude




some light-duty trucks from their programs.

-------
                              -45-
                            TABLE 11

         Tampering Prevalence in I/M and non-I/M Areas
Survey
Year
1978
1979
1981*
1982
1983
1984
non-I/M
19
20
14
19
29
31
Tampering
I/M-only
NS
13
NS
15
24
17
Rate ( % )
I/M + ATP
NS
NS
NS
10
16
11
Overall
19
18
14
17
26
22
NS = None Surveyed

*1981 survey was of limited scope, covering only two sites and
 399 vehicles

-------
                                    TABLE 12


Tanpering and Fuel Switdiing Prevalence by Vehicle Type in I/M and non-I/M Areas
      non-I/M Areas
I/M-only Areas
I/M + ATP Areas
Overall
Tanpering
Category
At least one
component
tampered
Catalytic
Converter
Inlet Restrictor
Air Pump
System
Evaporative
Control System
PCV System
EGR System
Fuel Switched
cars(%)

31
9
14
11
4
3
15
19
trucks(%)

33
18
17
14
6
5
13
25
cars(%)

16
3
6
4
1
1
9
10
trucks (%)

25
11
9
11
3
1
13
16
cars(%)
11
3
5
2
1
1
3
8
trucks(%)

14
5
8
6
2
2
2
9
cars(%)

21
5
9
7
2
2
10
13
trucks(%)

27
14
14
12
5
3
10
19
                                                                                                0%
                                                                                                 I

-------
                             -47-
       The effect of I/M programs on catalyst tampering is



investigated more thoroughly in Table 13, where catalyst



tampering rates in each program area are presented for each



vehicle model year and vehicle type.  The same trend in



program effectiveness is evident for cars and trucks of a



specific model year.  The small sample sizes for some model



years and vehicle types, however, prevent some comparisons



from being made.  For example, the truck rates by model



year in I/M-only and I/M + ATP areas are based on very small



sample sizes.  These rates have been included in Table 13



for the sake of completeness and should not be considered



meaningful.  Table 13 also shows the strong relationship



between vehicle age and catalyst tampering in cars and trucks,



particularly in non-I/M areas and in the overall database.



6.   Effect of Antitampering Programs on Tampering



     The impact of antitampering programs on tampering rates



is presented in Table 14, which compares the tampering rates



for components checked in the three I/M + ATP areas surveyed.



Boston, whose yearly inspection program covers filler neck



restrictors and catalysts on 1980 and later vehicles, had



very high tampering rates for these components on 1980 and



1981 model year vehicles.  Boston's program had been in effect



over a year at the time of the survey.  St. Louis had



significant tampering rates for a number of components on



1981 and 1982 model year vehicles.  St. Louis' yearly

-------
                                                  TABLE 13

      Catalytic Converter Tanpering Prevalence* by Vehicle Type in I/M and non-I/M Areas - 1984 Survey
                       non-I/M Areas
I/M only Areas
Automobiles
Model
Year
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
Number
Surveyed
77
150
167
222
111
158
145
147
138
130
Tampering
Rate(%)
23
16
21
11
10
8
6
1
1
0
Light-Duty Trucks
Number
Surveyed
5
13
16
16
42
50
43
55
66
56
Tanpering
Rate(%)
100
50
50
33
39
23
21
7
6
2
Automobiles
Number
Surveyed
70
114
129
155
132
135
139
111
115
108
Tanpering
Rate(%)
5
9
7
2
4
2
1
0
0
0
Light-Duty Trucks
Number
Surveyed
7
4
4
8
24
19
15
14
24
22
Tanpering
Rate(%)
20
0
i
0 co
43
17
0
21
7
8
0
* Many Light-Duty Trucks manufactured between 1975-79 were not originally equipped with catalysts,
  and thus were excluded from this table.

-------
                                          TABLE 13  (cont'd)




Catalytic Converter Tanpering Prevalence by Vehicle Type in  I/M and non-I/M Areas - 1984 Survey
                  I/M + ATP Areas
Overall
Automobiles
Model
Year
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
Nunber
Surveyed
34
99
87
148
114
127
110
119
107
113
Tanpering
Rate(%)
10
1
8
7
1
3
3
0
0
0
Light-Duty Trucks
Nunber
Surveyed
4
5
5
10
14
27
6
20
21
33
Tanpering '
Rate(%)
0
0
0
0
29
4
0
5
0
0
Automobiles
Nunber
Surveyed
181
363
383
525
423
420
394
377
360
351
Tanpering
Rate(%)
14
10
13
7
6
4
4
1
1
0
Light-Duty Trucks
Nunber
Surveyed
16
22
25
34
80
96
64
89
111
111
Tanpering
Rate(%)
50
35
38
32
30
14
19
7
5
1

-------
                                     -50-
                                   TABLE 14
Tampering Rates (percent)  for Cenponents Checked in I/M + ATP Areas  -  1984 Survey
                        Component
       Survey Site      or System
       Model Year
1980  1981  1982  1983  1984
Boston, MA Filler Neck
Restrictor
Catalyst
Filler Neck
or Catalyst
Portland, OR PCV System
Air System
EGR System
Catalyst
Filler Neck
Restrictor
Filler Neck
or Catalyst
Any of Above
St. Louis, MO PCV System
Air System
EGR System
Catalyst
Any of Above

11
7

15
0
0
1
1

0

1
2
*
*
*
*
*

7
2

10
0
0
0
0

0

0
0
0
3
0
5
7

3
0

3
1
0
0
0

0

0
1
3
5
4
3
3

0
0

0
0
0
0
0

0

0
0
0
0
0
0
0

0
0

0
0
0
0
0

0

0
0
0
0
0
0
0
   *0omponent/model year not covered by antitampering program.

-------
                             -51-




program, however, had only been implemented seven months prior




to the survey.  Portland's antitampering program appears to



be the most effective, with negligible tampering rates for all



components covered by the program.






7.  Effectiveness of I/M-only vs. I/M + ATP



     Figures 9(a) and (b) compare the effectiveness of I/M-only



programs and I/M + ATP in preventing tampering.  Tampering



rates for Portland and New Jersey have been selected since




these sites represent long-standing I/M + ATP and I/M-only



programs, respectively.  New Jersey instituted its I/M program



in February, 1974, and Portland's I/M + ATP program began in



July, 1975.  Additionally, these are the only two 1984 survey



sites that had been surveyed in previous years.  Figure 9(a)



shows that Portland's I/M + ATP has reduced overall tampering



and EGR tampering between 1982 and 1984 while AIR system and



catalyst tampering have remained very low.  Over the same



period of time New Jersey's I/M-only program has had no



impact on overall tampering rates, and over the past five



years the tampering rates for catalyst, AIR, and EGR systems




have all increased markedly.



     Half of the catalyst removals found in Portland in 1984



were from out-of-state vehicles not previously subjected to




the local inspection program.  In contrast, all of the vehicles



with missing catalysts in New Jersey were in-state vehicles

-------
                                           -52-
Tampering Rata (2)
       20
        18

        16

        14

        12

        10

        8

        6

        4

        2

        0
 102
                    22
               oz
                                   12
        102
                   Overall        Catalyst       AIR System
                                    a)  Portland. OR
                         [   |
                                                                1984
                                          EGR System
Tampering Rata (2)
       20
        18

        16

        14

        12

        10

        8

        6

        4

        2

        0
   162 162
112
                     52
                  32
              02
32
                            12  12
                   Overall        Catalyst       AIR System     EGR System
                                     b) Now  Jersey
                  Figures 9(a) and (b).   Comparison of data from
                                 1984 survey sites that  had been
                                 surveyed  previously.
                             1979

                             1982

                             1984

-------
                             -53-

subject to the state's I/M program.  The difference in EGR

tampering rates for the two sites in also noteworthy because

EGR reduces NOX emissions, a pollutant not checked by idle

emissions testing.  These results suggest that I/M-only

programs are not as effective as I/M + ATP in reducing

tampering rates, and that many tampered vehicles are appar-

ently able to pass an idle emissions test undetected.


8. I/M Programs and Geographic Bias

     Determining the impact of I/M and I/M + ATP programs on

tampering and misfueling may be complicated by a possible

geographic bias in the survey data.  The 1984 survey sites

are listed below by program type.


   Non-I/M          '    I/M-Only            I/M + ATP

Bakersfield, CA         Reno,  NV            Boston, MA
Dallas, TX              Washington, DC      St. Louis, MO
Birmingham, AL          New Jersey          Portland, OR
Cincinnati, OH          New York, NY
Tampa, PL               Milwaukee,  WI
El Paso, TX

     It is apparent that the geographic regions of the U.S.

are not equally represented in each program type.  The northern

states are disproportionately represented in the I/M areas,

while only one northern non-I/M site (Cincinnati) was surveyed.

Similarly, no southern I/M sites were surveyed, while four

southern non-I/M sites (Dallas, Birmingham, Tampa, and El

Paso) were included.  Also four of the northern survey areas

(Boston, New York City, New Jersey, and Washington) are

concentrated within 500 miles of each other.

-------
                             -54-
     The southern states  appear to have higher tampering



rates than the northern states, which would increase the



discrepancy between the I/M and non-I/M tampering rates as



surveyed.  In comparing the data from non-I/M sites in



Table 7, the component-specific tampering rates in Cincinnati



are lower than in the four southern cities surveyed for every



component except the PCV  and EGR systems.   Cincinnati also



has a much lower misfueling rate (Table 2).  The possibility



of a geographic influence cannot be further investigated



readily using the 1984 survey data, but it may influence



site selection in future  surveys.



9.  Correlation between Tampering and Idle Emissions



     As was mentioned previously,  vehicles which are subject



to an I/M program must meet specific idle emissions cutpoints.



To assess the relationship between tampering and fuel switch-



ing and idle failure rates, the idle emissions from vehicles



have been tested against  the cutpoints established by the



I/M program where they were sampled.  Vehicles in non-I/M



areas were tested against the cutpoints specified by the New



Jersey I/M program.  The  cutpoints for each I/M area are



listed in Appendix C.



     The results of the idle tests are presented in Figure 10



for vehicles in the various tampering and fuel switching



categories.  Only 10% of  the survey vehicles free of tampering



and fuel switching failed an idle test, while 60% of the

-------
                             FigurQ 10
       Distribution of SurvQy Sample Among Tampering*.
           Fuel  Switching, and Idle  Test Categories
                            EntirQ  survGy
                               sample
                              ,  100%
           Okay
            46%
Arguably
tampgred
   29%
Tamponed
  22%
U1
01
I
*excludes malfunctioning vehicles  (4% of total)

-------
                             -56-



tampered and fuel switched vehicles failed that test.  These



results indicate that a substantially larger proportion of



tampered and fuel switched vehicles than of okay vehicles



fail an idle test at typical  I/M cutpoints.   This is partly



due to the tendency for tampered vehicles to have misadjusted



carburetors, as is shown in Figure 11.   This Venn diagram



shows that 71% of the tampered vehicles with conventional



carburetors also had missing  sealed plugs or limiter caps.



It must be noted from Figure  10,  however, that 40% of these



tampered and misfueled vehicles were still able to pass the



idle test.



     Table 15 shows the percentage of vehicles that failed



the idle emissions test for each vehicle condition.  Over one-



third of the tampered vehicles failed the idle emissions test



for either HC or CO, while only 7% of the okay vehicles



exceeded limits for HC or CO.   Over one-third of the vehicles



that either had been fuel switched or had their catalysts



removed also exceeded HC and  CO limits.   Conversely, nearly



two-thirds of the vehicles with inoperative or missing



catalysts were still able to  pass an idle emissions test.



Interestingly, a significant  number of arguably tampered



vehicles also produced excess idle emissions.   Since the



majority of arguable tampering involves idle speed limiter



caps, the high failure rate demonstrates the adverse idle



emissions impact of improperly adjusted carburetors.

-------
                                          -57-
Carbureted Vehicles
have been tampered
(924 total)
that
Carbureted Vehicles
with Arguably
Tampered Carburetors
  (1729 total)
     Figure 11.  Overlap of Tampering and carburetor misadjustment  among  conventionally
                 carbureted vehicles - 1984  Survey.

-------
                         -58-
                       TABLE 15

   Idle Test Failure Rates (percent)  by Pollutant
               and Vehicle Condition
                  Vehicle Condition

Pollutant Okay
HC 7
CO 7
Arguably
Tampered Tampered
38 23
36 26
Cat. Removed/
Misfueled
40
35
                       TABLE 16

       Mean Idle Emissions  by Vehicle Condition
Survey           HC emissions(ppm)     CO emissions(%)
Sites            Tampered    Okay     Tampered  Okay
non-I/M           430.0      65.6       3.0      0.4

I/M only          287.2      60.1       2.4      0.4

I/M + ATP         323.4      60.4       2.1      0.3

OVERALL           381.7      62.3       2.7      0.4

-------
                             -59-




     The mean idle emissions for tampered and okay vehicles



are presented in Table 16 by program type.  The mean idle




emissions from tampered vehicles were considerably higher




than from okay vehicles.  Overall HC emissions were 513%



higher, while overall CO emissions were 575% higher.  The



means for non-I/M areas were higher than for I/M-only and




I/M + ATP areas.



     To investigate the impact of I/M programs on idle



emissions, the emissions from okay and tampered vehicles in




each program type can be compared.  The data indicates that



idle HC emissions from okay vehicles in I/M areas were only



8% lower than from vehicles in non-I/M areas, and that the




idle CO emissions were not affected by I/M programs.  Anti-



tampering programs had no additional impact on idle HC and



CO emissions of okay vehicles (Table 16).  These findings



agree with Table 15, which shows that nearly all okay vehicles



would pass the idle emissions test.  Idle HC and CO emissions



from tampered vehicles, however, were 33% and 20% lower,



respectively, in I/M-only area than in non-I/M areas, suggest-



ing that idle emissions may be reduced from vehicles for



which tampering is not successfully deterred.  It should be




noted that a vehicle's idle emissions are only loosely related



to its emissions under normal driving conditions.

-------
                             -60-



B. FUEL SWITCHING



1.  Fuel Switching Indicators and Overlap





     Fuel switching is more  easily  defined  than  measured,



since no single indicator can accurately determine its



prevalence.  Since 1981 the  surveys have used  a  combination



of three indicators to measure fuel switching  more accurately:



a tampered fuel filler inlet restrictor, a  positive Plumbtesmo.



test for lead deposits in the tailpipe, and a  gasoline lead



concentration of more than 0.05 grams  per gallon (gpg).  Of



these three indicators, only a tampered inlet  restrictor is



also considered tampering, and as such is used to calculate



both tampering and fuel switching rates.  Since  false  positive



indications should be extremely rare for these measures,  the



percentage of vehicles with  at least one positive indicator



is a reasonable minimum estimate of fuel switching.



     The presence of any of  these three indicators suggests



that a given vehicle has been misfueled; their absence,  how-



ever, does not rule it out.   For example, fuel samples could



only be obtained from 70% of the unleaded vehicles surveyed,



limiting the scope of this variable.   A vehicle  misfueled



repeatedly with leaded gasoline may also have  little detect-



able lead in its fuel tank due to subsequent proper fueling.



Similarly, a vehicle with an untampered fuel filler inlet



restrictor may have been fueled at  a leaded pump equipped



with a smaller nozzle, or by using  a funnel or similar device.

-------
                             -61-
The tailpipe lead test, due to the difficulties of field



administration, may also fail to identify misfueling, and



older vehicles may have had their tailpipes replaced since



last operated on leaded fuel.  The uncertainty in these



measures, then, is always toward underestimating the number



of vehicles misfueled.



     The limitations of the fuel switching indicators can be



seen in their incomplete overlap.  The results from these



indicators would be expected to overlap significantly,  since



they are three indicators of the same phenomenon.  This has



not held true, however, in the 1984 survey or in previous



surveys.  The Venn diagram (Figure 12) illustrates the degree



of overlap in the 1984 results.  For example, only 73% of



the vehicles having leaded fuel in their tank also registered



a positive Plumbtesmo test.  Additionally, only 35% of the



vehicles with tampered inlet restrictors actually had leaded



gasoline in their tanks at the time of the survey.  The



incomplete overlap reflects the limitations of each indicator



as well as the different aspects of fuel switching each



indicator identifies.





2.  Fuel Switching Rates



     Of the vehicles requiring unleaded fuel, 14% were



identified as misfueled by at least one of the indicators



discussed above.  The fuel switching incidence by survey site



and program type is listed in Table 17.  Since fuel samples

-------
                                        -62-
Positive Plumbtesmo
  (354 Total)
                                                        Leaded Fuel in Tank
                                                            (235 Total)
  Figure 12.
                                                                Tampered Inlet
                                                                Restrictor
                                                                (401 Total)
Overlap of fuel switching  indicators  among unleaded vehicles -
1984 Survey.

-------
                        -63-
                      TABLE 17

Fuel Switching Rates among Unleaded Vehicles by Site
            and Indicator - 1984 Survey
          Leaded     Tampered
Positive
>1 Positive
Survey Fuel in Inlet Plumbtesmo
Location Tank(%) Restrictor (% ) (%)
Bakersfield, CA
Dallas, TX
Birmingham, AL
Cincinnati, OH
Tampa, FL
El Paso, TX
Reno , NV
Washington, DC
New Jersey
New York, NY
Milwaukee, WI
Boston, MA
St. Louis, MO
Portland, OR
ALL NON-I/M SITES
ALL I/M ONLY SITES
ALL I/M+ATP SITES
ALL SITES
3
11
17
7
15
13
17
2
2
14
1
4
7
2
11
5
4
7
Non-I/M Areas
11
12
19
8
17
17
I/M Only Areas
15
9
5
2
5
I/M -I- ATP Areas
5
7
4
14
6
6
10
8
15
21
7
16
16
17
2
6
5
3
2
6
4
14
5
4
8
Indicators
(%)
14
18
25
12
23
23
22
10
8
13
7
9
10
7
19
10
8
14

-------
                             -64-
could not be obtained from all  unleaded vehicles surveyed,



the incidence of leaded fuel in the tank may be higher than



the overall misfueling rate for some survey sites (e.g., New



York).   Non-I/M sites had the highest fuel switching rate



(19%),  followed by I/M-only and I/M + ATP areas.  The preva-



lence of each fuel switching indicator in non-I/M areas was



at least twice that found in I/M-only areas.



     Tables 18 and 19 compare the fuel switching rates from



the 1984 survey with previous surveys.  Table 18 shows that



although the overall fuel switching rate has not changed



appreciably, the rate for non-I/M areas has been increasing



steadily.  Table 19 shows that  inlet restrictor tampering



has increased steadily,  while the prevalence of the ojther



two fuel switching indicators has remained unchanged.



     Table 20 presents the combined tampering and fuel



switching rates for the 1984 survey.  The percentage of



vehicles that were tampered or  fuel switched was 24%,  only



2% higher than the tampering rate alone. . The overlap in the



fuel switching and tampering rates results mainly from the



inlet restrictor tampering rates being used to calculate



both values.

-------
                             -65-
                           TABLE 18

      Fuel Switching Prevalence among Unleaded Vehicles
                   in I/M and non-I/M Areas
Survey
Year
1978
1979
1981**
1982
1983
1984
non-I/M
4*
12*
16
15
17
19
Fuel Switching
I/M only I/M
NS
3*
NS
7
12
10
Rate (%)
+ ATP
NS
NS
NS
2*
5
8
Overall
4*
9*
16
11
14
14
 *Plumbtesmo test not used.
**1981 survey was of limited scope, covering only two sites and
  399 vehicles.
NS:  None surveyed
                           TABLE 19

         Fuel Switching Rates among Unleaded Vehicles
                 by Indicator and Survey Year

Survey  Leaded Fuel  Tampered Inlet  Positive       ^1 Positive
Year    in Tank(%)   Restrictor(%)   Plumbtesmo(%)  Indicators(%)
1978
1979
1981
1982
1983
1984
4
10
7
6
7
8
3
4
6
6
7
10
*
*
8
7
10
9
4
9
16
11
14
14
* No Plumbtesmo test

-------
                             -66-

                                 "i,
                                 i

                           TABLE 20


    Combined Tampering and Fuel Switching Rates - 1984 Survey


                    Catalyst-equipped vehicles   Unleaded vehicles
Survey
Location
Bakersfield, CA
Dallas, TX
Birmingham, AL
Cincinnati , OH
Tampa , FL
El Paso, TX
Reno , NV
Washington, DC
New Jersey
New York, NY
Milwaukee, WI
Boston, MA
St. Louis, MO
Portland, OR
ALL NON-I/M SITES
ALL I/M-ONLY SITES
ALL I/M + ATP SITES
with catalysts removed or
fuel switched (%)
t
Non-I/M Areas
19
22
28
16
26
27
I/M-only Areas
25
13
9
16
8
I/M + ATP Areas
9
12
7
23
12
9
either tampered o
fuel switched (%)
34
31
35
31
42
34
35
25
18
25
12
17
17
10
34
20
13
ALL SITES
16
24

-------
                              -67-
3.  Fuel  Switching by Vehicle Type



     As was  reported previously,  the  fuel  switching  rates  for



trucks was considerably higher than for passenger  cars  - 19%



vs. 13%  (Table  1).  The filler neck restrictor  tampering



rates were also higher for trucks than for passenger cars



(Table 1).



4.  Fuel  Switching and Vehicle Age



     Table 21 correlates  vehicle  age  and model  year  with fuel



switching rates for the 1978-1984 surveys.  This method of



analysis  is  identical to  the one  used earlier to compare



tampering rates across model years and vehicle  ages.  Analyzing



Table 21  diagonally shows that the rate of fuel switching



"increased with  vehicle age .in every survey taken.  The  fuel



switching rate  reached a  maximum  of 20-30% when the  vehicles



were six  or  seven years old.  A similar though  less  pronounced



pattern can  be  seen when  the data is  analyzed within model



years (horizontally) or within vehicle age groups  (vertically).



5.  Catalyst Tampering and Fuel Switching



     Consumers  and mechanics remove catalytic converters for



a number  of  reasons, but  much of  their motivation  is related



to fuel switching.  The vehicle owner may  remove the catalytic



converter either prior to misfueling, or after  some  misfueling



if the vehicle's driveability has been adversely affected  by a



catalyst  damaged from the repeated misfueling.  The  data from

-------
                                                 TABLE 21


Percentage of Fuel Switching (and Sanple Size) among Unleaded Vehicles by Model Year and Vehicle Age

                                             at Time of Survey
Model
Year
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
First
3(462)
5(182)
5(250)
9(57)

6(328)
2(296)



Second

4(471)
6(226)
7(444)
11(62)

8(451)
3(438)


Third


6(465)
9(205)
8(447)
16(55)

9(428)
6(388)

Year of Vehicle Life
Fourth Fifth Sixth Seventh Eighth Ninth Tenth



8(457)
8(210) 11(487)
12(432) 19(269) 18(455)
18(74) 12(377) ' 15(221) 24(486)
18(60) 13(283) 23(176) 27(357)
15(316) 37(49) 14(249) 21(147) 24(314)
6(255) 14(213) 30(20) 17(146) 24(82) 26(174)
                                                                                                               00
                                                                                                               I

-------
                             -69-

this survey cannot be used to distinguish between these two

situations, but can be used to examine the extent to which

these;types of abuse occur in conjunction.
     |
     Of the catalyst-equipped vehicles surveyed, 16% were

either catalyst tampered or fuel switched (Table 20).  The

rates in non-I/M, I/M-only, and I/M + ATP areas were 23%,

12%, and 9%, respectively.

     Figure 13 depicts the degree of overlap between catalyst

removal and fuel switching.  Vehicles with catalyst tampering

exclusive of fuel switching were relatively uncommon — only

one-third of the catalyst tampered vehicles were not fuel

switched.  Fuel switching, however, is not always accompanied

by catalyst removal.  Over two-thirds of the.fuel switched

vehicles still have their catalysts.

6.  Gasoline Lead Concentrations

     Of the vehicles identified by any of the three indicators

as misfueled, 37% had only trace amounts of lead (less than

0.05 gpg) in their gasoline when inspected.   These vehicles,

then, were identified as fuel switched by a tampered filler

restrictor and/or a positive Plumbtesmo test.   Figure 14

presents the distribution of lead concentrations of 0.05 gpg

or more in misfueled vehicles.  This figure shows that 39% of

the misfueled vehicles have a gasoline lead concentration

in excess of 1.0 gpg.  Since the average lead concentration

-------
                               -70-
Catalyst Tampering
  (273 Total)
Fuel Switching
  (566 Total)
  Figure 13.  Overlap of catalyst  tampering and  fuel  switching among
              catalyst-equipped vehicles  - 1984  Survey.

-------
                        -71-
PercQntagQ of Misfuelod Vehicles
      45
      40


      35


      30


      25


      20


      15


      10
       0
          GasolinQ Load  Concentration  (grams/gallon)
            Figure 14.   Lead concentrations in fuel sampled
                       from misfueled vehicles.

-------
                            -72-
in leaded gasoline at the  refinery is  1.1  gpg,  the results



suggest that about 39% of  the misfueled vehicles are habitually



misfueled, as the leaded gasoline  in their tanks showed no



evidence of having been diluted by subsequent tankfuls of



unleaded gas.

-------
                             -73-
                          APPENDIX A


            RELEVANT PORTIONS OF THE CLEAN AIR ACT

Section 203(a)(3):  The following acts and the causing thereof
                    are prohibited —

(A)  for any person to remove or render inoperative any device

or element of design installed on or in a motor vehicle or

motor vehicle engine in compliance with regulations under this

title prior to its sale and delivery to the ultimate purchaser,

or for any manufacturer or dealer knowingly to remove or

render inoperative any such device or element of design after

such sale and delivery to the ultimate purchaser; or


(B)  for any person engaged in the business of repairing,

servicing, selling, leasing, or trading motor vehicles or

motor vehicle engines, or who operates a fleet of motor

vehicles, knowingly to remove or render inoperative any

device or element of design installed on or.in a motor

vehicle or motor vehicle engine in compliance with regulations

under this title following its sale and delivery to the

ultimate purchaser.

-------
                             -74-
                          APPENDIX B






             SURVEY AND DATA RECORDING PROCEDURES



1.   Explanation of Survey Forms




     The forms on the following pages were used for recording



the survey data in the field.  The forms were forced choice to




ensure coding consistency,  and were designed to facilitate



direct data entry.  The following codes were used to record



data for the major system components on the data sheets:



         0 - Not originally equipped



         1 - Functioning properly



         2 - Electrical disconnect



         3 - Vacuum disconnect



         4 - Mechanical disconnect



         5 - Incorrectly routed hose



         6 - Non-stock equipment



         7 - Missing item



         8 - Misadjusted item



         9 - Malfunctioning




         P - Stock equipment



         A - Add on equipment




     Additional codes were used for those components which




could not be classified into the above categories.  A brief




description of each data entry follows.

-------
                                                      SURVEY  - FORM A (Rear)
                12
                      ID NUMBER
                      MAKE
                      MODEL
 "IT
      VEHICLE TYPE (1-Car, 2-Truck)
 14   15
           • LICENSE PLATE (State)
                      HC, PPM
                      CO, %
                                                                     29
                                                                      31T
 32
                                                                      34
        TANK  CAP  (1,  7,  9)
        TANK LABEL (0,  1,  7)
        FUEL INLET RESTRICTOR (0,  1,  4,  7)
        CAT (0,  1, 7,  9)
        EXHAUST SYSTEM (P-stock, N-non)
        EXHAUST INTEGRITY (1,  9)
        FUEL SAMPLE (Y, N)
                                         Ol
                                         I
 24
       PLUMBTESMO (Positive, Negative)
 2$        27
                 ODOMETER READING,  Thousand
 28

3/84
       DASH LABEL (0, 1, 7)
0 - Not Original Equipped
1 - Functioning Properly
2 - Electrical Disconnect
3 - Vacuum Disconnect
4 - Mechanical Disconnect
5 - Incorrectly Routed Hose
6 - Non-Stock
7 - Missing Item
8 - Misadjusted Item
9 - Malfunctioning

-------
                                         NATIONAL  SURVEY  - FORM B (Underhood)
                       ID NUMBER
        EGR VALVE (0,  1, 3. 7, 9)
        EGR SENSOI (0, 1, 3, 5,  7,  9)  (CTO-Transducers-Other)
             MODEL W.yi
r
               I*    |   DISPLACEMENT (CID or liters)
                 TT











13 23










ENGINE


                                                         VIN*
                                                    35"
 77
n
~
 Tl
        CAT EQUIPPED (1-Yes;  2-Ho;  3-Can't Tell)
AIR CLEANER  (P-Stock; 6-Non)
        HEATED AIR INTAKE  (0,  1,  3, 4, 6,  7,,9)
        PCV (0. 1, 3, 4, 6,  7)
        TURBO (0, P-Stock,  6-Non, A-Add on)
 •If  Engine Family Not Found
 3/84
                                                                     50
                                                                                                    0 - Not Original Equipped
                                                                                                    1 - Functioning Properly
                                                                                                    2 - Electrical  Disconnect
                                                                                                    3 - Vacuum Disconnect
                                                                                                    4 - Mechanical  Disconnect
                                                                                                    5 - Incorrectly Routed Hose
                                                                                                    6 - Non-Stock
                                                                                                    7 - Hissing Item
                                                                                                    8 - Mlsadjusted Item
                                                                                                    9 - Malfunctioning
                                                                                                    P - Stock
                                                                    EVAP.  (0, 1, 3, 4,  5,  7,  9)
                                                                    AIR PUMP (0,  1,  4,  7,  9)
                                                                    AIR PUMP BELT  (0,  1,  7,  8)
                                                                    P.A.I.R.  (0,  1,  4,  7,  9)
INTAKE MANIFOLD  (P,  6)
                                                                            EXHAUST MANIFOLD  (P,  6)
                                                                       SENSOR  (0,  1,  2. 4, 7)
                                                                    DISTRIBUTOR  (P.  6
VACUUM SPARK  RETARD (0, 1, 2, 3)
                                                                    CARBURETOR  TYPE (P, Sealed, Fuel  Injection, 6)
                                                                    CARBURETOR,  NUMBER OF BARRELS  (0,  1, 2, 4)
                                                                     IDLE  STOP SOl.rilOIl) 10.  1,  2,  7,  9)
                                                                            LIMITER  CAP  (0,  1,  4, 7, 8-Sealed  Plugs Removed)

-------
                             -77-



Form A - Rear



  1-4  ID Number - Vehicles are numbered sequentially as



       they are inspected.  This number is preceded by a




       site identifying letter.






  5-8  Make






 9-12  Model






   13  Vehicle Type - coded as follows: 1 = car, 2 = truck






14-15  License Plate - State abbreviation






16-19  Exhaust gas HC concentration (in ppm) at curb idle.






20-23  Exhaust gas CO concentration (in percent) at curb idle,






   24  Plumbtesmo - Plumbtesmo paper is used to check for the



       presence of lead in vehicle exhaust pipes.  A positive



       indication is coded as 'P1 and a negative as 'N'.






25-27  Odometer - mileage in thousands






   28  Dash Label - displays the fuel required and is coded



       '0', 'I1, or '7'.






   29  Tank Cap - seals the fuel tank during normal operating



       conditions and is coded '!', '7', or '9'.






   30  Tank Label - displays required fuel and is coded '0',



       'I1, or '7'.

-------
                             -78-






   31  Filler Neck Inlet  Restrictor  (unleaded  vehicles only) -



       The restrictor is  designed  to prevent the introduction



       of leaded fuel into  a  vehicle requiring unleaded fuel.



       It is coded '0',  'I1,  '4'  (widened),  or '7'.






   32  Catalytic Converter  -  oxidizes the  HC and CO  to water




       and CC-2 in the exhaust gas.   Later  model catalysts



       also reduce oxides of  nitrogen.  The  converter is




       coded '0', '!',  '7'  (entire catalyst  canister removed),




       or '9'  (high temperature discoloration,  usually light



       blue).






   33  Exhaust System - if  originally equipped a 'P'  is coded.



       If non-stock an "N1  is coded.






   34  Exhaust System Integrity - the condition of the exhaust



       system is coded '!'  (no obvious leaks)  or '9'  (leaks



       evident).






   35  Fuel Sample - indicates if inspector  was able to take




       fuel sample for later  lead analysis ('Y1  or 'N')-






Form B - Format






  1-4  ID Number - same as  on Form A






       Exhaust Gas Recirculation  (EGR)  System  - directs a




       portion of the exhaust gases  back into  the cylinders




       to reduce NOX emissions in the exhaust  gas.   The

-------
                              -79-






       standard EGR configuration consists of a vacuum line




       from the carburetor to a sensor (used to detect



       engine operating temperature to activate the EGR



       valve), and another vacuum line from the sensor to




       the EGR valve.






    5  EGR Control valve - coded '0', 'I1, '3', '7', or



       '9' .






    6  EGR Sensor - coded '0',  '1', '3',  ' 5' ,  '7',  or




       '91 .






  7-8  Vehicle Model year






 9-12  Displacement - as recorded on the  underhood emission




       label.






13-23  Engine Family - as recorded on the underhood emission



       label.






24-36  Non-serial number portion of VIN - as recorded on the



       driver's side of the dash under the windshield or the



       driver's door post.  The VIN is recorded only if the



       engine family can not be determined.






   37  Originally Catalyst Equipped - as  recorded on the



       underhood emission label or the driver's door post.






   38  Air Cleaner - is coded 'P' (stock) or '6'.

-------
                          -80-






39  Heated Air Intake -  provides warm air to the carburetor



    during cold engine operation.   The heated air intake



    is coded '0',  'I1,  '3',  '4',  '6'  (custom air cleaner),



    '7' (stovepipe hose),  or '9'  (vacuum override).






40  Positive Crankcase Ventilation  (PCV)  system - prevents




    crankcase emissions  by purging  the crankcase of blow-



    by gases which leak  between the piston rings and the




    cylinder wall in the combustion chamber under high




    pressures.  The PCV  system is coded '0',  '!', '3',



    '4' (fresh air hose),  '6'  (includes fuel economy




    devices),  or '7' .






41  Turbocharger - coded '0',  '61,  'P',  or 'A'.






42  Evaporative Control  System (ECS) - controls vapors



    from the fuel tank and carburetor.   Some systems have



    two lines: from the  fuel tank to the canister, and



    from the canister to the carburetor or air cleaner



    (for purging the canister). Other systems have a



    third line connected to the carburetor.   The ECS is




    coded '0', '!', '3'  (carburetor line), '4'  (tank



    line), '5', '7',  or  '9'  (air cleaner unsealed).

-------
                          -81-



    Air Injection System - extends the combustion process




    into the engine's exhaust system by injecting fresh



    air into the exhaust ports,  lowering exhaust emissions



    while still maintaining proper vehicle performance.




    Two types of air injection systems are currently used.




    One type uses a belt-driven air pump to direct air



    through a control valve and into the exhaust manifold.




    The other type is a Pulse Air Injection Reaction



    (PAIR) system, which uses an aspirator located in the



    air cleaner to supply air to the exhaust manifold.






43  Air Pump System - for the purposes of this report,



    consists of the air pump and control valve and is



    coded '0' (if a PAIR or none), '!', '4'  (excluding



    belt removal), '?', or '9'.






44  Air Pump Belt - is coded '0' (if PAIR),  'I1, '7', or



   '8' (loose belt).






45  PAIR - coded '0'  (if air pump system or none),  'I1,



    '4',  '?', or '9'.
46  Intake Manifold - coded 'P'  or '6'.





47  Exhaust Manifold - coded 'P1 or '6'.





48  Oxygen Sensor - Controls the air-fuel mixture going



    into the engine of vehicles equipped with three-way



    catalytic converters.   The sensor is  coded '0',  '!',



    '2', '4' (unscrewed),  or '7'.

-------
                         -82-






49  Distributor - coded 'P1  or '6'.






50  Vacuum Spark Retard - retards the spark during idle



    to delay ignition within the combustion chamber and



    increase exhaust temperature, prolonging the com-



    bustion process and reducing HC  emissions.   Vacuum



    spark retard is coded 'O1, 'I1,  '2',  or '3'.






51  Idle Stop Solenoid - provides an idle stop  for




    maintaining idle speeds  at higher rpm levels and




    prevents the throttle plate from fully closing during



    deceleration to minimize CO emissions.  The idle stop



    solenoid is coded '0',  'I1,  '2',  '71,  or '91.






53  Limiter Caps - plastic caps on the idle mixture screws



    to limit carburetor adjustments.   The limiter caps




    are coded 'O1, '!', '4'  (tabs broken  or bent), '7',



    or '8'  (sealed plugs removed).

-------
                             -83-

2.  Classification Of Component Conditions

     The table below was used to classify the various system

components as 'tampered', "arguably tampered', or  'malfunctioning'

Only those codes which are applicable to a given component

are listed.  Codes for 'not originally equipped'. and  'functioning

properly1 are not included in this table.  Refer to Appendix B,

Part 1 for an explanation of the codes.
Component/system




Dash Label

Tank Cap

Tank Label

Filler Neck Restrictor

Catalytic Converter

Oxygen Sensor

PCV System

Idle Stop Solenoid

Heated Air Intake

Evaporative Control
  System

Aspirated Air
  Injection System

Air Pump Belt
                                Codes from form
| 2 3 | 4



or T

T T
T T
T
T A
T T
5 | 6 7 | 9
A
A
A
T
T M
T
T T
T M
T A M
T T M











M
T = tampered
A - arguably tampered
M = malfunctioning

-------
                            -84-



                    	Codes from form

Component/system     |   2  I   3  I   4  |   5   I
Air
EGR
EGR
Pump System T
Control Valve T
Sensor T T
T M
T M
T
Vacuum Spark Retard T T
T = tampered
A - arguably tampered
M = malfunctioning

-------
                             -85-
3.  Fuel Sample Collection and Labeling Procedures





     A fuel sample was taken from each vehicle requiring



unleaded fuel.  These samples were collected in four-ounce



bottles with a hand-operated fuel pump.  Once the sample was



drawn, the fuel was replaced with an equivalent amount of



unleaded fuel if the driver requested, and the pump was flushed



with unleaded fuel.



     Each bottle was identified with an adhesive label that



had the vehicle identifying survey number on it.  The vehicle



identifying number was the first entry on the data forms



described in Part 1 of Appendix B.



     Prior to shipment from the field, a sample tag with the



same identifying number was attached to each bottle.  The



bottles were packed, labeled, and shipped to NEIC Chemistry



Branch according to the shipper's requirements and the NEIC



Policy and Procedures Manual.

-------
                             -86-


4.  Plumbtesmo Application

1)   Clean a portion of the  inside  of  the  tailpipe large enough

     for the test paper by wiping it out with a paper towel or

     cloth.  This may be necessary  to  remove soot deposits

     which might mask the color change.

2)   Moisten the Plumbtesmo  paper with distilled water and

     immediately* press firmly against the surface to be tested

     for approximately thirty seconds.   If the tailpipe is hot

     you may wish to clamp the test paper  in the tailpipe

     using a clean clamp.

     *Note;  The Plumbtesmo  paper must be  applied during the
     time that the paper is  yellow  for the reaction to take
     place.  After approximately 15 seconds the yellow color
     disappears and the paper is no longer effective.  Excess
     water also interferes with the reaction.

     Care must be taken to avoid contamination of the test paper,

     If a person has recently handled  a  test paper with a

     positive reaction, some lead or reactive chemical may

     have been transferred to their fingers.   Subsequently

     handling a clean test paper may cause contamination.

3)   After removing the test paper,  determine whether a color

     change has occurred.  Red or pink coloration indicates

     the presence of lead.

-------
                             -87-






5.  Field Quality Control/Assurance






     Reference and calibration gases were used to ensure the



accuracy of the emissions analyzer.  Horiba gases certified by




RTF were used as reference gases.  Two cylinders of reference



gas were used to validate the accuracy of the calibration gases



before they were taken to the field on each survey.



     Three calibration gases (Horiba) were used.  These gases



were a mixture of CO and HC in nitrogen and were used to check



the instrument at least three times daily.  These calibration



gases were certified by the manufacturer and the RTF reference



gases.  Their approximate compositions were:



     8% CO



     1560 ppm HC (Hexane equivalent)








     4% CO




     827 ppm HC (Hexane equivalent)








     1.6% CO



     320 ppm HC (Hexane equivalent)

-------
                              -88-
                           APPENDIX C

               EMISSION OUTPOINTS FOR I/M AREAS


The table below lists the emission outpoints used by the I/M

areas covered in the 1984 tampering survey.  The outpoints for

pre-1975 vehicles are not included, since these vehicles were

not surveyed.
Survey Site

Boston, MA



Milwaukee, WI
New Jersey


New York, NY
Model Year
Emissions Cutpoints
 CO (%)    HC  (ppm)
1975-79
1980
1981+
1975-77
1978-79
1980
1981+
1975-80
1981 +
1975-77
1978
1979
1980
1981+
1975+
1975+
1975-79
1980
1981+
1975-79
1980+
4.0
2.7
1.2
6.0
4.0
2.5
1.2
3.0
1.2
5.7
4.3
3.0
2.7
1.2
0.5*
3.0
6.0
3.0
1.2
6.5
1.5
400
300
220
600
400
275
220
300
220
700
500
400
330
220
175*
-
600
300
220
600
300
Portland, OR

Reno,  NV

St. Louis, MO



Washington, DC
*Cutpoints for Portland are established by make and model
 year.  The listed cutpoints are applicable to most 1975
 and newer vehicles.

-------