United States
            Environmental Protection
            Agency
Office of Air and Radiation
(ANfl-443)
Washington, DC 20460
       February 1995
EPA-AA-EPSD-IM-94-1226
            Air
&EPA   I/M   Briefing   Book
               Everything  You  Ever  Wanted  to Know  About
                       Inspection  and  Maintenance

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                                 TABLE OF CONTENTS
                                                                                  Page
          Introduction	1
          Glossary of Acronyms	2
          Executive  Summary	3

Section One       Air Quality Information

          Formation of Ozone and Ozone Transport	2
          Health Effects of Carbon Monoxide	4
          Air Quality Designations and Classifications	5
          Carbon Monoxide Classifications	6
          Ozone Classifications	7

Section Two      Enhanced I/M and Clean Air Act Requirements

          Background on Enhanced I/M	2
          Clean Air Act Amendments of 1990	8
          Overview of I/M Rule	10
          Sanctions Required by the Clean Air Act	18
          History of I/M Sanctions	19
          Mandatory Sanctions Scheduled to go Into Effect	20

Section Three     Facts and Figures on I/M

          Cities and States Required to Implement I/M	2
          Population of Areas Required to Implement Inspection/Maintenance	4
          Number Of Vehicles,  Stations and Lanes in I/M Areas	9
          IM240 Program Start Dates	11
          SIP Status	12
          I/M Program Design Features	13

Section Four     Specific I/M Issues

      High-Tech I/M Tests	2
          High-Tech Tests for High-Tech Vehicles	3
          How to Prepare for an Enhanced I/M Test	8
          Recommended IM240 Emission Standards	9
          IM240  Reliability	11
      Cost   of High-Tech I/M	14
          Test  Fees  and Oversight Costs of Enhanced I/M Programs	15
          National Costs and Benefits of Enhanced I/M	16
          Economic Impact of an Enhanced Test-Only in California	•	19
      Test-and-Repair vs. Test-Only	20
          Car Owners'Attitudes Toward Emissions Testing	21
          Test-Only I/M is Effective at Reducing Vehicle Emissions	22
          Test-and-Repair is not Effective at Reducing Vehicle Emissions	23
          Excerpts of Comments on EPA's I/M Rule	25
          National Automobile Dealers Association's Court Challenge to the I/M Rule	27
          Quantitative Assessments of Test-Only and Test-and-Repair I/M Programs	28
          Analysis of Invalid Emission Testing in the California Smog Check Program	47
          Convenience of Test-Only Inspection Networks	48
      Maintenance Issues	52
          General Repair Issues	53
          Performance Monitoring	53

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          Technical Assistance	54
          Certification and Training	55
          Vehicle Maintenance Initiative	56
          Diagnostic Equipment and Tools	57
          Advanced Diagnostic Procedures	59
          Second-By-Second IM240 Emission Report	62
          Emission  Control  Parts  Issues	64
          Causes and Repair of Purge and Pressure Failures	67
      The  Asm  Emission Test	70
          Background on the ASM Test	71
          Evaluation of Acceleration Simulation Modes as an Alternative Enhanced I/M Test... 72
          Economic Comparison of IM240 and Four-Mode ASM	76
      Coverage Issues	77
          Diesel Vehicles	78
          Contribution of Old Cars vs. New  Cars	80
      Remote  Sensing	82
          Basic Information About Remote Sensing	...........	83
          Analysis of the Effectiveness and Cost-Effectiveness of Remote Sensing Devices.... 87

Section Five      Studies,  Papers, and Reports on I/M

          EPA Review  of  GAO Testimony	;"V*VV^	2
          EPA Response to the GAO Report on Proposed Vehicle I/M Programs	5
          EPA Comments on Testimony of RAND Corporation.....	.7
          I/M Effectiveness as Directly Measured by Ambient CO Data	12

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                                   INTRODUCTION

This document provides detailed information about Inspection/Maintenance (I/M) programs required
by the Clean Air Act Amendments of 1990 (the Act).  It is divided into four sections:

       1)     Background information on air quality

       2)     The mandates established by the Act and EPA's regulations

       3)     Topics and issues specific to I/M, and

       4)     EPA's responses to various reports critical of I/M.

Some of the materials presented in this document are subject to periodic revision by EPA. Updated
versions of these documents may be obtained by writing to:

                    U.S. EPA
                    I/M Section
                    2565 Plymouth Road
                    Ann Arbor, Michigan  48105

or, by sending a fax to the I/M Section at 313-668-4497. The items that are periodically updated
include all of those included in the air quality designations listed in Section One; the Facts and
Figures on I/M Coverage part of Section One; and, the State Implementation Status listed in Section
Three.  A full set of the I/M rules and complete copies of EPA reports referenced in this document
are also available upon request.  Reports by non-EPA organizations, for example RAND or GAO,
should be obtained directly from the organization.

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Act
CO
CO2
CVS
EPA
FTP
gpm
GVWR
HC
I/M
IM240
MSA
NAAQS
NOx
O3
OTC
OTR
ppm
psi
RG240
SIP
VOC
         GLOSSARY OF ACRONYMS
The Clean Air Act Amendments of 1990
Carbon monoxide
Carbon dioxide
Constant Volume Sampler
United States Environmental Protection Agency
Federal Test Procedure
Grams per mile
Gross vehicle weight rating
Hydrocarbons
Inspection/Maintenance
A high-tech transient, dynamometer test that takes up to 240 seconds
Metropolitan Statistical Area
National ambient air quality standards
Oxides of nitrogen
Ozone
Ozone Transport Commission
Ozone Transport Region
Parts per million
Pounds per square inch
Repair grade IM240 equipment, intended for diagnosis and repair verification
State Implementation Plan
Volatile Organic Compound
Section One
                                                                              Page 2

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                               EXECUTIVE SUMMARY
 Accurate and  Reliable Tests
    •    High-tech tests are necessary for high-tech cars, including transient, dynamometer tailpipe
         emission testing (IM240), and functional checks of the evaporative emission control system
    •    EM240 simulates on-road driving conditions and tests vehicles at all normal speeds to
         insure accurate identification of those that need repair
         IM240 can identify high emitting vehicles without failing clean ones (no false failures)
         IM240 is the most accurate short test available for use in I/M programs
 IM240 Gets Big Emission Reduction  Benefits
    •    32% reduction in mobile source VOCs
    •    34% reduction in mobile source CO
         11 % reduction in mobile source NOx
    •    Also reduces toxic emissions and fuel consumption
 Enhanced I/M Reduces  Consumer Hassle
         Doing the test right is better than doing it often — enhanced I/M can be done biennially
    •    Biennial testing cuts consumer inconvenience in half and cuts convenience costs in half
         Plenty of high-capacity, production style test lanes and stations means little or no wait time
         for most motorists and short driving distances to stations
    •    Virtually zero false failures means no more wasted repair expenditures on clean cars
 IM240 Testing Costs About the Same  as Idle
         Average cost: $20 every other year, or about $ 10 annually -  $3 less than the average
         annual fee consumers pay today  (based on contracts awarded to date)
         Fuel economy improvements average 13% for vehicles that fail the IM240 and 6% for
         vehicles that fail the evaporative system pressure or purge tests
         Average repair costs range from $40 - $250 depending on which tests are failed
    •     Fuel economy savings offset some of the repair cost
 IM240 is the Best Choice  for Air Pollution Control
    •     Most cost-effective air pollution control program at a cost of $500 per ton of VOCs reduced
    •    Reduces the current national expenditure on I/M by at least $350 million
    •    Creates 3,800 - 11,600 jobs in repair, construction, and inspection industry
         High-tech testing gets over 40% of the emission reductions needed to meet Act required
         15% reduction by 19%
    •    Adopting less effective I/M would cost the nation $ 1.6 billion a year in more expensive
        stationary source controls in order to meet air quality goals
    •    Basic I/M areas can opt-up to enhanced for more emission reductions (many states have)
Test-only Testing Eliminates Fraud
    •    Separating testing and repair eliminates the fraud found in test-and-repair programs
    •    States can implement centralized, test-only or decentralized, test-only systems for full credit
        Hybrid systems can be implemented for partial credit, with credit losses made up with
        measures such as tighter cutpoints, remote sensing, and repair technician certification.
Section One                                                                         Page3

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                        Section   One
              Air  Quality  Information



This section provides" background information on air quality, ozone formation and transport, the
health effects of ozone and carbon monoxide, and the classifications of areas around the country and
the associated requirements for I/M programs.

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                FORMATION OF OZONE AND OZONE TRANSPORT

What is Ozone?

Ozone is a form of molecular oxygen that consists of three oxygen atoms linked together. Ozone in
the upper atmosphere (the "ozone layer") occurs naturally and protects life on earth by filtering out
ultraviolet radiation from the sun.  Ozone at ground level, however, is highly corrosive, damaging
plant, animal, and human tissue, and other materials such as metals and masonry. It is the major
component of urban smog.

Why is Ozone a Public Health Problem?

Ozone is a severe irritant.  It is responsible for the choking, coughing, and stinging eyes associated
with smog. Ozone damages lung tissue, aggravates respiratory disease, and makes people more
susceptible to respiratory infections. Children are especially vulnerable to ozone's harmful effects,
as are adults with existing disease. But even otherwise healthy individuals may experience impaired
health from breathing ozone-polluted air. Elevated ozone levels also inhibit plant growth and can
cause widespread damage to crops and forests.

Unhealthy ozone levels are a problem across the United States, with about 90 cities exceeding the
National Ambient Air Quality Standard (NAAQS). The standard is based on the highest ozone
exposure sensitive persons can tolerate.  Nine cities, home to 57 million people, are considered
"severely" polluted and experience peak ozone levels that exceed the standard by 50% or more. (See
list of Ozone Classifications later in this section.)

How is Ozone Formed?

Ozone is not emitted directly but is formed in the atmosphere through a complex set of chemical
reactions involving hydrocarbons (HC) and oxides of nitrogen (NOx) catalyzed by sunlight. The
rate at which these reactions occur is affected by both temperature and intensity of the sunlight. For
this reason, high ozone levels occur most often on hot summer afternoons.

Hydrocarbons and nitrogen oxides come from a wide variety of industrial and combustion
processes. In typical urban areas, one-third to one-half or more of those pollutants come from cars,
trucks, and buses.

How is Ozone Monitored?

Pollutant concentrations are continually measured by networks of national, state and local monitoring
stations. Most monitoring stations are situated in urbanized areas to measure ozone concentrations to
which the population is exposed but some are located in down-wind areas as well. Ozone
measurements are averaged over a one-hour period and compared to the standard of 0.12 parts per
million (ppm). Violations of the ozone standard are determined by looking at the second highest
daily readings obtained from the monitoring sites in an urbanized area hi a year. Hence, more than
one day of high ozone readings is needed in order for an area to be in violation of the ambient ozone
standard. An area meets the ozone standard if, on average, not more than one annual exceedance is
recorded over a three year period.  As required by the Clean Air Act, EPA designated 98 areas as
ozone nonattainment areas in 1991. Since then, seven areas have been redesignated to attainment
based upon a lack of violations over a three year period and a demonstration that the air quality
improvements can be maintained over time. Resignations are pending in several other areas as
well (see lists later in this section).
Section One
                                                                                  Page 2

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 How is Ozone  Transported?

 Ozone is usually not formed at the point where the precursors, hydrocarbons and oxides of nitrogen,
 are emitted. Rather, these chemicals are typically carried some distance on the wind before the right
 mix and conditions for ozone formation are achieved. Pollutants in one area can contribute to ozone
 problems in other areas. In regions of the country where several urbanized areas are located close to
 each other, such as the northeast coastal region, ozone in one part of the area may be caused by a
 combination of ozone precursors emitted locally and those emitted in other, upwind areas. For
 example, NOx from an upwind source may combine with locally generated HC to form ozone in a
 particular area.  This means that ozone precursors and ozone itself can move over large areas causing
 problems wherever the wind takes them. Thus, ozone is a regional problem rather than a local
 problem.

 Why was the Ozone Transport Region Created?

 Given that ozone is a regional problem, it requires a regional solution. Traditional ozone control
 strategies, where the ozone problem in a given area is addressed by focusing only on ozone
 precursors generated in that area, have failed to bring the ozone problem under control in many parts
 of the country. The Act provided for the establishment of Ozone Transport Regions and directed that
 an Ozone Transport Region be established in the northeast, comprising the states of Maine, New
 Hampshire, Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey,
 Pennsylvania, Delaware, Maryland, and the Washington, D.C. Metropolitan Statistical Area,
 including the northern Virginia suburbs. The creation of an Ozone Transport Region enables
 measures which address ozone nonattainrnent as a regional problem, rather than addressing ozone
 nonattainment in each urbanized area individually.

 How Does the Establishment of an  Ozone Transport Region Affect  I/M?

 Emissions from cars and trucks are a major contributor to ozone nonattainment problems in our
 cities. For that reason, additional measures are taken in an Ozone Transport Region to bring these
 emissions under control. In an Ozone Transport Region, the Clean Air Act requires that enhanced
 I/M be implemented in all Metropolitan Statistical Areas with a population of 100,000 or more
 regardless of attainment status.  This is because hydrocarbons and oxides  of nitrogen emitted by
 vehicles in areas where ozone pollution is not a problem can be transported on the wind to nearby
 urbanized areas and contribute to ozone nonattainment there.
Section One

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                   HEALTH EFFECTS OF CARBON MONOXIDE

What  is Carbon Monoxide?

Carbon monoxide (CO) is a colorless, odorless, poisonous gas.  A product of incomplete burning
of hydrocarbon-based fuels, carbon monoxide consists of a carbon atom and an oxygen atom linked
together.

Why is Carbon Monoxide a Public Health Problem?

Carbon monoxide enters the bloodstream through the lungs and forms carboxyhemoglobin, a
compound that inhibits the blood's capacity to carry oxygen to organs and tissues.  Persons with
heart disease are especially sensitive to carbon monoxide poisoning and may experience chest pain if
they breathe the gas while exercising. Infants, elderly persons, and individuals with respiratory
diseases are also particularly sensitive.  Carbon monoxide can affect healthy individuals, impairing
exercise capacity, visual perception, manual dexterity, learning functions, and ability to perform
complex tasks. Acute exposure can cause death.

In 1994,11 urban areas in the United States exceeded the National Ambient Air Quality Standard for
carbon monoxide.

How  is Carbon Monoxide Formed?

Carbon monoxide results from incomplete combustion of fuel and is emitted directly from the
tailpipe. Incomplete combustion is  most likely to occur at low air-to-fuel ratios in the engine. These
conditions are most common during vehicle start-up when  air supply is restricted ("choke") and,
more importantly, when vehicles are not working properly  to minimize emission levels.

Nationwide, two-thirds of the carbon monoxide emissions  come from transportation sources, with
the largest contribution coming from highway motor vehicles. Motor vehicles typically contribute
more than 90% of the carbon monoxide pollution emitted in urban areas.

How  is Carbon Monoxide Monitored?

CO is continually measured by networks of monitoring stations similar to those used to measure
ozone. Most stations are situated near corridors of congested urban vehicle traffic, where high CO
concentrations are likely to occur. CO concentrations are averaged over periods of one hour and
eight hours. Violations are based upon the second highest  daily readings, with the one how-
averaged readings not to exceed 35  ppm, and the eight hour averaged readings not to exceed 9 ppm.
An area meets the CO standard if no more than two exceedances are recorded over a two year period.
Section One                                                                         Page 4

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             AIR  QUALITY DESIGNATIONS AND CLASSIFICATIONS

The Clean Air Act Amendments of 1990 required states to submit to EPA a list of areas to be
designated as "nonattainment" - i.e., in violation of the national ambient air quality standards. EPA
was required to place these areas into various classifications depending on the air pollution levels in
the area, as follows:
Ozone
Classification
Marginal
Moderate
Serious
Severe - 15
Severe - 17
Extreme

Carbon Monoxide
Classification
Moderate
Serious
Design Value
(ppm)
.121 - .138
.138 - .160
.160 - .180
.180 - .190
.190 - .280
.280 +

Design Value
(ppm)
9.1 - 16.4
16.5 +
Attainment
Date
1993
1996
1999
2005
2007
2010

Attainment
Date
1995
2000
The design value is the measured level of pollution in an area that is considered to be representative
of the air quality problem. The Act requires that classified areas must develop and implement State
Implementation Plans that will bring the nonattainment areas into attainment by the deadlines
established for the classification. "Attainment" is the point at which the air quality standards are no
longer violated The more severe the air quality problem, the more time is needed and allowed to
come into attainment. The Act requires more stringent pollution control programs in areas with
higher classifications. For example, moderate ozone areas are required to implement basic I/M
programs while serious or worse ozone areas must implement enhanced I/M.  Similarly, marginal
areas are not required to implement new I/M programs but they are required by the Act to keep
existing programs, at least until they achieve attainment.

The Act requires a variety of mobile source and stationary source controls, again depending on the
severity of the air quality problem.  In addition to specific control programs, the Act requires that
moderate and worse ozone areas achieve a 15% reduction in hydrocarbon emissions by November
15, 1996. The base year for comparison is 1990.  Serious, severe and extreme ozone areas also
have to achieve an additional 3% reduction in hydrocarbon emissions in each year after 1996, until
attainment is reached.

To achieve these reductions states will have to make difficult choices about which additional control
measures, over and above those required by the Act, to implement to achieve the required reductions.
Several states with moderate ozone areas have already decided to  "opt-up" to enhanced I/M as a
major measure to achieve the 15% requirement because of its superior cost-effectiveness (discussed
in the next section). Other choices typically involve putting regulations on small businesses, like
paint shops bakeries, and dry cleaners, to get the reductions.  These controls have a much greater
economic cost and a negative impact on jobs, making enhanced I/M a more attractive option.
Similarly contrary to popular belief, large stationary sources have been highly controlled since the
1977 amendments to the Clean Air Act. Getting additional emission reductions out of these sources
is very difficult and expensive.

Areas that fail to meet the ambient air quality standards by the deadline get "bumped-up" to the next
highest classification and must implement the additional measures associated with that classification.
Section One
                                                                                  PageS

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                      CARBON MONOXIDE CLASSIFICATIONS

The Act requires implementation of enhanced I/M in moderate and serious carbon monoxide areas
that exceed a 12.7 ppm design value and have an urbanized population of 200,000 or more. Basic
I/M is required in other carbon monoxide nonattainment areas if they had (or were required to have)
an operating I/M program prior to the Act. The 1991 classifications of all CO nonattainment areas
are as shown in the following table.


                                          Serious

                                       Los Angeles, CA
Anchorage, AK
Denver-Boulder, CO
Fresno, CA
  Moderate  >12.7 ppm

Las Vegas, NV
New York-New Jersey-Long Island,
   NY-NJ-CT
Provo, UT
Seattle-Tacoma, WA
Spokane, WA
Albuquerque, NM
Baltimore, MD
Boston, MA
Chico, CA
Colorado Springs, CO
El Paso, TX
Fairbanks, AK
Fort Collins, CO
Grants Pass, OR
 Moderate <= 12.7  ppm

Klamath Falls, OR
Lake Tahoe South Shore, CA
Longmont, CO
Medford,OR
Minneapolis-St. Paul, MN
Missoula,  MT
Modesto, CA
Ogden, UT
Philadelphia-Camden County, PA-NJ
Hartford-New Britain-Middletown, CT   Phoenix, AZ
Portland-Vancouver, OR-WA
Raleigh-Durham, NC
Reno, NV
Sacramento, CA
San Francisco-Oakland-
   San Jose, CA
San Diego, CA
Stockton, CA
Washington, DC-MD-VA
Winston-Salem, NC
Section One
                                                     Page 6

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                               OZONE  CLASSIFICATIONS
The Act requires states to adopt either a basic or enhanced I/M program, depending on the
classification of the area. Basic I/M programs are required in all moderate ozone nonattainment areas
(except rural areas) and marginal ozone nonattainment areas that had (or were required to have) an
operating I/M program prior to the Act. Enhanced I/M programs are required in all serious, severe,
or extreme ozone nonattainment areas with urbanized populations of 200,000 or more (basic is
required in smaller serious ozone areas). Enhanced I/M is also required in all Metropolitan Statistical
Areas with a population of 100,000 or more in the Northeast Ozone Transport Region. Moderate
areas may opt-up to enhanced I/M for more credit (and many have). The 1991 ozone classification
and attainment years are as follows:

                                       Extreme  (2010)
                               Los Angeles-South Coast Air Basin, CA
Chicago-Gary-Lake County, IL-IN
Houston-Galveston-Brazoria, TX
Baltimore, MD
Atlanta, GA
Baton Rouge, LA
Beaumont-Port Arthur, TX
Boston-Lawrence-Worchester, MA-NH
Atlantic City, NJ
Charlotte-Gastoria, NC
Cincinnati-Hamilton, OH-KY
Cleveland-Akron-Lorain, OH
Dallas-Fort Worth, TX
Dayton-Springfield, OH
Detroit-Ann Arbor, MI
Grand Rapids, MI
Huntington-Ashland, WV-KY
Kewaunee County, WI (rural)
Albany-Schenectady-Troy, NY
Allentown-Bethlehem-Easton, PA-NJ
Altoona, PA
Birmingham, AL
Buffalo-Niagara Falls, NY
Canton, OH
Columbus, OH
Door County, WI
Edmonson County, KY
Erie, PA
Essex County, NY
Evansville, IN
Greenbriar County, WV
Hancock and Waldo Counties, ME
      Severe  (2007)
Milwaukee-Racine, WI
New York-New Jersey-Long Island, NY-NJ-CT
      Severe  (2005)
Philadelphia-Wilmington-Trenton,
   PA-NJ-DE-MD

      Serious  (1999)
El Paso, TX
Greater Connecticut
Portsmouth-Dover-Rochester, ME-NH
Providence, RI (statewide)

     Moderate (1996)
Knox and Lincoln Counties, ME (rural)
Lewiston-Auburn, ME
Louisville, KY-IN
Manitowoc County, WI (rural)
Miami-Fort Lauderdale-W Palm Beach, FL
Monterey Bay, CA
Muskegon, MI
Nashville, TN
Phoenix, AZ
Pittsburgh-Beaver Valley, PA

     Marginal (1993)
Harrisburg-Lebanon-Carlisle, PA
Indianapolis, IN
Jefferson County, NY
Jersey County, IL
Johnstown, PA
Kent and Queen Anne's Counties, MD
Lake Charles, LA
Lancaster, PA
Lexington-Fayette, KY
Manchester, NH
Memphis, TN
Norfolk-Virginia Beach-Newport News,VA
Owensboro, KY
Paducah,KY
San Diego, CA
Ventura, CA
Sacramento metro area, CA
San Joaquin Valley, CA
Springfield, MA
Washington, DC-MD-VA
Portland, ME
Reading, PA
Richmond, VA
Salt Lake City, UT
San Francisco-Bay area, CA
Santa Barbara-Santa Maria
   -Lompoc, CA
Sheboygan. WI
St. Louis, MO-EL
Toledo, OH
Portland-Vancouver, OR-WA
Poughkeepsie, NY
Reno, NV
Scranton-Wllkes-Barrt, PA
Seattle-Tacoma, WA
Smyth County, VA
South Bend-Elkhart, IN
Sussex County, DE
Tampa-SL Petersburg-
   Clearwater, FL
Walworth County, WI
York, PA
Youngstown-WnreQ-Shiron,
   OH-PA
Section One
                                                                                        Page?

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                       Section  Two
       Enhanced I/M  and  Clean  Air  Act

                       Requirements


This section discusses the enhanced I/M program, the requirements of the Clean Air Act
Amendments of 1990 and EPA's response to those requirements. It explains the specific
requirements for enhanced and basic I/M areas. It also addresses the general approach of the Clean
Air Act, the rate of progress requirements (e.g., 15% reduction by 1996), and the mandatory and
discretionary sanctions included in the Act.

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                         BACKGROUND ON ENHANCED  I/M

 This section provides a more detailed discussion of various aspects of the enhanced I/M program
 requirement. The Clean Air Act was amended in 1990 with strong bipartisan support and was
 signed by President Bush to ensure that all Americans will breathe clean air.

 The Clean Air Act Requirements

 While the Clean Air Act Amendments of 1990 required EPA to provide states with flexibility in
 designing enhanced I/M programs, they nevertheless contained several minimum requirements for
 such programs, including:

     •   Implementation in the urbanized portion of any serious or worse ozone or carbon monoxide
         nonattainment area with a 1980 Census-defined population of 200,000 or more, and within
         any metropolitan statistical area of 100,000 or more in a designated ozone transport region.

     •   Enforcement through registration denial (unless an existing alternative is superior).

     •   Sufficient emission reductions to meet a minimum performance standard developed by
         EPA.  The Act specifies minimum features of the enhanced I/M performance standard:

            »  Coverage  of all 1968 and newer light-duty vehicles and trucks (up to 8,500 Ibs;)

            »  A battery  of tests including tailpipe emissions, on-road testing, an antitampering
               check, and onboard diagnostic system interrogation

            »  Annual, centralized testing

     •   Limits on waivers for non-complying vehicles, including no waivers for vehicles under
         warranty or for vehicles which have not received a minimum of $450 in repairs (with the
         amount to be adjusted annually starting in 1996, based upon the Consumer Price Index).

EPA's  I/M Rule

On November 5, 1992, EPA published the I/M rule in the Federal Register, thus formalizing (among
other things) the performance standard for enhanced I/M. The enhanced performance standard
includes the following program elements (keep in mind, this is not EPA's recommended enhanced
I/M program design - read on):

                            Performance  Standard  Program

       Network Type              Centralized
       Test Frequency             Annual
       Model Year Coverage        1968 and newer
       Vehicle Types              Light-duty vehicles and trucks to 8,500 Ibs. GVWR
       Exhaust Tests               IM240 on 1986 and newer vehicles (at specified cutpoints)
                                 Two-speed idle on pre-86 vehicles (at specified fail rates)
       Evaporative System Tests   Purge test on 1986 and newer vehicles
                                 Pressure test on 1983 and newer vehicles
       Visual Tests                Catalyst and fuel inlet checks on 1984 and newer vehicles
       Waiver Rate                3%
       Compliance Rate            96%

The above elements of the performance standard do not represent mandatory program design features
(or even EPA s recommended program features). Instead,  the performance standard is just a


Section Two                                                                       Page 2

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collection of inputs which are entered into EPA's mobile source emission factor model (currently
MOBILESa) along with local area parameters such as vehicle age distribution, fuel type, altitude, and
temperature, to produce an emission target which a proposed program must meet or beat to be
considered in compliance with the performance standard. States are free to design a program that
best meets local needs. EPA's recommended program design is as follows:

                         Recommended Enhanced I/M Program

       Network Type               Centralized
       Test Frequency              Biennial
       Model Year Coverage        1968 and newer
       Vehicle Types               Light-duty vehicles and trucks  to 14,000 Ibs. GVWR
       Exhaust Tests               BVI240 on all vehicles (at specified cutpoints)
       Evaporative System Tests     Purge test on 1971 and newer vehicles
                                   Pressure test on 1971 and newer vehicles
       Visual Tests                 None
       Waiver Rate                 3%
       Compliance Rate             96%

EPA recommends that states adopt this more cost-effective program design.  It requires only biennial
testing, which is accommodated by expanding the model years covered by the IM240, purge, and
pressure tests.  The IM240 and evaporative tests are far more effective and cost-effective than the
older idle and visual checks that are part of the performance standard. Since the IM240 is effective
enough to fail  vehicles with missing or broken emission controls, the time-consuming and less
effective visual checks are not needed.

Options for  Meeting the  Enhanced I/M  Performance Standard

While EPA recommends the  centralized approach to setting up the enhanced I/M program, and the
above mix of tests, states have other options. The range of program variations that meet the
enhanced I/M  performance standard is wide. Section Three provides detailed information on the
design of I/M programs, and it shows that states have chosen a wide variety of mixes of testing and
coverage.

The Act requires that enhanced I/M programs be centralized unless a state makes a demonstration that
decentralized is equally effective (see detailed discussion in Section Four). In the final rule, EPA
specifically found that a decentralized, test-only program could meet this requirement of the Act. So,
instead of hiring a single contractor, a state could contract with any vendor that wanted to set up a
station and provide testing services. These contractors would be specifically barred from being
involved in any way with the automotive service and repair business. Texas and Nevada have
chosen to implement the decentralized, test-only system using two different approaches.

Another network design that states could implement is what is referred to as a hybrid program. A
hybrid program consists of test-only and test-and-repair elements.  In one hybrid approach, a
specified range of model year vehicles participate in the less effective test-and-repair network
ftvoicallv  2 and 4 year old vehicles in a biennial program), while all other vehicles must go to
enhanced test-only stations (6 year old and older vehicles).  A 50% discount is applied to the  credit
from the test-and-repair portion of the program, so it is necessary to maximize al aspects of the test-
only portion to offset this deficit. Maximization of the test-only program generally means tighter
standards and much higher failure rates on older cars. California and Georgia have chosen to
implement hybrid designs (see further discussion in Section Four).
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Other Minimum Requirements

The Act also called upon EPA to develop minimum requirements for "program administration
features necessary to reasonably assure that adequate management resources, tools, and practices are
in place to attain and maintain the performance standard." Along with the performance standard
described above, these minimum administrative requirements were promulgated by EPA as part of
the I/M rule, which was published in the Federal Register on November 5, 1992.  These
administrative provisions include requirements for:
     •  A non-lapsing funding mechanism
     •  Minimum hours of operation and customer convenience at test stations
     •  Vehicle coverage
     •  Test procedures, standards, and specifications
     •  Quality control and assurance, and minimum enforcement program oversight
     •  Motorist and inspector enforcement
     •  Repair effectiveness performance monitoring and repair technician support
     •  Data collection and reporting
     •  Recall compliance
     •  Public information and consumer protection

Geographic Coverage

In the northeast ozone transport region (OTR), the act requires enhanced I/M to be implemented in
any metropolitan statistical area (MSA), or portion of an MSA, with a population of 100,000 or
more, regardless of the area's attainment classification. This means that even MS As that have no
local air quality problem must implement enhanced 1/M.  EPA rules require that enhanced I/M be
implemented county-wide in the entire OTR MSA, except in largely rural counties with fewer than
200 persons per square mile (as long as at least 50% of the MSA population is covered).

Outside of the northeast ozone transport region, the Act requires I/M programs only in areas that
have air quality problems.  Any area in the nation designated as serious or worse for ozone
nonattainment, or as moderate or serious CO nonattainment with a design value greater than 12.7
ppm, and having a 1980 Census defined urbanized area population of 200,000 or more, must
implement enhanced I/M in at least the urbanized area.  Serious or worse ozone nonattainment areas
which have urbanized areas which were smaller than 200,000 population in 1980, must implement
basic I/M programs. EPA recommends that states expand geographic coverage beyond urbanized
area boundaries to include areas that contribute in a significant way to the mobile source emission
inventory in the nonattainment area. Most areas expand coverage to the county boundaries in the
primary counties that include the urbanized area.  Only a few states  (NJ, MA, Rl, CT) have
expanded implementation to the entire state.

The reason coverage of I/M program is limited to urban areas or MS As is because it costs
substantially more on a per vehicle basis to implement the program in less dense, rural areas. A
nation-wide inspection program would be very costly and yield little additional benefit over the more
limited coverage program called for in the Act.

Vehicle Coverage

States generally have the flexibility to choose vehicle coverage. In order to meet the performance
standard, nearly all light-duty cars and trucks must be included. States typically exclude pre-1968
vehicles. Some states have model year cutoffs somewhere in the 1970s. Heavy-duty gasoline
powered highway trucks are usually included in enhanced I/M programs. Diesel vehicles are
typically not included in I/M programs because their hydrocarbon or carbon monoxide emissions do


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 not tend to increase as they age.  Of course, diesel vehicles do produce noxious smoke if they are not
 properly maintained but that smoke does not contribute to ozone formation. (See discussion in
 Section 3.)

 The Act requires that vehicles which are owned by the Federal government or operated on a Federal
 installation located within an I/M program area be tested, regardless of whether the vehicles are
 registered in the state or local I/M area.  This requirement applies to all employee-owned or leased
 vehicles (including vehicles owned, leased, or operated by civilian and military personnel on Federal
 installations) as well as agency-owned or operated vehicles.  The Act does exclude tactical military
 vehicles.

 Implementation Schedule

 Enhanced I/M is required to start in 1995. States may phase-in testing during 1995, as long as a
 minimum of 15% of the fleet is tested in the new program.  The program must be fully phased-in by
 January of 1996.

 Benefits  of Enhanced I/M

 One of the main features of the enhanced I/M program is that it achieves more emission reductions
 than basic I/M  and at the same time is very cost-effective. The IM240  and the evaporative system
 checks together make enhanced I/M about five times more effective than the typical basic I/M
 program.

 The Act requires states to not only meet the enhanced I/M performance standard, but to also make
 reasonable further progress in meeting the goal of attaining the national ambient air quality standards.
 The Act specifies that moderate and worse ozone areas achieve a 15% reduction in hydrocarbon
 emissions between 1990 and 1996. The  enhanced I/M program can make a major contribution to
 achieving these reductions. As much as  40% of the 15% requirement can be satisfied with enhanced
 I/M. The Act also requires that serious and worse ozone areas achieve  a 3% reduction each year after
 1996. Again, enhanced I/M plays a major role in achieving this goal. Several states that are required
 to implement only basic I/M programs have opted-up to the enhanced I/M program to help meet the
 15% reduction. Those states include Arizona, Kentucky, Michigan, Missouri, Ohio and Utah. In
 addition, states that have both enhanced and basic areas have opted up in some or all of the basic
 areas including: Colorado, Illinois, Indiana, Maine, Texas, and Wisconsin.

 These states are opting-up to enhanced I/M because it is the most cost-effective way to accomplish
 the needed reductions.  The alternative is to further regulate stationary sources of air pollution. Up
 until now, all of the large stationary sources have been installed emission controls. All of the
 relatively inexpensive controls have been installed. Additional controls on stationary sources cost
 $5,000 - $25,000 per ton of VOC reduced. Test-and-repair I/M programs, which are already in
 place in many of these opt-up areas, cost about $15,000 per ton. Enhanced test-only I/M costs only
 about $500 per ton, and gets CO and NOx reductions too. In addition, in order to meet the 15%
 reduction requirement, controls on small sources such as bakeries, dry cleaners, paint shops, and
 other small businesses would be necessary.  These controls could cost jobs and hurt the economies
 of the affected areas. Enhanced test-only I/M, on the other hand, will substantially increase jobs.
 Studies conducted by EPA and other independent organizations all show that jobs will increase as a
 result of enhanced I/M.  In states that are switching from test-and-repair to test-only, the number of
 persons employed in the testing business will decrease, but at the same time the number of persons
 employed in the repair business will substantially increase. The increase in repair jobs more than
 offsets the decrease in testing jobs. The repair jobs also tend to be higher paying, skilled jobs. In
 addition, setting up and maintaining the test network provides business to local construction, real
 estate and service industries.
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       Enhanced I/M  Achieves Greater Emission  Reductions Than Basic I/M
                                                        40%
                                       32%
                      6%
                   Basic I/M
      Enhanced I/M      Maximum I/M
          Enhanced I/M is Much More Cost-Effective Than Alternatives
                                                              $15,000
                                              $10,000
                              $3,700
               $500
             Enhanced
             Test-Only
                I/M
Tierl Car
Standards
Additional
Stationary
 Controls
Test-and-
Repair I/M
                   Jobs  Increase With Test-Only, Enhanced I/M
                                                               15,000
                                  Without Enhanced I/M
                                  With Enhanced I/M
                                                       11,400
               9,100   8)80o
                                           6,200
               Inspection Jobs
        Repair Jobs
            Total Jobs
Section Two
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The  Centralized  Requirement

»     The most controversial aspect of the Clean Air Act is the following requirement for enhanced
      I/M areas:

       "Operation of the program on a centralized basis, unless the State demonstrates to
        the satisfaction of the Administrator that a decentralized program will be equally
        effective."  (emphasis added)

»     EPA's proposed rulemaking on I/M asked for comment on whether states should be allowed to
      "try one more time" to make test-and-repair work.

»     While some representatives of the test-and-repair industry supported this provision or
      suggested even weaker options, most commenters said the option should be eliminated.

»     Every state commenter strongly urged elimination of test-and-repair unless EPA could find a
      way to make it work because there was, in their view, no way that a test-and-repair program
      could meet the enhanced performance standard  and be cost-effective.

»     As a result of these comments and the evidence available, EPA published a final rule without
      the "one-more-try" option

»     The final rule establishes presumptive equivalency (to centralized) for decentralized, test-only
      networks. Based on the evidence available, EPA decided that a decentralized program that
      separated testing from repair could meet the Act's requirements for equivalency.

»     The final rule establishes national default assumptions about the effectiveness of test-and-repair
      programs in relation to test-only programs (the  "50% credit" discount).  These credit
      assumptions make it impossible for a state to meet the enhanced I/M performance target with a
      test-and-repair program. This issue has been litigated and the Federal Appeals Court upheld
      the provision, stating that ample evidence exists to support EPA's rule.

»     The final rule also establishes criteria that allow a state to make a demonstration  that the test-
      and-repair program it has been operating is more effective than EPA's default assumption.

»     This issue is addressed in detail in Section Three.
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                     CLEAN AIR ACT AMENDMENTS OF 1990

                        Excerpt That Pertains to Enhanced  I/M

The following text is from Section 182(c)(3), the main section of the Clean Air Act Amendments of
1990 that specifies the enhanced I/M program design.

(3)     Enhanced Vehicle Inspection And Maintenance Program

       (A)  Requirement For Submission.  Within  2 years after the date of the enactment of the
            Clean Air Act Amendments of 1990, the State shall submit a revision to the applicable
            implementation plan to provide for an enhanced program to reduce hydrocarbon
            emission and NOx emissions from in-use motor vehicles registered in each urbanized
            area (in the nonattainment area), as defined by the bureau of the Census, with a 1980
            population of 200,000 or more.

       (B)  Effective Date Of State Programs: Guidance.  The  State program required under
            subparagraph (A) shall take effect no later than 2 years from the date of the enactment
            of the Clean Air Act Amendments of 1990,  and  shall comply in all respects with
            guidance published in the Federal Register (and from time to time revised) by the
            Administrator for enhanced vehicle inspection and maintenance programs.   Such
            guidance shall include-

            (i)   a performance standard achievable by a program combining emission testing,
                 including on-road emission testing, with inspection to detect tampering with
                 emission control devices and misfueling for all light-duty vehicles and all light-
                 duty trucks subject to standards under section 202; and

            (ii)   Program administration features necessary to reasonably assure that adequate
                 management resources, tools and practices are in  place to attain and maintain the
                 performance standard.

            Compliance with the performance standard under clause (i) shall be determined using a
            method to be established by the Administrator.

       (C)  State Program. The State program required under subparagraph (A) shall include, at a
            minimum, each of the following elements -
            (0
Computerized emission analyzers, including on-road testing devices.
            (ii)   No waivers for vehicles and parts covered by the emission control performance
                 warranty as provided for in section 207(b) unless a warranty remedy has been
                 denied in writing, or for tampering-related repairs.

            (iii)  In view of the air quality purpose of the program, if, for any vehicle, waivers are
                 permitted for emissions-related repairs not covered by warranty, an expenditure to
                 qualify for the waiver of an amount of $450 or more for such repairs (adjusted
                 annually as determined by the Administrator on the basis of the Consumer Price
                 Index in the same manner as provided in title V).

            (iv)  Enforcement through denial of vehicle registration (except for any program in
                 operation before the date of the enactment of the Clean Air Act Amendment of
                 1990 whose enforcement mechanism is demonstrated to the Administrator to be
                 more effective than the applicable vehicle registration program in assuring that
                 noncomplying vehicles are not operated on public roads).
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             (v)   Annual emission testing and necessary adjustment, repair, and maintenance,
                  unless the State demonstrates to the satisfaction of the Administrator that a
                  biennial inspection, in combination with other features of the program which
                  exceed the requirements of this Act, will result in emission reductions which
                  equal or exceed the reductions which can be obtained through such annual
                  inspections.

             (vi)  Operation of the program on a centralized basis, unless the State demonstrates to
                  the satisfaction of the Administrator that a decentralized program will be equally
                  effective. An electronically connected testing system, a licensing system, or other
                  measures (or any combination thereof) may be considered, in accordance with
                  criteria established by the Administrator, as equally effective for such purposes.

             (vii)  Inspection of emission control diagnostic systems and the maintenance or repair
                  of malfunctions  or system deterioration identified by or affecting such diagnostics
                  systems.

       Each State shall biennially prepare a report to the Administrator which assesses the emission
       reductions achieved by the program required under this paragraph based on data collected
       during inspection and repair of vehicles. The methods used to assess the emission reductions
       shall be those established by the Administrator.
Section Two
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                              OVERVIEW OF I/M RULE

Preface

This section provides a condensed version of EPA's Inspection/Maintenance rule, published in the
Federal Register on November 5, 1992.

Background

The control of in-use motor vehicle emissions is crucial to the attainment of clean air. While motor
vehicle manufacturers have made tremendous advances in emission control technology, cars and
trucks still account for about half of the ozone air pollution and nearly all of the carbon monoxide
(CO) air pollution in United States cities, with 10% to 30% of in-use vehicles causing the bulk of the
problem. Inspection and Maintenance (I/M) programs reduce mobile source emissions by
identifying in-use vehicles in need of engine or emission control repairs.

The Environmental Protection Agency (EPA) has had oversight and policy development
responsibility for I/M programs since the passage of the Clean Air Act in 1970, which included I/M
as an option for improving air quality. With the passage of the 1977 amendments to the Clean Air
Act, I/M was mandated for certain areas with long term air quality problems, while the 1990
amendments to the Clean Air Act (the Act) expand I/M's role as an attainment strategy and require
EPA to develop different performance standards for "basic" and "enhanced" I/M programs. The
performance standard is the minimum amount of emission reductions a program must achieve, based
on a model or benchmark program design. In addition, the Act directs EPA to address requirements
for specific design elements and program implementation issues for both basic and enhanced
programs. The provisions of the  regulation addressing these requirements are summarized below.

Applicability

The Act contains assorted requirements for ozone transport regions (OTR) and specifically
establishes one such region in the Northeastern United States, covering Connecticut, Delaware,
Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode
Island, Vermont, and the Consolidated Metropolitan Statistical Area (CMSA) that includes the
District of Columbia.  Within an OTR, enhanced I/M is required in any metropolitan statistical area
(MSA) with a 1990 population of 100,000 or more, regardless of a given area's attainment
classification. In the case of a multi-state MSA, enhanced I/M is required in all OTR portions if the
sum of these portions equals a population of 100,000 or more, irrespective of the population of the
individual OTR state portion.

Outside of an OTR, any area having a 1980 Census-defined urbanized area population of 200,000 or
more that has been designated serious or worse ozone nonattainment or moderate to serious CO
nonattainment (with a design value greater than 12.7 ppm) must implement enhanced I/M in the 1990
Census-defined urbanized area (at a minimum). Basic I/M must be implemented in 1990 Census-
defined urbanized  areas with populations of less than 200,000 that have been designated as serious
or worse ozone nonattainment or  as CO nonattainment with a design value greater than 12.7 ppm.
All areas designated as marginal ozone nonattainment or moderate CO nonattainment must continue
operating programs that were part of an approved SIP as of November 15, 1990 and, where
necessary, must upgrade such programs to meet the requirements of a basic I/M program. In
addition, any moderate ozone area must implement a basic I/M program in the 1990 Census-defined
urbanized area.

Program coverage is to be MSA-wide and county-wide in subject MSAs in an OTR, except that
some rural counties with population densities of less than 200 persons per square mile (as defined by
the 1990 Census) can be excluded, as long as at least 50% of the MSA is covered.  Outside of an
OTR, programs must nominally cover the entire 1990 Census-defined urbanized area. Exclusion of


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 some urban population is allowed as long as an equal number of non-urban residents within the
 subject MSA are included to compensate for the exclusion. Expansion of the program beyond the
 required population can no longer be used to demonstrate compliance with the performance standard,
 but could be used for offsets or could be applied to the reasonable further progress (RFP)
 requirements of the Act.

 Performance Standard

 The performance standard allows states flexibility in designing I/M programs as long as such
 programs result in the same or lower emission target from mobile sources as that achieved by  the
 relevant model program.  SIP demonstrations are to be made with the most current MOBILE model
 or an alternative approved by the Administrator. Areas shall meet the performance standard for the
 pollutants which cause them to be subject to I/M. For enhanced I/M areas designated nonattainment
 for ozone, the performance standard must be met for both NOx and VOCs. Basic ozone
 nonattainment areas must meet the VOC performance standard and prevent NOx increases. If the
 Administrator finds that NOx emission reductions are not beneficial in a given ozone nonattainment
 area, then NOx emission targets will not be required to be met by the I/M program for that area.

 The basic I/M performance standard is based upon the original New Jersey program and remains
 essentially unchanged from prior to enactment as a result of EPA's new regulation.  The model
 program includes annual, centralized idle tailpipe testing of model year 1968 and later light duty
 vehicles (LDV). The standard does not include testing of heavy duty vehicles or inspection of
 emission control devices. It also assumes no waivers and full compliance.  Programs must be
 designed such that NOx emission increases, overall, do not occur.

 The enhanced modelprogram is based on annual, centralized testing of all model year 1968 and later
 LDVs and light duty trucks (LDT).  Steady-state testing is performed on 1968 through  1985 model
 year vehicles, while 1986 and later model year vehicles are subject to transient tailpipe emission
 testing(M240) and transient evaporative system purge testing.  1983 and later model year vehicles
 also receive evaporative system pressure tests, while 1984 and later model year vehicles are visually
 inspected for the presence and proper connection of the catalyst and fuel inlet restrictor. The steady-
 state cutpoints for 1981-1985 model year light duty vehicles are 1.2% CO, 220 ppm HC, and 6%
 CO+CO2. The rule also specifies performance standard cutpoints for the IM240. (Recommended
 IM240 cutpoints can be found in Section Three.)

 The enhanced I/M standard includes on-road testing of at least 0.5% of the subject vehicle
 population, or 20,000 vehicles, whichever is less.  The Act also requires testing of a vehicle's
 onboard diagnostic systems (OBD) for both basic and enhanced programs. EPA will revise relevant
 sections of its I/M regulation once OBD regulations have been finalized.

 Network Type

Enhanced programs must implement a centralized, test-only network unless the state can demonstrate
that a decentralized program will be equally effective in achieving the performance standard, based
on past performance. The demonstration has to include, at a minimum, surveys to access the
effectiveness of repairs, rates of tampering,  and effectiveness of inspectors at identifying vehicles in
need of repair.  EPA is not aware of any program that could make this demonstration.  A network
consisting of testing facilities in which owners and employees only perform official I/M testing
(which may include safety-related inspections) and are contractually or legally barred from engaging
in motor vehicle repair or service will be considered equally effective to a centralized program.
Network design can be test-only or test-and-repair in basic areas, as long as the performance
standard is met.

MOBILE model credits for test-and-repair networks are assumed to be 50% less than for a test-only
network for the tailpipe emission test, purge test, evaporative system pressure test, catalyst, and gas


Section Two                                                                        Page 11,,

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cap checks; and 75% less for the evaporative canister checks, PCV checks, and air system check.
Basic and enhanced I/M areas can receive more prospective SIP credit if the state can demonstrate
that past performance supports such additional credit, as described above.  Hybrid programs will be
modeled based upon the percentage of the fleet tested in test-only versus test-and-repair type
facilities.

All I/M programs are required to submit biennial program evaluations to quantify the emission
reduction benefits of the program.  In enhanced areas, a random, representative sample of at least
0.1 % of the subject vehicles shall receive a state-administered or monitored IM240 as part of this
evaluation.

Adequate Tools and  Resources

A portion of the test fee or a separately assessed per vehicle fee must be placed in a dedicated fund
and retained on an annual basis to finance program oversight, management, personnel, and capital
expenditures.  Alternatives to this approach are acceptable provided the state can demonstrate mat
adequate funding can be maintained in some other fashion besides reliance on future uncommitted
annual or biennial appropriations from the state or local general fund. The SIP must include a
detailed program budget, including personnel allocations.

Test Frequency and Vehicle Coverage

Both I/M performance standards include annual testing (as required by the Act) of 1968 and later
LDVs, while only the enhanced I/M standard includes LDTs to 8,500 pounds  GVWR. Subject
vehicles are comprised of vehicles registered or required to be registered and fleets primarily operated
within the I/M program area, including leased vehicles and those operated on Federal installations
located in the I/M area. Vehicles registered in the program area but primarily operated in another I/M
area are to be tested in one or the other of the I/M areas.  Alternative vehicle testing schedules  and
coverage options can be approved, provided the required emission reductions are achieved. EPA
encourages biennial testing as a cost effective alternative to annual testing.

Test Procedures and  Standards

Valid I/M test procedures include idle, two-speed, steady-state loaded, and transient tailpipe emission
testing(IM240), visual emission control device inspections, and purge and pressure testing of the
evaporative system.  Alternative test procedures may be approved if they can be shown to be
equivalent or better in minimizing false failures, correlating to the Federal Test Procedure, and lead to
fleetwide emission levels equal to or lower than those achieved by the applicable performance
standard.  All I/M programs regardless of the tests used are required to implement procedures to
ensure accurate testing, allow owner observation of the tests, ensure completion of official tests,
provide for use of proper equipment and its calibration, prevent the testing of vehicles in unsafe
condition or with missing or leaking exhaust systems, and ensure proper retesting of failed vehicles.

HC, CO, and CO+CO2 pass/fail standards are to apply to all vehicles and repairs are required for
failure of any standard, regardless of the attainment status of the area. NOx pass/fail standards are to
apply to vehicles subject to a transient test in ozone nonattainment areas or in an OTR, unless a
waiver of NOx control requirements is approved by the Administrator.  Pass/fail standards for the
visual inspection, pressure and purge tests are given.

Test Equipment

Equipment is to be tested and certified by the program before it is used. The equipment must be able
to test all subject vehicles, be adaptable to new technology vehicles, and be automated to the highest
degree possible to prevent tampering and abuse and to ensure test integrity. The system must
generate, a test record for the vehicle owner that includes unique vehicle information, the applicable


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 standards, the results of the tests conducted, warranty information, certification that the tests were
 conducted in compliance with program requirements, and information concerning possible causes of
 the specific pattern of high emissions found during the test. The pass/fail decisions for all
 measurements must be automatic. The data are to be recorded to an electronic medium, and the
 system is to regularly perform self checks for recording and calibration accuracy and system
 integrity. Automatic lockouts should occur if the system is tampered with or if quality control checks
 are not performed or are failed.  Test systems in enhanced areas must include a real-time data link to
 a host computer to ensure test accuracy and prevent unauthorized multiple initial tests.  All manual
 data entry must be verified.

 Quality Control

 The regulation includes minimum quality control (QC) requirements to be met by all I/M programs,
 as well as specific requirements for enhanced I/M programs. The measures addressed include^
 periodic test equipment checks, calibration and maintenance requirements, accuracy specifications,
 QC record keeping requirements, frequency requirements for QC checks, process automation
 requirements, and document security requirements. Calibration gas specifications are also detailed.
 Alternatives or exceptions to the procedures or frequencies may be approved by the Administrator
 based-on a demonstration, including control chart analysis, of equivalent performance.

 Waivers

 Programs may issue waivers to allow motorists to complete the I/M program requirements without
 meeting the applicable test standards, provided minimum requirements are met including a minimum
 expenditure for relevant repairs.  The cost of repairs covered by warranty, tampering-related repairs
 and repairs not performed by a repair technician cannot be assigned to meeting the minimum
 expenditure, except that repairs for pre-1980 model year vehicles can be made by non-technicians. A
 visual check is required to determine that repairs were actually made on vehicles for which waivers
 are sought. For basic I/M programs, the minimum expenditure is $75 for pre-81 vehicles and $200
 for 1981 and later vehicles; for enhanced I/M programs, the minimum expenditure is $450, adjusted
 annually based upon the Consumer Price Index. One-time-only time extensions not exceeding one
 inspection cycle  may be granted in the case of economic hardship, but must be tracked and reported
 by the program.  Waivers can be issued for less than $450 if a program is established to scrap
 vehicles that do not meet standards after the lower expenditure is made.

 Programs are required to quality control waiver issuance. In enhanced programs, waivers may only
 be issued by the  state agency (or its contractor), i.e., inspectors cannot issue waivers.  In basic
 programs, inspectors in stations and lanes may issue waivers, provided comprehensive quality
 assurance procedures are in place to minimize abuse of the waiver system. All programs must
 inform vehicle owners of potential warranty coverage, insure that repair receipts cannot be revised or
 reused, insure that waivers are only valid for one test cycle, and track, manage and account for time
 extensions or exemptions to the prevent the improper issuance or use of waivers. The SIP must
 include a maximum waiver rate to be used in the MOBILE analysis to estimate the emission
 reductions from the program, with corrective action or SIP revision required if the  waiver rate
 exceeds the rate modeled.

 Motorist Compliance Enforcement

I/M programs must be enforced through registration denial, unless an existing alternative is proven
more effective (in the case of enhanced programs) or as effective (in the case of basic programs); no
alternative to registration denial is allowed in newly implementing I/M programs subject to enhanced
requirements.  Existing sticker-based and computer-matching enforcement programs are the
alternative enforcement mechanisms which may be able to meet the Act's requirements.
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 "Registration denial" means a subject vehicle cannot be registered in an I/M area without first
 establishing proof of compliance with all applicable I/M program requirements.  Pursuant to
 &207(g)(3) of the Act, the regulation does not require new vehicles to receive emission testing prior
 to initial retail sale. Minimum requirements for a registration-based enforcement program include:
 easy visual confirmation of a vehicle's compliance status; a dated compliance certificate which is
 linked to a specific operator and vehicle; routine citations for operating a vehicle with expired or
 missing license plates or tags and/or no or expired registration; provision for enforcement by officials
 other than police (e.g., parking meter attendants) and the citing of parked vehicles; validation of
 registration changes that would change a vehicle's status from subject to exempt; strict limits on and
 accounting of exemptions from the testing/registration requirements; and, assurance that vehicle
 registrations are changed upon moving into an I/M area.

 A state considering an alternative enforcement mechanism must demonstrate its equal or superior
 effectiveness of past performance by comparing the percentage of I/M subject vehicles actually in
 compliance to the percentage of vehicles complying with the registration requirement.  Additionally,
 sticker-enforced programs must assess the extent to which using stolen, counterfeit, safety only, or
 expired stickers is a problem.  Also, the sticker or identifier used must be clearly visible,
 unambiguously indicate compliance status, be difficult to counterfeit or steal, and its absence from
 subject vehicles must result  in significant, monetary fines. States pursuing sticker enforcement must
 also conduct annual, random samples of at least 10% or 10,000 vehicles (whichever is less) as a
 backup assessment of the compliance rate.

 States pursuing computer-matching enforcement must demonstrate that at least 90% of the subject
 fleet is in compliance within 4 months of the compliance deadline, with significant monetary
 penalties for non-cornpliance beyond 4 months, and prevention of vehicle operation for continued
 noncompliance. All initial notices, warnings, notices of violation and penalty notices must be
 tracked and reported monthly. The number and percentage of vehicles that never comply (as a result
 of being junked or moved from the I/M area) must be assessed.

 Motorist Compliance Enforcement Program Oversight

 Oversight of the motorist compliance enforcement program is required, including quality assurance,
 quality control, and information management activities. These activities include: verification and
 tracking of vehicle exemptions through physical examination, facilitation of accurate test data,
 maintenance of an audit trail for all enforcement activities, establishment of written procedures for
 enforcement personnel (including registration personnel), procedures for disciplining, retraining, or
 replacing personnel not following established procedures, and prevention of the fraudulent use of
 inspection documents.  Programs are to evaluate motorist compliance program effectiveness, which
 requires periodic auditing of test and compliance records, determination of the subject vehicle
 population, comparison of the testing data base and the registration data base to determine
 compliance, comparison of these data bases to "red flag" potential non-compliance, and sampling of
 the in-use fleet.

 Quality Assurance

 All I/M programs must be quality assured by performing regular audits - both overt and covert.  At
 least two overt audits per test lane must be conducted per year including equipment audits, checks of
 document security, record keeping, licensing and display information, and evaluation of the
 inspector's ability to properly perform an inspection. Screening or review of inspector and station
 records is required at least monthly to identify problems that may indicate potential fraud or
 incompetence and indicate the need for additional audits.  The review is to include computerized
analysis, with on-site review of non-covered records, to identify statistical  inconsistencies, unusual
patterns, and other discrepancies, and should provide for comprehensive accounting of forms that
can be used to demonstrate compliance.
Section Two                                                                          _    ,.
                                                                                    Page 14

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 Covert audits using vehicles set to fail are required at least once per year per the number of
 inspectors.  In test-and-repair networks, covert audits are to be conducted at least once per station per
 year, and are to include the purchase of repairs and retesting if the vehicle is properly failed. The
 program must use a sufficient number of covert vehicles and auditors to avoid detection; the vehicles
 should cover the range of vehicle technology groups (e.g., carbureted and fuel-injected).  Auditors
 must be trained in program basics including the use of analyzers, air pollution control basics,
 emissions-related engine repair, emission control systems, evidence gathering, administrative
 procedures, applicable laws, and quality assurance practices.  The auditors themselves are to be
 audited at least once annually.

 Enforcement Against Contractors. Stations, and Inspectors

 The regulation requires programs to develop and submit as part of the SIP penalty schedules setting
 minimum penalties for violations of program requirements. In the case of contracted systems, the
 state may use compensation retainage in lieu of penalties.  Inspectors who intentionally pass a failing
 vehicle will have their licenses suspended for a minimum of six months. Adequate legal authority to
 effectively enforce the penalty schedule is required.  Quality assurance personnel must have the
 authority to immediately, temporarily suspend station or inspector licenses for violations (with
 supervisory approval). A hearing must be held within 14 days of a written request from the station
 or inspector, or the temporary suspension will automatically lapse. If a state's constitution precludes
 such authority to immediately suspend, the program must demonstrate adequate resources and
 mechanisms to process violations within three business days. The SIP is to describe the
 administrative and judicial procedures and responsibilities relevant to the enforcement process.

 Data Collection. Analysis  and Reporting

 Accurate data collection is essential to the management, evaluation, enforcement, and oversight of a
 state's program and provides vital information to both the program management and EPA. The
 regulation therefore requires data analysis and reporting, including summary statistics and
 effectiveness evaluations of the enforcement mechanism, the quality assurance system, the quality
 control program, and the vehicle testing element of the program.  Test data including specific vehicle
 and station identification are to be collected  to allow the linking of specific test results to a  specific
 vehicle, test site and inspector, and to assess whether correct test procedures were followed.
 Summaries of this data must be submitted to EPA annually. A biennial report detailing any changes
 made to the program over the two year period as well as any weaknesses discovered and the
 improvements made or corrective actions taken, including the results of those actions, and any future
 actions planned, must be submitted. Initial  submission of the required annual reports must be within
 18 months of implementation of the program, and the biennial report must be submitted within 30
 months of the initial implementation of the program.

 Inspector Training and Licensing or Certification

 All inspectors are to be trained and licensed or certified in  order to perform inspections. The state is
 responsible for administering or overseeing  inspector training; employers may not be responsible for
 the certification or licensing of their own employees. The  curriculum is to cover the causes and
effects of air pollution; the purpose, rules, procedures, and technical details of the test program;
emission control device function, configuration, and inspection; equipment calibration, operation,
and maintenance; public relations; and safety and health issues related to the inspection process.
Inspectors must pass a written test covering this information, and a hands-on test demonstrating the
ability to properly conduct an inspection without assistance. Licenses and certifications can only be
valid for up to two years, at which point refresher training and retesting is required. Alternative
approaches based on more comprehensive skill examination and determination of inspector
competency may be used.
Section Two                                                                          Pa«e 15

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 Public Information and Consumer Protection

 Public information and consumer protection plans are required. Measures must include a mechanism
 whereby vehicle owners can challenge the results of an inspection. In addition, states are to inform
 the public of the air quality problem, the role of motor vehicles in the air quality problem, the need
 for and benefits of an inspection program, and how to maintain a vehicle in a low-emission
 condition.  In enhanced areas, motorists that fail the test should be given assistance in finding a
 qualified mechanic and should be provided with software generated interpretive diagnostic
 information. Other required measures include protection of whistle blowers, processes for
 following up on complaints, and assistance for owners in obtaining warranty covered repairs for
 eligible vehicles.

 Improving Repair Effectiveness

 The state is to insure that adequate training for mechanics performing emission control repairs'exists.
 In addition, the regulation requires that the oversight agency assist the repair industry with
 information related to vehicle diagnosis and repair, and with technical and legal questions that may
 arise. In enhanced areas, performance monitoring of the repair service facilities is required, so that
 motorists who fail the test are provided with information on the success of individual service
 facilities in repairing vehicles to pass.  This information is to be provided to the public as well as to
 service providers.

 Compliance with Recall Notices

 The state must be able to determine a recalled vehicle's compliance status.  Owners or lessees of
 vehicles designated as unresolved are required to provide proof of recall compliance before being
 allowed to  complete the registration or inspection process.  The state shall report recall compliance
 statistics to EPA annually. The recall compliance requirements apply only to enhanced areas and go
 into effect for recalls with owner notification after January  1, 1995.

 On-road Testing

 The Act requires on-road testing in enhanced I/M areas. The regulation specifies that at least 0.5% or
 20,000 vehicles, whichever is less, of the subject fleet shall be on-road tested, either through the use
 of remote sensing devices or through road-side pullovers. Owners  of high emitting vehicles that
 have previously passed a normal periodic test or retest are to be notified that the vehicles are required
 to pass an out-of-cycle follow-up inspection. Emission credit for on-road testing will be granted to
 the extent the on-road testing lowers the fleetwide emission level below what is achieved by other
 elements of the I/M program.  The SIP must include technical support for the claimed additional
 emission reductions.

 State Implementation Plan Submissions

 By November 15,  1992, states are to submit a SIP revision which includes a formal commitment
 from the Governor to implement an I/M program meeting the requirements of the regulation and a
 schedule describing milestones leading to full implementation of mandatory testing. By November
 15, 1993, states are to submit complete SBPs including the necessary legal authority, final
 regulations, a description of each of the program elements required to be developed in the
 implementation schedule, and a detailed description of each of the design elements required by the
regulation,  including plans to address federal facility compliance. The SIP is to include an emission
reduction analysis of the program using the most current emission factor model to demonstrate
achievement of the performance standard.
Section Two                                                                           Page 16

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 Implementation Deadlines

 Basic I/M programs must be implemented as expeditiously as practicable, with full implementation
 by January 1, 1994 for decentralized programs and July 1, 1994 for centralized programs.
 Additional phase-in time may be granted for areas opting for enhanced I/M. All requirements relating
 to enhanced I/M shall be implemented in 1995.  Areas may phase in the change between January of
 1995 and January of 1996, such that at least 30% of subject vehicles participate in the test-only
 program and be subject to the new test procedures beginning in 1995, with full  participation in the
 test-only network by January of 1996. In states with multiple I/M areas, implementation is not
 required in every area by January 1995 as long as statewide, 30% of the subject vehicles are in a test-
 only system. During the phase-in period, all requirements of the regulation are  applicable to the test-
 only portion of the program; existing requirements may continue to apply for the test-and-repair
 portion of the program until it is phased out.
Section Two                                                                          Pa8e 17

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                 SANCTIONS  REQUIRED BY THE CLEAN AIR ACT
 What Triggers The Sanctions Process?
    »  Failure to submit a required plan
         •  I/M Committal SIPs were due 11/15/92
         •  I/M plans were due 11/15/93
    »  Failure to implement a required program
       •  Basic I/M Deadline      test-and-repair systems January 1994
                                 test-only systems July 1994
       •  Enhanced I/M Deadline   30% of fleet in 1995
                                 100% of fleet starting January 1996
    »  Findings Letter
       •  EPA sends a letter to the Governor making a finding of failure to submit or implement
 When Will Sanctions Take  Effect?
    »  Sooner
       •  EPA has discretionary authority to impose sanctions any time after a finding (§ 110(m))
       •  Such authority has been used in the past when a state has failed to make good faith efforts
          to comply
    »  Later
       •   EPA must by law (§ 179(a)) impose sanctions as follows:
          -    18 months after finding: Offset ratios of 2:1 for new or modified sources § 179(b)(2)
          -    24 months after finding: Highway Funding Limitations  §179(b)(l)
       •   If a state still fails to comply, EPA is required by the Act to promulgate a Federal
          Implementation Plan 24 months after a finding
What Are The Sanctions?
    »   Highway funding limitations   § 179(b)( 1)
       •   Federal highway money can no longer be spent on highway projects or USC §23 grants
       •   Exceptions are made for projects for safety or air quality improvement
    »   Offsets Sanctions  §179(b)(2)
       •   New or modified stationary sources must reduce emissions by 2 pounds (from the
          modified source or another source) for every pound of emissions added (2:1 offsets)
Section Two
                                                                               Page 18

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                           HISTORY  OF I/M SANCTIONS

EPA has imposed sanctions in nine states for failure to submit I/M plans or implement I/M programs.
              California (six major metropolitan areas)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sewage Treatment Grant Limitations
                    Sanctions Removed

              Kentucky (Kenton and Campbell Counties)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sewage Treatment Grant Limitations
                    Sanctions Removed

              Pennsylvania (Philadelphia)
                    Highway Funding Limitations
                    Sanctions Removed

              Colorado (Denver)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sewage Treatment Grant Limitations
                    Sanctions Removed

              Tennessee (Nashville)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sanctions Removed

              Oregon (Medford)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sewage Treatment Grant Limitations
                    Sanctions Removed"

              New Mexico (Albuquerque)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sanctions Removed

              Ohio (Cleveland)
                    Construction Moratorium
                    Highway Funding Limitations
                    Sanctions Removed

              Vermont (Burlington)
                    Offset Sanctions
12/12/80
12/12/80
12/12/80
10/18/82
9/22/80
12/12/80
12/12/80
10/28/86
1/22/82
5/6/83
5/2/80
5/2/80
5/2/80
7/16/80
4/5/84
4/5/84
7/31/84
9/11/84
5/3/85
5/3/85
6/25/85
4/3/85
4/3/85
9/23/88
1/9/89
1/9/89
3/14/89
9/4/94
Section Two
                                                                               Page 19

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         MANDATORY SANCTIONS SCHEDULED TO GO INTO EFFECT

The following areas currently have mandatory sanctions clocks running for I/M.  These sanctions
will automatically go into effect if the state does not submit an I/M plan. No further action is
required by EPA before sanctions go into effect - only state action can stop sanctions.
State
California
Delaware
District of Columbia
Georgia
Illinois
Indiana
Louisiana
Maryland
Massachusetts
New Jersey
New Mexico
Rhode Island
Vermont
Virginia
Washington
Date Finding
Made
12/30/93
1/14/94
1/14/94
12/30/93
12/30/93
12/30/93
2/22/94
1/14/94
1/26/94
2/2/94
1/14/94
1/26/94
1/15/93
1/21/94
5/6/94
Date of Offset
Sanctions
6/30/95
7/15/95
7/15/95
6/30/95
6/30/95
6/30/95
8/23/95
7/15/95
7/27/95
8/2/95
7/15/95
7/27/95
In Effect
7/22/95
1 1/4/95
Date of
Highway
Sanctions
12/30/95
1/14/96
1/14/96
12/30/95
12/30/95
12/30/95
2/22/96
1/14/96
1/26/96
2/2/96
1/14/96
1/26/96
3/6/95
1/21/96
5/5/96
Section Two
                                                                                Page 20

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                         Section   Three
              Facts  And  Figures  On  I/M



The section provides basic information on the number of areas, vehicles, and people that will benefit
from the I/M program. It also provides an area-by-area description of the I/M program designs that
states have selected, along with information on the status of implementation. EPA periodically
issues separate updates of each of the documents in this section, he materials presented in this
document are subject to periodic revision by EPA. Updated versions of these documents may be
obtained by sending a fax to the I/M Section at 313-668-4497 or by writing to:

                                  U.S. EPA
                                  I/M Section
                              2565 Plymouth Road
                            Ann Arbor, Michigan 48015

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             CITIES AND STATES REQUIRED TO IMPLEMENT I/M

Cities
Cities Implementing Basic
Basic Cities Opting Up to Enhanced
Enhanced Required Cities
Total Cities Implementing I/M
States
States Implementing Only Basic
Basic States Opting Up to Enhanced
States Implementing Basic & Enhanced
States Implementing Only Enhanced
Total States Implementing I/M
Operating
58
24
58
140
8
12
5
U
36
Not Operating
7
6
26
39
1
1
2
Total
65
30
84
179
9
12
5
12
38
                                BASIC I/M AREAS

                      Currently Operating Basic Programs (75)
Albuquerque, NM
Alton, IL*
Anchorage, AK
Antioch-Pittsburg, CA
Aurora, IL *
Beaumont, TX
Boise, ID °
Bristol, CT *
Cincinnati, OH-KY*
Charlotte, NC t £
Chico, CA
Cleveland, OH *
Colorado Springs, CO
Davis, CA
Detroit, MI t
Durham, NC
Elgin, IL *
Fairbanks, AK
Fairfield, CA
Fort Collins, CO
Fort Lauderdale-Holly wood-
  Pompano Beach, FL f
Gastonia, NC t
Greeley, CO
Greensboro, NC °
Hamilton, OH *
Hemet-San Jacinto, CA
Hesperia-Apple Valley-
  Victorville, CA
High Point, NC °
Indio-Coachella, CA
Jacksonville, FL t
Joliet, IL *
Kenosha, WI *
Lancaster-Palmdale, CA
Lodi, CA
Lompoc, CA
Lorain-Elyria, OH*
Louisville, KY-IN
Medford, OR
Memphis, TN-AR-MS °
Merced, CA
Miami-Hialeah, FL t
Middletown, OH *
Minneapolis-St. Paul, MN
Modesto, CA
Napa, CA
Nashville, TN
Ogden, UT *
Palm Springs, CA
Port-Arthur, TX
Portland-Vancouver, OR-WA
Provo-Orem, UT *
Racine, WI*
Raleigh, NC °
Reno, NV
Round Lake Beach-
  McHenry, IL-WI *
Salinas, CA
Salt Lake City, UT  *t
San Francisco-Oakland, CA t
San Jose, CA
San Luis Obispo, CA
Santa Barbara, CA
Santa Cruz, CA
Santa Maria, CA
Santa Rosa, CA
Seaside-Monterey, CA
Sheboygan, WI
Simi Valley, CA
St. Louis, MO-IL *
Stockton, CA
Tampa-St. Petersburg-
  Clearwater, FL
Tucson, AZ
Vacaville, CA
Visalia, CA
West Palm Beach-Boca
  Raton-Delray Beach, FL T
Winston Salem, NC °
                Basic Areas Currently Not Operating Programs (13)
Akron, OH *               Holland, MI *                       Port Huron, MI t
Ann Arbor MI t            Huntmgton-Ashland, WV-KY-OH °     Richmond, VA
Crystal Lake IL             Muskegon, MI *                     Springfield, OH *
Dayton OH t              Petersburg-Colonial Heights, VA        Toledo, OH-MI t
Grand Rapids, MI *

-------
  Baltimore, MD MSA
  Boulder, CO *
  Dallas-Ft. Worth, TX *
  Denton, TX *
  Denver, CO
    ENHANCED I/M AREAS

Operating Enhanced Programs (13)

  Galveston, TX *
  Houston, TX
  Lewiston-Auburn, ME *
  Lewisville, TX
  Phoenix, AZ *
Portland, ME MSA
Portsmouth-Dover-
  Rochester, NH-ME MSA
Texas City, TX *
              Enhanced Areas Currently Operating Basic Programs (52)
 Allentown-
   Bethlehem, PA-NJ MSA
 Atlanta, GA
 Atlantic City, NJ MSA
 Bakersfield, CA
 Baton Rouge, LA
 Bergen-Passaic, NJ PMSA
 Boston, MA PMSA
 Bridgeport-Milford, CT PMSA
 Brockton, MA PMSA
 Chicago, IL-NW Indiana
 Danbury, CT PMSA
 El Paso, TX-NM
 Fall River, MA-RI PMSA
 Fitchburg-
  Leominster, MA MSA
 Fresno, CA
 Hartford, CT PMSA
 Jersey City, NJ PMSA
  Las Vegas, NV
  Lawrence-Haverhill, MA-NH PMSA
  Los Angeles, CA
  Lowell, MA-NH PMSA
  Middlesex-Somerset-
    Hunterdon, NJ PMSA
  Milwaukee, WI
  Monmouth-Ocean, NJ PMSA
  Nashua, NH PMSA
  Nassau-Suffolk, NY PMSA
  Newark, NJ PMSA
  New Bedford, MA MSA
  New Britain, CT PMSA
  New Haven-Meriden, CT MSA
  New London-Norwich, CT-RI MSA
  New York, NY PMSA
  Norwalk, CT PMSA
  Oxnard-Ventura, CA
  Philadelphia, PA-NJ PMSA *
 Pittsburgh, PA PMSA t
 Pawtucket-Woonsocket-
   Attleboro, RI-MA PMSA
 Riverside-San Bernardino, CA
 Sacramento, CA
 Salem-Gloucester, MA MSA
 San Diego, CA
 Seattle, WA
 Spokane, WA
 Springfield, MA MSA
 Stamford, CT PMSA
 Tacoma, WA
 Trenton, NJ PMSA
 Vineland-Millville-
   Bridgeton, NJ PMSA
 Washington, DC-MD-VA MSA
 Waterbury, CT MSA
 Wilmington, DE-NJ-MD PMSA.
 Worcester, MA MSA
               Enhanced Areas Currently Not Operating Programs (26)
 Albany-Schenectady-
   Troy, NY MSA
 Altoona, PA MSA
 Binghamton, NY MSA'
 Buffalo, NY PMSA
 Burlington, VT MSA °
 Erie, PA MSA
 Glen Falls, NY MSA °
 Hagerstown, MD MSA
 Harrisburg-Lebanon-Carlisle, PA MSA
 Jamestown-Dunkirk, NY MSA °
 Johnstown, PA MSA
 Lancaster, PA MSA
 Manchester, NH MSA
 Niagara Falls, NY PMSA
 Orange County, NY PMSA
 Poughkeepsie, NY MSA
 Providence, RI PMSA
 Reading, PA MSA f
 Rochester, NY MSA'
 Scranton-Wilkes Barre, PA MSA
 Sharon, PA MSA            ^
 State College, PA MSA
 Syracuse, NY MSA
 Utica-Rome, NY MSA'
 Williamsport, PA MSA
 York, PA MSA
This is a list of the Metropolitan Statistical Areas (MS As) and Primary MSAs (PMSAs) in the Ozone
Transport Region and urbanized areas in the rest of the country required to implement I/M. In some
cases, official urbanized area names include more than one state (e.g., El Paso, TX-NM) but not all
states in the name may be required to implement I/M (i.e., only the Texas part of El Paso is required
to implement). The number in parentheses after each sub-heading is the number of cities listed in
that category.  The listing of the number of states doing different types of programs avoids double
counting by listing states with areas that are opting up to enhanced in the opt-up line even though
they might also fit into other categories listed.
0   Attainment area or unclassified for both ozone and carbon monoxide
*   Areas opting up to enhanced
t   Redesignation request submitted for ozone
$   Redesignation request submitted for carbon monoxide
Section Three
                                                 Page3

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	 POPULATION OF AREAS REQUIRED TO IMPLEMENT llMSPFnTTOWMMNTFNANrP
State City Counties Urban Pop County
Alaska 252,726 304,058
Anchorage 221,883
Anchorage Borough* 226,338
Fairbanks 30,843
Fairbanks North Star Borough* 77,720
Arlzona 2,585,474 2,788,981
Phoenix 2,006,239
Maricopa* 2,122,101
Tucson 579,235
Pima* 666,880
California ~ 22,267,187 25,950,442
Bakersfield 302,605
Kem* 543,477
Chico 71,831
Bu«e 182,120
Davis 52,711
Sacramento 1,097,005
El Dorado 125,995
Placer* 172,796
Sacramento 1,041,219
Yolo* 141,092
Fairfield 99,964
Solano* 340,421
Fresno 453,388
Fresno 667,490
Hemet-San Jacinto 90,929
Hesperia-Apple Valley 153,176
Palm Springs 129,025
Riverside-San Bernardino 1,170,196
Riverside* 1,170,413
San Bernardino* 1,418,380
Los Angeles 11,402,946
Lancaster-Palmdale 187,190
Los Angeles* 8,863,164
Oran8e 2,410,556
Lodi 55,590
San Joaquin 480,628
Lompoc 56,591
Santa Barbara 369,608
Merced 64,742
Merced 178,403
Modesto 230,609
Stanislaus* 370,522
Napa 68,049
NaPa 110,765
Oxnard-Ventura 480,482
Ventura* 669,016
State City Counties Urbar
Salinas 122
Monterey
i Pop County
225
355.660
San Diego 2,348.417
San Diego*
2.498.016
San Francisco-Oakland 3,629516
Alameda
Contra Costa
Marin
San Francisco
San Mateo
2,082,914
803,732
230,096
723,959
649,623
Colorado 2,147,263 2,563,290
Boulder 98,910
Boulder
Colorado Springs 352,
El Paso
225,339
989
397,014
Denver 1,517,977
Adams
Arapahoe
Denver
Douglas
Jefferson
Fort Collins 105,
Larimer
265,038
391,511
467,610
60,391
438,430
809
186.136
Greeley 71,578
Weld
Connecticut 3,287
131,821
,116 3,287,116

Delaware
Wilmington, DE-NJ-MD-PA 407,962
New Castle
441,946
District Of Columbia
Washington, DC-MD-VA 606,900
District of Columbia
Florida 5,656
Ft. Lauderdale-Hollywood
-Pompano Beach 1,238
B reward
Miami-Hialeah 1,914
Dade
Tampa-StPetersburg-Clearwater 1 ,708
Hillsborough
Pinellas
West Palm Beach-Boca Raton
606,900
,352 5,741,813

,134
1,255,488
,660
1,937,094
,710
834,054
851,659

-Delray Beach 794,848
Palm Beach


863,518


Section Three
                                                                                                   Page 4

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POPULATION OF AREAS REQUIRED TO IMPLEMENT INSPECTION/MAINTENANCE
State City Counties Urban Pop County
Georgia 2,157,806 2,513,828
Atlanta 2,157,806
Cherokee 90,204
Clayton 182,052
Cobb 447,745
Coweta 53,853
DeKalb 545,837
Douglas 71,120
Fayette 62,415
Fulton 648,951
Gwinnett 352,910
Henry 58,741
Illinois 7,459,942 7,845,016
St. Louis, MO-IL 328,299
Alton 86,236
Madison* 249,238
St. Clair* 262,852
Aurora 192,043
Chicago, IL - IN 6,373,610
Crystal Lake 72,498
Elgin 123,899
Joliet 170,717
Round Lake Beach-McHenry, IL-WI 1 1 2,640
Cook* 5,105,067
DuPage* 781,666
Grundy* 32,337
Kane* 317,471
Kendall* 39,413
Lake* 516,418
McHenry* 183,241
Will* 357,313
Indiana 591,134 756,707
Chicago Area 490,975
Lake 475,594
Porter 128,932
Louisville Area 100,159
Clark 87,777
Floyd 64,404
Kentucky 947,268 999,573
Cincinnati, OH-KY 236,349
Boone 57,589
Campbell 83,866
Kenton 142,031
Huntington- Ashland 56,122
Boyd 51,150
Louisville 654,797
Jefferson 664,937
state City Counties Urban Pop County.
Louisiana
Baton Rouge 365,943
East Baton Rouge Parish 380,105
Maine 205,330 729.087
Lewiston-Auburn 71,598
Androscoggin 105,259
Portland 120,220
13,512
Cumberland 243,135
York 164,587
Other Counties Included
Kennebec 115,904
Knox 36,310
Lincoln 30,357
Sagadahoc 33,535
Maryland 3,392,830 4.363.941
Baltimore 1,889,873 T
Anne Arundel 427,239
Baltimore 692,134
Baltimore City 736,014
Carroll 123,372
Harford 182,132
Howard 187,328
Queen Anne's 33,953
Hagerstown 68,226
Washington 121,393
Washington. DC-MD-VA 1 .420,999
Calvert 51.372
Charles 101.154
Frederick 150.208
Montgomery 757,027
Prince George's 729,268
Wilmington, DE-NJ-MD 13,732
Cecil 71,347
Massachusetts 6,106,425 6,106,42S~"

Michigan 4.302,535 4,760,061"
Detroit 3.697,529 ~T
Macomb 717,400
Oakland 1,083.592
Wayne 2.111.687
Grand Rapids 498.754
Holland
Kent 500,631
Ottowa 187,768
Muskegon 106,252
Muskegon 158.983
Section Three
Pages

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POPULATION OF AREAS REQUIRED TO IMPLEMENT INSPECTION/MAINTENANrF
State City Counties Urban Pop County
Minnesota 2,079,676 2,288,721
Minneapolis-St. Paul 2,079,676
Anoka 243,641
Carver 47,915
Dakota 275,227
Hennepin 1,032,431
Ramsey 485,765
Scott 57,846
Washington 145,896
Missouri 1,618.227 1,774,501
St. Louis 1,618.227
Jefferson 171,380
St. Charles 212,907
St. Louis 993,529
St. Louis City 396,685
Nevada 911,095 996,126
Las Vegas 697,348
Clark* 741,459
Reno 213,747
Washoe 254,667
New Hampshire 313,157 806,156
Manchester 114,918
Nashua 96,791
Hillsborough 336,073
Merrimack 1 20,005
Portsmouth-Dover-RochesterNH-ME 1 0 1 ,448
Rockingham 245,845
Strafford 104,233
New Jersey 7,730,188 7,730,188
New Mexico 497,120 480,577
Albuquerque 497,120
Bernalillo* 480.577
New York 1,726,988 2,439,466
Albany-Schenectady-Troy 509,106
Albany 292,594
Rensselaer 1 54,429
Saratoga 181,276
Schenectady 149,285
Binghamton 158,405
Broomc 212,160
Buffalo-Niagara Falls, NY 954,332
Erie 968,532
Niagara 220,756
Glens Falls 56.475
Warren 59,209
Washington 59,330
Jamestown-Dunkirk 48,670
Chautauqua 141,895
State City Counties Urban Pop County
New York 10,930,132
Bronx 1.203,789
Kings 2.300,664
New York 1.487,536
Putnam 83,941
Queens 1.951,598
Nassau 1,287,348
Orange 307,647
Richmond 378,977
Rockland 265,475
Suffolk 1.321.864
Westchester 874,866
Poughkeepsie 148,527
Dutchess 259,462
Rochester 619,653
Monroe 713,968
Syracuse 388,918
Onondaga 468,973
Utica-Rome 158,553
Oneida 250.836
North Carolina 1,080,514 1.291,741
Charlotte 455.597
Mecklenburg 5 1 1 .433
Durham 205,355
Durham 181,835
Gastonia 113,637
175,093
Raleigh 305,925
Wake 423,380
Ohio 4,325,021 5,039,750
Akron 527,863
Portage 142,585
Summit 514,990
Cincinnati 976,326
Clermont 150,187
Hamilton 866.228
Warren 113,909
Cleveland 1,677,492
Cuyahoga 1,412,140
Geauga 8 1 , 1 29
Lake 215,499
Medina 122,354
Dayton 613,467
Springfield 88.649
Clark 147,584
Greene 136,731
Montgomery 573,809
Ohio continued on next page
Section Three
Page 6

-------
POPULATION OF AREAS REQUIRED TO IMPLEMENT INSPECTION/MAINTENANCE
State City Counties Urban Pop County
Ohio, continued
Hamilton 118,315
Middletown 98,822
Butler 291,479
Lorain-Elyria 224,087
Lorain 271,126
Oregon 1,071,650 1,320,680
Medford 66,974
Jackson 146,389
Portland- Vancouver, OR-WA 1 ,004,676
Clackamas 278,850
Multnomah 583,887
Washington 311,554
Pennsylvania 6,842,565 9,031,865
Allentown-Bethlehem-Easton,PA-NJ 385,619
Lehigh 291,130
Northampton 247,105
Altoona 76,551
Blair 130,542
Erie 177,668
Erie 275,572
Harrisburg-Lebanon-Carlisle 292,904
Cumberland 195,257
Dauphin 237,813
Lebanon 113,744
Johnstown 77,841
Cambria 163,029
Lancaster 193,583
Lancaster 422,822
Philadelphia, PA-NJ 3,277,336
Bucks 541,174
Chester 376,396
Delaware 547,651
Montgomery 678,111
Philadelphia 1,585,577
Pittsburgh 1,678.745
Allegheny 1,336,449
Beaver 186,093
Washington 204,584
Westmoreland 370,321
Reading 186,267
Berks 336,523
Scranton-Wilkes-Barre 388,225
Lackawanna 219.034
Luzerne 328,149
Sharon 46.587
Mercer 121,003
State City Counties Urban Pop County
State College 61,239
Centre 123,786
Williamsport 57,425
Lycoming 118,710
York 142,675
York 339,574
Rhode Island 1,003,464 1,003,464
Tennessee 1,334,546 1. 707,66 T
Memphis, TN-AR-MS 761 ,252
Shelby* 826,330
Nashville 573,294
Davidson • 510,784
Rutherford 118,570
Sumner 103.281
Williamson 81,021
Wilson 67,675
Texas 7,148,268 8.122,612
Beaumont 122,841
Port Arthur 109,560
Jefferson 239.397
Orange
Dallas-Fort Worth 3,198,259
Denton 66,445
Collin 264.036
Dallas 1.852.810
Denton 273.525
Tarrant 1,170,103
ElPaso,TX-NM 562,838
El Paso 591.610
Houston 2.901,851
Galveston 58,263
Texas City 128,211
Brazoria 191,707
Waller 23.390
Chambers 20.088
Montgomery 182,201 :
Liberty 52,726
Fort Bend 225,421 i
Galveston 217,399
Harris 2,818,199
Utah 1.269.150 1,335,817^
Salt Lake City 789,447
Ogden 259,147 i
Davis 187,941
Salt Lake 725.956 \
Weber 158,330 |
Provo-Orem 220.556
Utah 263,590
Section Three
Page?

-------
	 POPULATION OF AREAS REQUIRED TO IMPI.RMF.NT rv«PFrTTON^, INTFN 4Nrw
State City Counties Urban Pop County
Vermont 87,088 124,640
Burlington 87,088
Chittenden 124,640
Virginia 2,028,638 2,157,856
Washington, DC-MD-VA 1,335,132
Arlington 170,936
Fairfax 818,584
Loudoun 86,129
Prince William 215,686
Stafford 61,236
Alexandria City 111,183
Fairfax City 19,622
Falls Church City 9,578
Manassas City 27,957
Manassas Park City 6,734
Richmond 589,980
Petersburg 103,526
Chesterfield 209,274
Henrico 217,881
Richmond City 203,056
Washington 2,687,816 3,158,581
Seattle 1,744,086
King* 1,507,319
Snohomish* 465,642
Spokane 279,038
Spokane* 361,364
Tacoma 497,210
Pierce* 586,203
Portland- Vancouver, OR- WA 167,482
Clark* 238,053
West Virginia 79,681 138,463
Huntington-Ashland, WV-KY-OH 79,681
Cabell 96,827
Wayne 41,636
Wisconsin 1,503,385 1,839,241
Kenosha 94,292
Kenosha 128,181
Milwaukee 1,226,293
Milwaukee 959,275
Ozaukee 72,831
Washington 95,328
Waukesha 304,715
Racine 121,788
Racine 175,034
Sheboygan 61,012
Sheboygan 103,877
State City Counties Urban Pop! Countv
Total Urban Population 108,078,430
Total County Population 120,774,900
Section Three
                                                                                            Page8

-------
        NUMBER OF VEHICLES, STATIONS  AND LANES IN I/M AREAS
State
Alaska
Arizona


California

Colorado


Connecticut
Delaware
D.C.
Florida
Georgia
Illinois
Indiana
Kentucky


Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nevada


>Jew Hampshire
^ew Jersey
^ew Mexico
New York
North Carolina
City
Anchorage and Fairbanks
All areas
Phoenix
Tucson
Enhanced areas
Basic areas
All areas
Denver-Boulde
Other areas
Statewide
Wilmington
Washington
All areas
Atlanta
All areas
All areas
All areas
Cincinnati area
Louisville
Baton Rouge
All areas
All areas
Statewide
Western Michigan
Minneapolis-St. Paul
St. Louis
All areas
Las Vegas
Reno
i// areas
Statewide
Albuquerque
11 areas
Ml areas
Vehicle
Population
210,000
1,768,707
1,355,959
412,748
9,940,000
7,300,000
2,100,000
1,500,000
600,000
2,400,000
330,872
205,891
2,446,964
2,000,000
4,800,000
456,000
714,430
236,430
478,000
261,338
500,000
1,400,000
3,900,000
615,000
1,404,352
1,361,124
768,589
571,589
197,000
622,815
4,800,000
450,000
9,500,000
1,500.000
Type
Basic

Enhanced
Basic
Enhanced
Basic

Enhanced
Basic
Enhanced
Enhanced
Enhanced
Basic
Enhanced
Enhanced
Enhanced

Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Basic
Enhanced

Enhanced
Basic
Enhanced
Enhanced
Basic
Enhanced
Basic
Freq-
uency
A
B
B
B
B
B
M
M
M
B
B
B
A
A
B
B

B
A
B
B
B
B
B
A
B
M
M
A
B
B
B
B
A
Annual
Test
Volume
210,000
884,354
677,980
206,374
5,370,000
3,950,000
1,260,000
900,000
360,000
1,320,000
181,980
113,240
2,446,964
2,000,000
2,640,000
250,800
608,037
130,037
478,000
143,736
275,000
770,000
2,145,000
338,250
1,404,352
748,618
511,374
314,374
197,000
342,548
2,640,000
220,000
5,225,000
1,500,000
Test-only
Stations
na
10
10
na
unknown
na
15
15
na
26
unknown
unknown
32
unknown
unknown
7

unknown
5
unknown
9
19
40 to 60
7
11
unknown
unknown
unknown
na
unknown
unknown
na
74
na
Test-only
Lanes
na
49
49
na
unknown
na
71
71
na
92
unknown
unknown
149
unknown
unknown
21 to 28

unknown
20
unknown
24
87
N/A
23
46
unknown
unknown
unknown
na
unknown
unknown
na
500 to 615
na
                          A = Annual, B = Biennial, M = Mixed
Section Three
Page 9

-------
      NUMBER OF VEHICLES, STATIONS AND LANES IN I/M AREAS
State
Ohio
Oregon
Pennsylvania
Rhode Island
Tennessee


Texas




Utah
Vermont
Virginia


Washington



Wisconsin
City
All areas
Portland and Medford
All areas
Statewide
All areas
Memphis
Nashville
All areas
Beaumont-Port Arthur
Dallas-Fort Worth
El Paso
Houston-Galveston
All areas
Burlington
All areas
Washington, DC area
Other areas
All areas
Seattle-Tacoma
Spokane
Portland- Vancouver
All areas
Vehicle
Population
5,549,311
758,000
5,920,193
550,000

unknown
676,572
6,500,000
245,590
2,830,830
363,842
2,812,811
856,725
90,000
unknown
600,000
unknown
1,200,000
2,200,000
290,000
260,000
914,438
Type
Enhanced
Basic
Enhanced
Enhanced

Basic
Basic

Basic
Enhanced
Enhanced
Enhanced
Basic
Enhanced

Enhanced
Basic

Enhanced
Enhanced
Basic
Enhanced
Freq-
uency
B
B
B
B
A
A
A
B
B
B
B
B
A
B
M
B
A
B
B
B
B
B
Annual
Test
Volume
3,030,335
400,000
3,256,106
302,500


676,572
3^75,000
135,000
1,513,500
194,600
1,513,500
856,725
49,500

325,000
unknown
660,000
1,189,000
156,000
140,000
502,941
Test-only
Stations
45
7
86
unknown
unknown
unknown
unknown
60
3
25
4
28
na
unknown

unknown
na
unknown
16
2
2
11 to 12
Test-only
Lanes
181
24
287
unknown
unknown
unknown
unknown
229
12
104
16
100
na
unknown

unknown
na
unknown
64
8
8
45 to 47
Section Three
                                                             Page 10

-------
                 ENHANCED I/M START DATES
   State
 Arizona
 Colorado
 Connecticut
 Wisconsin
 Indiana
 Illinois
 District Of Columbia
 Ohio
 Georgia
 Maryland
 Missouri
 California
 Delaware
 Louisiana
 Maine
 Massachusetts
 Nevada
 New Hampshire
 New Jersey
 New York
 Pennsylvania
 Rhode Island
 Texas
 Utah
 Vermont
 Virginia
 Washington
IM240  Start Date
January 1995
January 1995
April 1995
July 1995
October 1995
December 1995
January 1996
January 1996
May 1996
June 1996
December 1996
 Overall  Status
 Implemented, Running Smoothly
 Implemented, Running Smoothly
 Phase-in Proceeding Smoothly
 Proceeding Smoothly
 Proceeding Smoothly
 Proceeding Smoothly
 Proceeding, Minor Problems
 Proceeding Smoothly
 Proceeding, Minor Problems
 Enhanced On Hold, Implementing Basic
 On Hold, Evaluating Alternatives
 On Hold, Evaluating Alternatives
 Proceeding Smoothly
 On Hold, Evaluating Alternatives
 Terminated
 On Hold, Evaluating Alternatives
 On Hold, Evaluating Alternatives
 On Hold, Evaluating Alternatives
 Proceeding, Minor Problems
 On Hold, Evaluating Alternatives
 Suspended Until August 1995
 On Hold, Evaluating Alternatives
Terminated
 On Hold, Evaluating Alternatives
On Hold, Evaluating Alternatives
On Hold, Evaluating Alternatives
Implemented, Minor Problems
Section Three
     May  1995
                       Page 11

-------
                                  I/M SIP STATUS
   State
  SIP  Status
                                                                  Prospects
 Florida
 Tennessee
 Arizona
 Texas
 Oregon
 Wisconsin
 New Hampshire
 Minnesota
 Maine
 Colorado
 Pennsylvania
 California
 Illinois
 Indiana
 District Of Columbia
 Maryland
 Virginia
 New Jersey
 New York
 Louisiana
 Washington
 Vermont
 Rhode Island
 Utah
 Georgia
 Massachusetts
 Delaware
 New Mexico
 Ohio
 Nevada
Alaska
North Carolina
Missouri
Connecticut
 Approved 10/11/94
 Approved 10/26/94
 Approved 5/9/95
 Approved 8/22/94
 Approved 9/9/94
 Conditionally Approved 1/12/95
 Conditionally Approved 10/12/94
 Conditionally Approved 10/13/94
 Conditionally Approved 11/3/94
 Conditionally Approved 11/8/94
 Disapproved 4/14/95
 Finding Made 12/30/93
 Finding Made 12/30/93
 Finding Made 12/30/93
 Finding Made 1/14/94
 Finding Made 1/14/94
 Finding Made 1/20/94
 Finding Made 2/2/94
 Finding Made 2/2/94
 Finding Made 2/22/94
 Finding Made 5/6/94
 Sanctions Imposed 9/6/94
 Submitted/Complete 11/94
 Submitted/Complete 11/94
 Submitted/Complete 12/29/94
 Submitted/Complete 12/29/94
 Submitted/Complete 3/3/95
 Submitted/Complete 4/1/95
Submitted/Complete 7/22/94
Submitted/Complete 7/28/94
Submitted/Complete 7/15/94
Submitted/Complete 8/5/94
Submitted/Complete 9/1/94
Submitted/Complete June 1994
 Implemented, Redesignating
 Implemented
 Implemented
 Not Implementing
 Implemented
 Submittal Likely
 Not Implementing
 Submittal Likely
 Not Implementing
 Implemented
 Not Implementing
 Submittal Unlikely
 Submittal Likely
 Submittal Likely
 Submittal Likely
 Submittal Likely
 Submittal Likely
 Submittal Unlikely
 Submittal Unlikely
 Submittal Unlikely
 Submittal Likely
 Submittal Unlikely
 Not Implementing
 Not Implementing
 Not Implementing
 Probably Approvable
 Not Implementing
 Implemented
Probably Approvable
Not Implementing
Probably Approvable
Implemented, Redesignating
Not Implementing
Probably Approvable
   Section Three
                                      May 1995
                                                                            Page 12

-------
                                                 ALASKA
    Areas
  Anchorage
                       Required
                       Basic
            CO Class
           Moderate > 12.7
 Ozone       Status        Start Date
Attainment   Operating Basic       7/85

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
PROGRAM
July 1995
July 1985
Test-and-Repair
$50 max
Annual
Registration Denial
12,000 Ibs.
$450/3500
DESIGN Basic
Tests
Performed







Two Speed
Catalyst
Inlet
Air Pump






1975+
1975+
1975+
1975+





IMPLEMENTATION STATUS Implemented, Minor Problems
Legislation
SIP Status
Air Agency
None Needed
Submitted/Complete 7/15/94
Department of Environmental Conservation
Rule Status
RFP Stage
I/M Agency
Promulgated
Not Applicable


Department Health and Human Services
                                                 ALASKA
    Areas
 Fairbanks
                      Required
                      Basic
           CO  Class
           Moderate
 Ozone        Status       Start Date
Attainment  Operating Basic       7/85
Upgrade Start  Date
Original  Start  Date
     Network Type
          Test  Fee
    Test Frequency
 Enforcement Type
    Weight  Classes
      Waiver Type
July 1995
July 1985
Test-and-Repair
$35 max
Annual
Registration Denial
12,000 Ibs.
$350/$500
PROGRAM DESIGN Basic
                      Tests  Two Speed        1975+
                 Performed  Catalyst          1975+
                             Inlet             1975+
                             Lead Tests        1975+
                             Air Pump        1975+
                             PCV Valve        1975+
                                        IMPLEMENTATION  STATUS  Implemented, Running Smoothly
       Legislation   None Needed                             Rule  Status   Promulgated
       SIP   Status   Submitted/Complete 7/15/94-                RFP   Stage   Not Applicable
       Air Agency   Department of Environmental Conservation     I/M  Agency   North Star Borough
       Page 13
                     I/M Program Design Summary
                                                                                           April 1995

-------
                                  ARIZONA
Areas
Phoenix
Tucson

Upgrade Start Date
Original Start Date
Network Type
Test Fee

Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Required CO Class Ozone Status Start Date
Basic Moderate <12.7 Moderate Operating Enhanced 1/77
Basic Not Classified Attainment Operating Basic 1/77
PROGRAM
January 1995
January 1977
Test-Only
$16.75- $24.50

Biennial
Registration Denial
All vehicles
67-74:$100 75-79:$300 80+:$450
DESIGN High Enhanced, Opt-up
Tests IM240 Phoenix 81+ >8,500 Ibs
Performed Loaded/Idle 81+<8,500lbs
Idle Test 1967+
Purge Phoenix 1981+
Pressure Phoen 1975+
Catalyst 1975+
Inlet 1975+
Air Pump 1975+

IMPLEMENTATION STATUS Implemented, Running Smoothly
Legislation
SIP Status
Air Agency
Signed 11/12/93
Approved 5/9/95
Department of Environmental Quality
Rule Status Promulgated
RFP Stage Contract Signed
I/M Agency Bureau of Vehicular Emissions Inspection
                               CALIFORNIA
Areas
Bakersfield
Fresno
Los Angeles-Long Beach
Oxnard- Ventura- 1000 Oak
Riverside-San Bernardino
Sacramento
San Diego

Upgrade Start Date
Original Start Date March 1984
Network Type Hybrid
Test Fee Unknown
Test Frequency Biennial
Enforcement Type Registration Denial
Weight Classes 14,000 Ibs.
Waiver Type
Required
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
PROGRAM








CO Class Ozone Status
Attainment Serious Operating Basic
Moderate <12.7 Serious Operating Basic
Serious Extreme Operating Basic
Serious Extreme Operating Basic
Serious Extreme Operating Basic
Serious Serious Operating Basic
Moderate < 12.7 Serious Operating Basic
DESIGN Enhanced
Tests Unknown
Performed






Start Date
3/84
3/84
3/84
3/84
3/84
3/84
3/84









IMPLEMENTATION STATUS On Hold, Evaluating Alternatives
Legislation Signed 3/30/94

SIP Status Finding Made 12/30/93
Air Agency California Air Resources Board
Rule Status Not Drafted
RFP Stage Not Drafted
I/M Agency Bureau of Automotive Repair
l_^____^^^__^_^^^^^

•[^•^•^••H
Page 14
I/M Program Design Summary
                                                                     April 1995

-------
                                     CALIFORNIA
Areas
Chico
Davis
Fairfield
Hemet-San Jacinto
Hesperia-Apple Valley
Lompoc
Lancaster-Palmdale
Lodi
Merced
Modesto
Napa
Palm Springs
Salinas
San Francisco-Oakland
Required
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
Basic
CO Class Ozone Status
Moderate < 12.7 Transitional Operating Basic
Moderate <12.7 Serious Operating Basic
Moderate < 12.7 Moderate Operating Basic
Serious Severe Operating Basic
Attainment Severe Operating Basic
Attainment Moderate Operating Basic
Serious Severe Operating Basic
Attainment Serious Operating Basic
Attainment Serious Operating Basic
Moderate < 12.7 Serious Operating Basic
Moderate < 12.7 Moderate Operating Basic
Attainment Severe Operating Basic
Attainment Attainment Operating Basic
Moderate <12.7 Moderate Operating Basic
Start Date
3/91

3/91
3/84
3/91
7/90
7/90
4/88
7/90
7/90
3/84
7/90
1/91
3/84
PROGRAM DESIGN Basic
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
January 1995
March 1984, or later
Test-and-Repair
Market; About $32 with certificate
Biennial
Registration Denial
All vehicles
Cost: $450
Tests Two Speed 1966+
Performed pcv Valve 1967+
Air Pump 1967+
Evap Canister 1970+
ECR Valve 1973+
Catalyst 1975+











IMPLEMENTATION STATUS Proceeding, Minor Problems
Legislation
SIP Status
Air Agency
Signed 3/30/94
Not Submitted, No Finding
California Air Resources Board
Rule Status Not Drafted
RFP Stage Not Applicable
I/M Agency Bureau of Automotive Repair


	
COLORADO
Areas
Boulder
Denver
Required
Basic
Enhanced
CO Class Ozone Status
Moderate > 12.7 Transitional Operating Enhanced
Moderate > 12.7 Transitional Operating Enhanced
Start Date
7/81
1/81

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

PROGRAM
January 1995
July 1981
Test-Only
1982+: $24.25; Pre-1981: $15
Biennial 1982+, Annual Pre-1981
Registration Denial and Sticker
All vehicles
Cost: $450


DESIGN High Enhanced
Tests
Performed


Two Speed
IM240
Catalyst
Inlet
Air Pump
Purge
Pressure


IMPLEMENTATION STATUS Implemented, Running
Legislation
SIP Status
Air Agency
Signed 6/8/93

Conditionally Approved 11/8/94
Department of Health
Rule Status
RFP Stage
I/M Agency
Promulgated
Pre-1982
1982+
1975+
1975+
1975+
1982+
1982+


Smoothly

Awarded December 1993
Department of Revenue
Page 15
I/M Program Design Summary
April 1995

-------
                                     COLORADO
Areas
Colorado Springs
Fort Collins
Greeley

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type





January 1995
July 1981
Test-and-Repair
$15
Annual
Registration/Sticker
All vehicles
Cost: $200
Required
Basic
Basic
Basic
PROGRAM








CO Class Ozone Status
Moderate < 12.7 Attainment Operating Basic
Moderate < 12.7 Attainment Operating Basic
Not Classified Attainment Operating Basic
DESIGN Boric
Tests Idle Test 1968+
Performed Two Speed 1981+
Catalyst 1975+
Inlet 1975+
Air Pump 1975+



Start Date
7/81
7/81
1/81









IMPLEMENTATION STATUS Implemented, Running Smoothly
Legislation
SIP Status
Air Agency
Signed 6/8/93
Submitted/Complete
Department of Health



Rule Status Promulgated
RFP Stage Awarded December 1993
I/M Agency Department of Revenue



CONNECTICUT
Areas
Bridgeport-Milford
Bristol
Danbury
Hartford
New Britain
New Haven-Meridien
New London-Norwich
Norwalk
Stamford
Waterbury

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type












April 1995
January 1983
Test-Only
1981+:$20; 1968-80:
Required
Enhanced
Basic
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
PROGRAM



$15
CO Class Ozone Status
Moderate Severe Operating Basic
Moderate < 12.7 Serious Operating Basic
Moderate > 12.7 Severe Operating Basic
Moderate <1 2.7 Serious Operating Basic
Moderate < 12.7 Serious Operating Basic
Not Classified Serious Operating Basic
Moderate < 12.7 Serious Operating Basic
Moderate > 12.7 Severe Operating Basic
Moderate < 12.7 Serious Operating Basic
Not Classified Serious Operating Basic
DESIGN High Enhanced
Tests Idle. Test 1968+
Performed IM240 1981+
Pressure 1971+
Purge 1981+
Start Date
1/83
1/83
1/83
1/83
1/83
1/83
1/83
1/83
1/83
1/83





Biennial 1981 +. Annual 1968-1980
Registration Suspension
10,000 Ibs.
Cost: $450









IMPLEMENTATION STATUS Phase-in Proceeding Smoothly
Legislation
SIP Status
Air Agency

Signed June 1993

Submitted/Complete June 1994
Department of Environmental Protection

^•••^•^^^^^H
Rule Status Promulgated
RFP Stage Awarded 12/3/93
I/M Agency Department of Motor Vehicles
•Ml^MHMBHHHHH^^^M


w^am^
Page 16
I/M Program Design Summary
                                                                              April 1995

-------
                              DELAWARE
Areas Required CO Class Ozone Status Start Date
Wilmington, DE-NJ-MD Enhanced Attainment Severe Operating Basic 1/83
PROGRAM DESIGN Low Enhanced
Upgrade Start Date
Original Start Date
Network Type

Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
January 1909
January 1983
Test-Only

None
Biennial
Registration Denial
8,500 Ibs.
Cost: $200
IMPLEMENTATION
Passed 11/4/93
Submitted/Complete 3/3/95
Natural Resources and Conservation
Tests
Performed







Idle Test
Pressure
Catalyst
Inlet





1968+
1971+
1975+
1975+





STATUS Proceeding Smoothly
Rule Status
RFP Stage
I/M Agency
Not Drafted
NA
Department Motor


Vehicles
^^••HHH^H
                      DISTRICT OF COLUMBIA
Areas
Required
Washington, DC-MD-VA Enhanced











Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
PROGRAM
January 1996
January 1983
Test-Only
Unknown
Biennial
Registration Denial
26,000 Ibs.
Cost: $450
CO Class Ozone Status Start Date
Moderate < 12.7 Serious Operating Basic 1/83
DESIGN Enhanced
Tests IM240 1977+
Performed Purge ]977+
Pressure 1977+





IMPLEMENTATION STATUS Proceeding, Minor Problems
Legislation
SIP Status
Air Agency
Passed
Finding Made 1/14/94
Consumer and Regulatory Affairs
Rule Status Drafted
RFP Stage NA
I/M Agency Department of Public Works
Page 17
I/M Program Design Summary
April 1995

-------
                                        FLORIDA
Areas Required CO Class Ozone Status Start Date
Miami-Hialeah Basic Attainment Moderate Operating Basic 4/91
Ft. Lauderdale-Hollywood-Pompano Beach Basic Attainment Marginal Operating Basic 4/91
Tampa-St. Petersburg-Clearwater Basic Attainment Marginal Operating Basic 4/91
West Palm Beach-Boca Raton-Dekay Beach Basic Attainment Marginal Operating Basic 4/91
Jacksonville None Attainment Attainment Operating Basic 4/91
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency
PROGRAM DESIGN Basic
April 1991 Tests Idle Test 1975+
April 1991 Performed Catalyst 1980+
Test-Only Met 1980+
$10 Evap/Gas Cap 1980+
Annual
Registration Denial
10.000 Ibs.
Cost: $100/$200
IMPLEMENTATION
Passed
Approved 10/1 1/94
Department of Environmental Regulation
STATUS Implemented, Redesignation Requested
Rule Status Promulgated
RFP Stage Awarded
I/M Agency Highway Safety and Motor Vehicles
                                       GEORGIA
Areas
Atlanta
Required CO Class Ozone Status
Enhanced Attainment Serious Operating Basic
Start Date
4/82
PROGRAM DESIGN Enhanced
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
January 1996
April 1982
Hybrid
Unknown
Annual
Registration Denial
8,500 Ibs.
Cost: $450
Tests ASM
Performed Catalyst
Air Pump
Inlet
Purge
Pressure



First 6
MYRs
7+ MYRs to
1975+
1975+
1975+
1975+
1975+








                                IMPLEMENTATION STATUS Proceeding, Minor Problems
Legislation   Signed Spring 1992                       Rule Status
SIP  Status   Submitted/Complete  12/29/94               RFP  Stage
Air Agency   Department of Natural Resources             I/M Agency  Department of Public Safety
Page 18
I/M Program Design Summary
                                                                                 April 1995

-------
                                                ILLINOIS
Areas
Aurora
Alton
Chicago, 11 - NW Indiana
Crystal Lake
East St. Louis, MO-IL
Elgin
Joliet
Round Lake Beach-McHenry, IL-WI
1
Upgrade Start Date
Original Start Date May 1986
Network Type Test-Only
Test Fee None
Test Frequency Biennial
Required
Basic
Basic
Enhanced
Basic
Basic
Basic
Basic
Basic
PROGRAM




CO Class Ozone Status
Attainment Severe Operating Basic
Attainment Severe Operating Basic
Attainment Severe Operating Basic
Attainment Severe Not Operating
Attainment Moderate Operating Basic
Attainment Severe Operating Basic
Attainment Severe Operating Basic
Attainment Severe Operating Basic
DESIGN Enhanced Opt-up
Tests Idle Test 1968+
Performed ASM 1981+
Purge 1981+
Pressure 1971+
Start Date
1/1/92
NA
5/86
NA
NA
1/1/92
1/1/92
1/1/92





Other On waiver only
Enforcement Type License and Registration Suspension
Weight Classes All vehicles
Waiver Type Cost: $450






IMPLEMENTATION STATUS Proceeding Smoothly
Legislation Signed 1/13/94
SIP Status Finding Made 12/30/93
Air Agency Illinois EPA



Rule Status Proposed 7/2 1/94
RFP Stage Drafted
I/M Agency Illinois EPA


•••••M
                                               INDIANA
  Areas
Chicago Area: Lake & Porter County
Louisville Area:  Clark & Floyd County
 Required
 Enhanced
 Basic
CO  Class
Attainment
Attainment
 Ozone        Status       Start Date
Severe      Operating Basic        6784
Moderate    Operating Basic        6/84









PROGRAM DESIGN High Enhanced, Opt-up
Upgrade Start Date
Original Start Date
Network Type

Test Fee

Test Frequency
Enforcement Type
| Weight Classes
Waiver Type
1





Legislation
SIP Status
Air Agency
October 1995
June 1984
Test-Only

None

Biennial
Registration Denial
9,000 Ibs.
Cost: $450
IMPLEMENTATION
Signed 3/4/94
Finding Made 12/30/93
Department of Environmental Management
Tests
Performed








Idle Test
IM240
Purge
Pressure

Catalyst
Evap/Gas Cap
PCV Valve


1976+
1981+
1981+
1976+

1976+
1976+
1976+


STATUS Proceeding Smoothly
Rule Status
RFP Stage
I/M Agency
Proposed
Awarded June 1994


Department of Environmental Management
      Page 19
l/M Program Design Summary
                                   April 1995

-------
Areas
Louisville
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency

January 1984
January 1984
Test-Only
$8.25
Annual
Subpoena
18,000 Ibs.
Cost: $75/$200
KENTUCKY
Required CO Class Ozone Status Start Date
Basic Attainment Moderate Operating Basic 1/84
PROGRAM DESIGN Basic
Tests Idle Test 1968+
Performed Catalyst 1975+
Air Pump 1975+
Pressure 1976+
IMPLEMENTATION STATUS Implemented, Proceeding Smoothly
None needed Rule Status Promulgated 1/20/93
Submitted/Complete 8/2/94 RFP Stage Contract Awarded
Jefferson Co. Air Pollution Control District I/M Agency Jefferson Co. Air Pollution Control District
   Areas
 Baton Rouge
                                             LOUISIANA
                      Required
                      Enhanced
CO  Class
Attainment
 Ozone
Serious
  Status
Operating Basic
Start  Date
   9/85
Upgrade Start Date
Original  Start Date
     Network  Type
          Test Fee
    Test Frequency
 Enforcement  Type
    Weight  Classes
      Waiver  Type
September 1985
                        PROGRAM  DESIGN Low Enhanced
                                             Tests  Unknown
                                         Performed
                                       IMPLEMENTATION STATUS On Hold, Evaluating Alternatives
       Legislation  Notdrafted                               Rule Status  NotDrafted
       SIP   Status  Finding Made 2/22/94                     RFP  Stage  NotDrafted
       Air Agency  Department of Environmental Quality          I/M Agency  Department of Environmental Quality
       Page 20
                     I/M Program Design Summary
                                                                                         April 1995

-------
                                                  MAINE
    Areas
 Lewiston-Auburn
 Portland
Upgrade Start Date
Original  Start Date
     Network Type
          Test Fee
    Test Frequency
 Enforcement Type
    Weight  Classes
      Waiver Type
  Required
  Basic
  Enhanced
CO  Class
Attainment
Attainment
 Ozone
Moderate
Moderate
    PROGRAM DESIGN Enhanced
                          Tests
                     Performed
   Status
Not Operating
Not Operating
Start  Date
 July 1994
 July 1994
                                        IMPLEMENTATION  STATUS Terminated
       Legislation  Signed                                 Rule Status  Promulgated
       SIP   Status  Conditionally Approved 11/3/94              RFP  Stage  Contract Awarded
       Air Agency  Department of Environmental Protection       I/M Agency  Department of Environmental Protection
                                             MARYLAND
Areas Required CO
Class Ozone Status Start Date
Baltimore Enhanced Moderate < 12.7 Severe Operating Basic 2/84
Hagerstown Enhanced Attainment Attainment Operating Basic na
Washington, DC-MD-V A Enhanced Moderate < 12.7 Serious Operating Basic 2/84
Wilmington, DE-NJ-MD Enhanced Attainment Severe Operating Basic 2/84
PROGRAM DESIGN High Enhanced
Upgrade Start Date June 1996
Original Start Date February 1984
\ Network Type Test-Only
Test Fee $17
Test Frequency Biennial
Enforcement Type Registration Suspension
Weight Classes 26,000 Ibs.
Waiver Type Cost: $250 in 1995, $450 by 1997
IMPLEMENTATION
Legislation Signed
SIP Status Finding Made 1/14/94
Air Agency Department of the Environment
Tests IM240
Performed Idle Test
Purge
Pressure




STATUS Enhanced On Hold,
Rule Status Proposed
RFP Stage Awarded
1983+
1977+
1983+
1977+




Implementing Basic


I/M Agency Department of Transportation
      Page 21
I/M Program Design Summary
                                 April 1995

-------
                           MASSACHUSETTS
Areas
Boston
Brockton
Fall River, MA-RI
Fitchburg-Leominster
Lawrence-Haverhill
Lowell
New Bedford
Salem-Gloucester
Springfield
Worcester
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency
Areas
Detroit
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency

April 1983
Test-Only
Unknown
Biennial
Registration Denial
8,500 Ibs.
Cost: $450
Required
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
PROGRAM
CO Class Ozone
Moderate < 12.7 Serious
Attainment Serious
Attainment Serious
Attainment Serious
Attainment Serious
Not classified Serious
Attainment Serious
Attainment Serious
Nonattainment Serious
Not classified Serious
DESIGN Enhanced
Tests IdleTest
Performed IM240
Purge
Pressure
Status
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
1968+
1981+
1981+
1971+
Start Date
4/83
4/83
4/83
4/83
4/83
4/83
4/83
4/83
4/83
4/83

IMPLEMENTATION STATUS On Hold. Evaluating Alternatives
Signed 1/14/94 Rule Status Drafted
Submitted/Complete 12/29/94 RFP Stage Dnfted
Department of Environmental Protection I/M Agency Registry of Motor Vehicles
MICHIGAN
Required CO Class Ozone
Basic Not classified Attainment
January 1986
January 1986
Test-and-Repair
$10
Annual
Registration Denial
8,500 Ibs.
Cost: $82
PROGRAM
DESIGN Boric
Tests Idle
Performed
Status
Operating
7975+
Start Date
12/85

IMPLEMENTATION STATUS Redesignated
Signed Rule Status Promulgated
Redesignation Effective 4/7/95 RFP Stage N/A
Department of Natural Resources I/M Agency Department of Transportation
Page 22
l/M Program Design Summary
                                                                 April 1995

-------
                                          MINNESOTA
  Areas
Minneapolis-St. Paul
  Required     CO Class     Ozone      Status       Start Date
  Basic         Moderate < 12.7   Attainment  Operating Basic       7/91
PROGRAM DESIGN Basic
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
^MMBHBHIM
July 1991
July 1991
Test-Only
$8
Annual
Registration Denial
8,500 Ibs.
Cost: $75/3200
IMPLEMENTATION
Signed
Conditionally Approved 10/13/94
Pollution Control Agency
Tests
Performed






Idle Test
Catalyst
Inlet
Gas Cap




STATUS Implemented, Running
Rule Status
RFP Stage
[/M Agency
Promulgated
Contract Awarded
1976+
1976+
1976+
1976+




Smoothly


Pollution Control Agency
                                          MISSOURI
Areas
St. Louis












Required CO Class Ozone Status Start Date
Basic Not classified Moderate Operating Basic 1/84
PROGRAM DESIGN Enhanced Opt-up
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
December 1996
January 1984
Test-Only
$24.00 cap
Biennial
Registration Denial
8,500 Ibs.
Cost: $75/$200/$450
IMPLEMENTATION
Signed 6/3/94
Submitted/Complete 9/1/94
Department of Natural Resources
Tests Idle Test
Performed IM240
Purge
Pressure
Full ATP



1971+
1981+
1986+
1981+
Afterfailure



STATUS On Hold, Evaluating Alternatives
Rule Status Adopted 3/30/95
RFP Stage Contract Awarded


I/M Agency State Highway Patrol
     Page 23
I/M Program Design Summary
April 1995

-------
                                                   NEVADA
    Areas
 Las Vegas
                       Required
                       Enhanced
CO  Class
Moderate > 12.7
 Ozone       Status        Start Date
Attainment  Operating Basic       10/83
Upgrade Start Date  January 1996
Original Start Date  October 1983
     Network  Type  Decentralized test-only
           Test Fee
    Test Frequency
 Enforcement  Type
                          PROGRAM DESIGN Enhanced
                                                Tests
                                            Performed
    Weight  Classes
Estimated at $45
1968-1985 Annual;  1986+ Biennial
Registration Denial
All vehicles
                   Idle Test
                   IM240
                   Catalyst
                   Met
                   Air Pump
                   1968-1985
                   1986+
                   1981+
                   1981+
                   1981+
      Waiver Type  Cost:  $450
                                          IMPLEMENTATION  STATUS On Hold, Evaluating Alternatives
       Legislation  Authority bill signed, budget bill needed        Rule Status  Adopted 5/26/94
       SIP  Status  Submitted/Complete 7/28/94                 RFP  Stage  Not Drafted
       Air Agency  Department of Environmental Protection        I/M Agency  Motor Vehicles and Public Safety
                                                  NEVADA
Areas
Reno
Required CO Class Ozone Status Start Date
Basic Moderate < 12.7 Marginal Operating Basic 10/83
PROGRAM DESIGN Boric
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency

Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
January 1995
October 1983
Test-and-Repair
Cap = 35% of shop hourly rate
Annual

Registration Denial
8,500 Ibs.
Owner repairs: $100; Shop: $200
IMPLEMENTATION
Signed
Submitted/Complete 7/28/94
Department of Environmental Protection
Tests
Performed






Two Speed
Catalyst
Inlet
Air Pump
Evap/Gas Cap
EGR



1968+
1981+
1981+
1981+
1981+
1981+



STATUS Proceeding Smoothly
Rule Status
RFP Stage
I/M Agency
Adopted 5/26/94
N/A


Motor Vehicles and Public Safety
       Page 24
                      I/M Program Design Summary
                                    April 1995

-------
                               NEW HAMPSHIRE
Areas
Manchester
Nashua
Portsmouth-Dover-Rochester, NH-ME
Required
Enhanced
Enhanced
Enhanced
CO Class Ozone Status
Nonattainment Marginal Not Operating
Not Classified Serious Operating Basic
Attainment Serious Not Operating
Start Date
na
10/87
na
PROGRAM DESIGN Enhanced
Upgrade Start Date December 1 995
Original Start Date October 1987
Network Type Test-Only
Test Fee Unknown
Test Frequency Biennial
Enforcement Type Registration Suspension
Weight Classes 26,000 Ibs.
Waiver Type Cost: $450





Tests IM240 1981+
Performed Two Speed 1968+
Purge 1981+
Pressure 1979+









IMPLEMENTATION STATUS On Hold, Evaluating Alternatives
Legislation Signed June 1993

SIP Status Conditionally Approved 10/1 2/94
Air Agency Air Resources Division

Areas
Atlantic City
Bergen-Passaic
Monmouth-Ocean
Newark
Trenton
Vineland-Millville-Bridgeton
Jersey City
Middlesex-Somerset-Hunterdon, NJ

NEW
Required
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Rule Status Promulgated
RFP Stage Bids Received
I/M Agency Department of Safety
JERSEY
CO Class Ozone Status
Not Classified Moderate Operating Basic
Moderate < 12.7 Severe Operating Basic
Moderate < 12.7 Severe Operating Basic
Moderate <12.7 Severe Operating Basic
Not Classified Severe Operating Basic
Moderate <12.7 Severe Operating Basic
Moderate <12.7 Severe Operating Basic
Moderate Severe Operating Basic




Start Date
2/74
2/74
2/74
2/74
2/74
2/74
2/74
2/74

Upgrade Start Date
Original Start Date
Network Type

Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
PROGRAM
January 1996
February 1974
Hybrid: Age and Re test Based

Unknown
Biennial
Registration Denial
All
Cost: $450
DESIGN High Enhanced
Tests ASM 1968+
Performed Prison 1971+
Purge 1971+
Catalyst 1975+





IMPLEMENTATION STATUS Proceeding, Minor Problems
Legislation
SIP Status
Air Agency
Awaiting Signature
Finding Made 2/2/94
Dept of Environmental Protection & Energy
Rule Status Not Drafted
RFP Stage Not Drafted
I/M Agency Division of Motor Vehicle Services
Page 25
I/M Program Design Summary
                                                                       April 1995

-------
                                 NEW MEXICO
Areas
Albuquerque

Upgrade Start Date March 1989
Original Start Date March 1989
Network Type Test-and-Repair
Test Fee Market
Test Frequency Biennial
Enforcement Type Registration Denial
Weight Classes 26,000 Ibs.
Required CO Class Ozone Status Start Date
Basic Moderate < 12.7 Attainment Operating Basic
PROGRAM DESIGN Basic
Tests Idle Test 1975+
Performed Catalyst 1975+
Air Pump 1975+
Inlet 1975+



3/89








Waiver Type Time Extensions; cost varies

Legislation Signed Early 1994
SIP Status Finding Made 1/14/94
IMPLEMENTATION STATUS Implemented, Redesignation Expected
Rule Status Promulgated April 13, 1995
RFP Stage Not Applicable



Air Agency Environmental Health Department I/M Agency Environmental Health Department

Areas
Albany-Schenectady-Troy
Binghamton
Buffalo
Glen Falls
Jamestown-Dunkirk
Niagara Falls
New York
Orange County
Poughkeepsie
Rochester
Syracuse
Utica-Rome

Upgrade Start Date January 1996
Original Start Date January 1981
Network Type Test-Only
Test Fee $25
Test Frequency Biennial
Enforcement Type Registration Suspension
Weight Classes 10,000 Ibs.
Waiver Type Cost: $450

Legislation Signed
SIP Status Finding Made 2/2/94
NEW YORK
^••••H
Required CO Class Ozone Status Start Date
Enhanced Attainment Marginal Not Operating
Enhanced Attainment Attainment Not Operating
Enhanced Attainment Marginal Not Operating
Enhanced Attainment Attainment Not Operating
Enhanced Attainment Attainment Not Operating
Enhanced Attainment Marginal Not Operating
Enhanced Moderate > 12.7 Severe Operating Basic
Enhanced Moderate < 12.7 Severe Not Operating
Enhanced ' Attainment Marginal Not Operating
Enhanced Attainment Attainment Not Operating
Enhanced Moderate <12.7 Attainment Not Operating
Enhanced Attainment Attainment Not Operating
PROGRAM DESIGN Enhanced
Tests IM240 1981+
Performed Idle Test 1968+
Catalyst 1975+
Met 1975+
Purge 1981+
Pressure 1971+


IMPLEMENTATION STATUS On Hold, Evaluating Alternatives
Rule Status Emergency Rule Promulgated
RFP Stage Awarded November 1993
na
na
na
na
na
na
1/81
na
na
na
na
na
1











Air Agency Department of Environmental Conservation I/M Agency Department of Motor Vehicles

^— ^—^^^^^^•^M^^^^^HB
•••••
Page 26
I/M Program Design Summary
April 1995

-------
                                          NORTH CAROLINA
   Areas
Charlotte
Durham
Gastonia
Greensboro
High Point
Raleigh
Winston-Salem
Required
Basic
Basic
Basic
Basic
Basic
Basic
Basic
CO Class
Attainment
Moderate < 12.7
Attainment
Moderate < 12.7
Moderate < 12.7
Moderate < 12.7
Moderate < 12.7
Ozone
Attainment
Attainment
Moderate
Attainment
Attainment
Attainment
Attainment
Status
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Operating Basic
Start Date
12/82
11/86
7/92
7/91
1/92
11/86
1/92
PROGRAM DESIGN Boric
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
December 1981
December 1981
Test-and-Repair
$19.50
Annual
Windshield Sticker
All vehicles
Cost: $75/3200
IMPLEMENTATION
None needed
Submitted/Complete 8/5/94
Environmental Health & Natural Resources
Tests Idle Test 1975+
Performed Catalyst 1975+
Inlet 1975+
Air Pump 1975+
PCV Valve 1975+
Evap/Gas Cap 1975+



STATUS Implemented, Redesignation Requested
Rule Status Promulgated July 1993
RFP Stage Not Applicable
I/M Agency Department of Motor Vehicles
                                                    OHIO
   Areas
Akron
Cincinnati
Cleveland
Dayton
Hamilton
Lorain-Elyria
Middletown
Springfield
Toledo, OH-MI
                                            Required
                                            Basic
                                            Basic
                                            Basic
                                            Basic
                                            Basic
                                            Basic
                                            Basic
                                            Basic
                                            Basic
CO  Class
Moderate < 12.7
Attainment
Moderate < 12.7
Attainment
Attainment
Moderate < 12.7
Attainment
Attainment
Attainment
 Ozone
Moderate
Moderate
Moderate
Attainment
Moderate
Moderate
Moderate
Moderate
Attainment
   Status
Operating Basic
Operating Basic
Operating Basic
Not Operating
Operating Basic
Operating Basic
Operating Basic
Not Operating
Not Operating
Start Date
   12/90
   2/88
   2/88
    na
   2/88
   2/88
   2/88
    na
    na
Upgrade Start Date  January 1996
Original Start Date  December 1988
     Network  Type  Test-Only
           Test Fee  $19.50
    Test Frequency  Biennial
 Enforcement  Type  Registration Denial
    Weight Classes  10,000 Ibs.
       Waiver  Type  Pre-81: $100,1981+: $200
                                             PROGRAM  DESIGN Enhanced Opt-up
                                                                    Tests  1M240           25-year window
                                                                Performed  Two Speed        Pre-1981
                                                                           Purge            25-year window
                                                                           Pressure          25-year window
                                         IMPLEMENTATION  STATUS Proceeding Smoothly

      Legislation  Effective 9/22/93                           Rule Status  Effective 6/13/94
      SIP   Status  Submitted/Complete 7/22J94                 RFP  Stage  Issued 2/11/94
      Air  Agency  Ohio EPA                                I/M Agency  Ohio EPA
      Page 27
                                            I/M Program Design Summary
                                                                                             April 1995

-------
                                                 OREGON
    Areas
 Medford
 Portland-Vancouver, OR-WA
   Required
   Basic
   Basic
CO  Class
Moderate < 12.7
Moderate < 12.7
 Ozone
Attainment
Marginal
   Status
Operating Basic
Operating Basic
                                             PROGRAM DESIGN Basic
Upgrade Start Date
Original  Start Date July 1975/January 1986
     Network Type Test-Only
          Test Fee $10
    Test Frequency Biennial
 Enforcement Type Registration Denial
   Weight  Classes 26,000 Ibs.
      Waiver Type None
                           Tests  Two Speed
                      Performed  Cata[ys,
                                  Inlet
                                  Air Pump
                                  PCV Valve
                                  Evap/Gas Cap
                                  1974+
                                  1975+
                                  1975+
                                  1981+
                                  1981+
                                  1981+
Start  Date
   1/86
   7/75
                                        IMPLEMENTATION STATUS Implemented, Running Smoothly
       Legislation  None needed                              Rule status  Promulgated
       SIP  Status  Final Approval 9/9/94                      RFP  Stage  State-run
       Air Agency  Department of Environmental Quality          I/M Agency  Department of Environmental Quality
                                           PENNSYLVANIA
Areas
Allentown-Bethlehem-Easton, PA-NJ
Altoona
Erie
Harrisburg-Lebanon-Carlisle
Johnstown
Lancaster
Philadelphia, PA-NJ
Pittsburgh
Reading
Scranton-Wilkes-Barre
Sharon
State College
Williamsport
York

Upgrade Start Date March 1995
Original Start Date June 1984
Network Type Hybrid
Test Fee $17
Test Frequency Biennial
Enforcement Type Registration Denial
Weight Classes 9,000 Ibs.
Waiver Type Cost: $450
Required
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
Enhanced
PROGRAM







" 	 •
CO Class Ozone Status
Attainment Marginal Operating Basic
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Moderate < Severe Operating Basic
Not Classified Moderate Operating Basic
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
Attainment Marginal Not Operating
DESIGN Enhanced
Tests 1M240 1977+
Performed Idle Test 1968+
Purge 1977+
Pressure 1977+
Catalyst 1984+
Inlet 1984+


Start Date
6/84
na
na
na
na
na
6/84
6/84
na
na
na
na
na
na









IMPLEMENTATION STATUS Suspended Until August 1995
Legislation Signed
SIP Status Disapproved 4/14/95


Air Agency Department Environmental Resources

••••^^^^^
Rule Status Promulgated
RFP Stage Awarded
I/M Agency Department of Transportation
"^ — — m—m


•••Mi
     Page 28
I/M Program Design Summary
                                                                                         April 1995

-------
                                           RHODE ISLAND
Areas
Providence
Newport
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency
Required CO Class Ozone Status Start Date
Enhanced Attainment Serious Not Operating na
Basic Attainment Serious Not Operating na
PROGRAM DESIGN Enhanced
December 1995 Tests IM240 1968+
None Performed Purge 1968+
_ , Pressure 1971+
Test-Only
Unknown
Biennial
Registration Denial
8,500 Ibs.
Cost: $450
IMPLEMENTATION
Signed
Submitted/Complete 11/94
Department of Environmental Management
STATUS On Hold, Evaluating Alternatives
Rule Status Final Effective 1 1/24/94
RFP Stage Drafted
I/M Agency Department of Transportation
   Areas
 Memphis, TN-AR-MS
                                             TENNESSEE
Required
Basic
CO  Class
Attainment
Ozone       Status        Start Date
Attainment   Operating Basic       1/85
Upgrade Start Date  January 1985
Original  Start Date  January 1985
     Network  Type  Test-Only
          Test Fee  $6
    Test Frequency  Annual
 Enforcement  Type  Registration Denial
    Weight  Classes  8,500 Ibs.
      Waiver  Type  None
  PROGRAM DESIGN Basic
                        Tests Idle Test
                   Performed
                                                                                        7975+
                                       IMPLEMENTATION STATUS Implemented, Running Smoothly
       Legislation  None Needed                             Rule Status  Promulgated
       SIP   Status  Final Rule 1(^2604                       RFP  Stage  Not Applicable
       Air Agency  Metropolitan Health Department              I/M  Agency  Motor Vehicle Inspection Bureau
       Page 29
                                         I/M Program Design Summary
                                                April 1995

-------
                                             TENNESSEE
Are" ^""-ed CO Class Ozone Status Start Date
Basic Moderate Marginal Ooeratin* Basic »/»
Upgrade Start Date July 1994/November 1994
Original Start Date August 1983
Network Type Test-Only
Test Fee 56
Test Frequency Annual
Enforcement Type Registration Denial
Weight Classes 8,500 Ibs.
Waiver Type None
PROGRAM DESIGN Basic
Tests Idle Test 1975+
Performed Catalys( m5+
Inlet 1975+
Evap/Gas Cap 1975+



IMPLEMENTATION STATUS Proceeding, Minor Problems
Legislation None Needed Rule Status Promulgated November 9. 1993
SIP Status Submitted/Complete 7/8/94 RFP Stage AwardedMay 1994
Air Agency Department of Conservation I/M Agency Motor Vehicle Inspection Bureau
   Areas
 Beaumont
 Port Arthur
                                       TEXAS  - Basic Areas
 Required
 Basic
 Basic
CO  Class
Attainment
Attainment
 Ozone
Serious
Serious
  Status
Not Operating
Not Operating
Start Date
    na
   1/86
Upgrade Start Date
Original Start Date
     Network Type
          Test  Fee
    Test Frequency
 Enforcement Type
   Weight Classes
      Waiver Type
   PROGRAM  DESIGN Basic
                        Tests
                    Performed
                                      IMPLEMENTATION  STATUS Terminated
       Legislation  Signed                                Rule  Status
       SIP  Status  Approved 8/22/94                       RFP  Stage  Awarded
       Air Agency  Natural Resources Conservation Commission   I/M Agency  Natural Resources Conservation Commission
       Page 30
I/M Program Design Summary
                                                                                     April 1995

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                                    TEXAS - Dallas  & Houston
Areas
Houston
Dallas-Fort Worth
Denton
Galveston
Texas City

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
Required CO Class Ozone Status
Enhanced Attainment Severe Not Operating
Basic .Attainment Moderate Not Operating
Basic Attainment Moderate Not Operating
Basic Attainment Severe Not Operating
Basic Attainment Severe Not Operating
PROGRAM DESIGN Enhanced Opt-up
Tests
My 1984/January 1986 Performed





IMPLEMENTATION STATUS Terminated
Signed Rule Status Promulgated
Final Approval 8/22/94 RFP Stage Awarded
Natural Resource Conservation Commission I/M Agency Natural Resource Conservation
Start Date
7/84
1/86
na
na
na











   Areas
 El Paso
                                          TEXAS  - El  Paso
                     Required
                     Enhanced
CO  Class
Moderate <
 Ozone
Serious
  Status
Not Operating
Start Date
   1/86
Upgrade  Start Date
Original Start Date
     Network Type
          Test  Fee
    Test  Frequency
 Enforcement Type
   Weight Classes
      Waiver Type
July 1984/January 1986
                       PROGRAM  DESIGN Enhanced
                                            Tests
                                        Performed
                                      IMPLEMENTATION STATUS Terminated
       Legislation  Signed                                Rule  Status  Promulgated
       SIP  Status  Final Approval 8/22/94                    RFP  Stage  Awarded
       Air Agency  Natural Resource Conservation Commission    I/M  Agency  Natural Resource Conservation Commission
       Page 31
                    I/M Program Design Summary
                                                                                      April 1995

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                                                  UTAH
Areas
Ogden
Provo-Orem
Salt Lake City
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type
Legislation
SIP Status
Air Agency
Required CO Class Ozone Status Start Date
Basic Moderate < 12.7 Attainment Operating Basic 1/92
Basic Moderate > 12.7 Attainment Operating Basic 7/86
Basic Not Classified Not Operating Basic 4/84
PROGRAM DESIGN Enhanced Opt-up
January 1994 Tests TWO Speed
January 1992 Performed Catalyst
Test-and-Repair Air Pump
$14 Inlet
Annual
Registration Denial
< 26,000 Ibs.
Pre-81: $100, 1981+: $200
IMPLEMENTATION
Signed
Submitted/Complete 11/94
Utah Division of Air Quality
7965+
7977+
7977+
7977+
STATUS On Hold, Evaluating Alternatives
Rule Status Promulgated
RFP Stage Not applicable
I/M Agency Environmental Health Department
^__^^^__^_-^___|^_^^B1||^^^^^
   Areas
 Burlington
                                               VERMONT
 Required
 Enhanced
CO  Class
Attainment
 Ozone       Status
Attainment   Not Operating
Start  Date
Upgrade Start Date
Original  Start Date
     Network  Type
          Test Fee
    Test Frequency
 Enforcement  Type
    Weight  Classes
      Waiver  Type
   PROGRAM  DESIGN Enhanced
                        Tests
                    Performed
                                       IMPLEMENTATION STATUS On Hold, Evaluating Alternatives
       Legislation  Needed                                  Rule  Status  Not Drafted
       SIP   Status  Sanctions Imposed 9/6/94                   RFP  Stage  Not Drafted
       Air Agency  Department of Environmental Conservation     I/M  Agency  Department of Environmental Conservation
       Page 32
I/M Program Design Summary
                                                                                         April 1995

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                                                 VIRGINIA
    Areas
 Petersburg-Colonial Heights
 Richmond
                       Required     CO  Class      Ozone       Status
                       Basic          Attainment       Moderate    Not Operating
                       Basic          Attainment       Moderate    Not Operating
Start  Date
    na
    na
                                             PROGRAM  DESIGN Basic
Upgrade Start Date
Original  Start Date
     Network Type
          Test  Fee
    Test Frequency
 Enforcement Type
    Weight  Classes
      Waiver Type
                                               Tests  Unknoqn
                                          Performed
Test-and-Repair
17.00
Biennial
Registration Denial
8.500 Ibs.
Cost: $75/$200
                                         IMPLEMENTATION  STATUS Proceeding Smoothly
       Legislation   Signed                                  Rule Status  Drafted
       SIP   Status   Finding Made 1/20/94                     RFP  Stage  Not Applicable
       Air  Agency   Department of Air Pollution Control          I/M Agency  Department of Air Pollution Control
                                                VIRGINIA
Areas Required CO Class Ozone Status
Washington, DC-MD-VA Enhanced Moderate Serious Operating Basic
Start Date
12/81
PROGRAM DESIGN Enhanced
Upgrade Start Date
Original Start Date December 1981
Network Type Test-and-Repair
Test Fee $20 cap
Test Frequency Biennial
Enforcement Type Registration Denial
Weight Classes 10,000 Ibs.
Waiver Type Cost: $450
IMPLEMENTATION
Legislation Needed
SIP Status Finding Made 1/20/94
Air Agency Department of Air Pollution Control
Tests ASM2 1968+
Performed Two Speed 4 Wheel Drive
Purge 1973+
Pressure 1973+




STATUS On Hold, Evaluating Alternatives
Rule Status Not Drafted
RFP Stage Not Drafted
I/M Agency Department of Air Pollution

Control
       Page 33
                                          I/M Program Design Summary
                                                                      April 1995

-------
                          WASHINGTON
Areas
Required CO
Class Ozone Status Start Date
Portland-Vancouver, OR-WA Basic Moderate < Marginal Operating Basic 6/93
PROGRAM DESIGN Basic
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
October 1995
January 1982
Test-Only
$12.00
Biennial
Registration Denial
26.000 Ibs.
Cost: $100/3200 Basic;$450 Enhanced
IMPLEMENTATION
Signed
Finding Made 5/6/94
Department of Ecology
Tests
Performed






Idle Test
Loaded/Idle
Two Speed





7965+
1968+
Heavy Duty





STATUS Proceeding Smoothly
Rule Status
RFP Stage
I/M Agency
^^••^•H
Promulgated
Awarded


Department of Ecology
I^^^H^HH^MH^^^^M^MM
                          WASHINGTON
Areas
Seattle
Spokane
Tacoma

Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency






January 1982
Test-Only
$12.00
Biennial
Registration Denial
26,000 Ibs.
$200

Signed
Finding Made 5/6/94
Department of Ecology
Required CO Class Ozone Status Start Date
Enhanced Moderate >12.7 Marginal Operating Basic 1/82
Enhanced Moderate > 12.7 Attainment Operating Basic 7/85
Enhanced Moderate > 12.7 Marginal Operating Basic 6/93
PROGRAM DESIGN Low Enhanced
Tests Idle Test 1968+
Performed Loaded/Idle 1968+
ASM: Spokane





IMPLEMENTATION STATUS Implemented. Minor Problems
Rule Status Not Drafted
RFP Stage Awarded
I/M Agency Department of Ecology
Page 34
I/M Program Design Summary
                                                          April 1995

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                                  WISCONSIN
Areas
Kenosha
Milwaukee
Racine
Sheboygan
Required CO
Class Ozone Status Start Date
Basic Attainment Severe Operating Basic 4/84
Enhanced Attainment Severe Operating Basic 4/84
Basic Attainment Severe Operating Basic 4/84
Basic Attainment Serious Operating Basic 7/93
PROGRAM DESIGN Enhanced Opt-up
Upgrade Start Date
Original Start Date
Network Type
Test Fee
Test Frequency
Enforcement Type
Weight Classes
Waiver Type

Legislation
SIP Status
Air Agency
July 1995
April 1984
Test-Only
None: IM240 Cost $8.50
Biennial
Registration Denial
14,000 Ibs.
Cost: $450
IMPLEMENTATION
None Needed
Conditionally Approved 1/12/95
Department of Natural Resources
Tests /A/240
Performed Purge
Pressure




STATUS Proceeding Smoothly
Rule Status Promulgated
RFP Stage Contract Signed
1968+
1968+
1968+







I/M Agency Department of Transportation
Page 35
                              I/M Program Design Summary
April 1995

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                          Section  Four
                    Specific  I/M   Issues


This section addresses specific issues related to I/M. It discusses the new IM240 and evaporative
system tests and how much they will cost. Alternative approaches and their costs are also discussed.
It covers convenience issues and the question of test-and-repair vs. test-only networks

-------
               HIGH-TECH I/M TESTS
Section Four
                                                 Page 2

-------
                  HIGH-TECH TESTS FOR HIGH-TECH  VEHICLES
  nrkth       i          Tdu°n P35560^ cars since 1968 (controls were later used on
 trucks). Since the early 1980s, vehicles have been equipped with sophisticated emission control
 systems capable of minimizing pollution from exhaust and from evaporating fuel, while maximizing
 fuel economy and performance. Inspection and Maintenance (I/M) programs have been established
 in many parts of the country to ensure these systems are working properly so in-use vehicles will
 retain low pollution profiles.  The 1990 Clean Air Act requires enhanced I/M programs and more
 comprehensive testing to improve the effectiveness of the I/M programs. To achieve this goal EPA
 has developed three new short tests for use in I/M programs and field tested them on over  15 000
 vehicles in actual I/M lanes. The new tests are specifically designed to measure emissions from
 high-tech vehicles, but are effective on old technology vehicles as well.

 Differences Between  High-Tech Tests and Existing Tests

 The "high-tech" tests provide a very thorough, accurate check of the engine and vehicle emission
 control system. The sophistication of these tests enables them to determine a car's true emissions
 and do a better job than current I/M tests of identifying vehicles needing emission repair  The
 accuracy of the high-tech tests also ensures that malfunctioning vehicles will be repaired to  truly
 acceptable emission levels. The high-tech test includes three distinct parts:

         Transient, mass emission tailpipe test (IM240)
     •   Purge flow test of the evaporative canister
     •   Pressure test of the evaporative system

 The IM240 differs from traditional UM tests in that the emissions are measured while the vehicle is
 driven on a treadmill-like device called a dynamometer. Most I/M tests today are conducted while the
 vehicle is idling. A few states currently test vehicles on a dynamometer, but only operate the vehicle
 at one speed.

 In the M240, the vehicle is operated over a driving cycle that has many different speeds. The cycle
 is designed to resemble typical city driving and includes driving modes such as acceleration and
 deceleration. Vehicle acceleration and deceleration can be significant sources of emissions from
 malfunctioning vehicles.

 The IM240 measures hydrocarbon, carbon monoxide, and oxides of nitrogen emissions. Only HC
 and CO emissions are measured in traditional I/M tests. The IM240 also measures fuel economy and
 generates diagnostic information that helps in the repair process for vehicles that fail.

 Another important difference between the IM240 and traditional  I/M tests is the way emissions are
 measured.  The IM240 captures the entire exhaust stream during the test and measures the total mass
 of emissions from the vehicle (in grams of pollutant per mile driven). Traditional tests  measure the
 concentration of pollutants in exhaust (percent or ppm). Mass emissions are a more accurate way of
 measuring the emission performance of large and small engines and are more directly related to the
 contribution that each vehicle makes to air pollution.  As a result, the IM240 has virtually zero false
 failures while it reduces false passes to a minimum. The steady-state tests suffer from significant
 levels of both false passes and false failures.

 The purge and pressure tests check for proper functioning of a vehicle's evaporative emission control
 system. This system prevents fuel vapors from escaping into the atmosphere. Evaporative
 emissions can be a major source of HC emissions, especially in hot weather when smog levels are
 highest.  1 raditional I/M tests cannot measure evaporative emissions.

The evaporative emission system uses engine vacuum to draw fuel vapors in the fuel tank and vaoors
stored in the evaporative canister into the engine for combustion. The purge test determines whether


Section Four
                                                                                    Page 3

-------
this system is functioning properly by measuring the flow of vapors into the engine during the
IM240. The pressure test checks the evaporative emission system for leaks.

IM240 Test Procedure

The IM240 is a highly-automated test that involves only minimal inspector discretion. The process
begins by driving the vehicle onto the dynamometer, activating vehicle restraints, properly placing
the exhaust collection device, and positioning an engine cooling fan.  An inspector then "drives" the
vehicle according to a prescribed cycle displayed on a video screen. The inspector follows the
driving cycle by using the accelerator pedal and the brake to speed up or slow down just as if the
vehicle were being driven on a city street. A cursor on the video screen indicates vehicle speed. The
inspector adjusts the speed to keep the cursor on the trace. This technique is easily and quickly
learned by anyone who can drive a car.  If the inspector fails to follow the driving trace properly, the
inspector adjusts tne speea to Keep tne cursor on me trace,  i n
learned by anyone who can drive a car. If the inspector fails t
    is aborted and restarted, although this rarely is a problem.

The length of the IM240 test varies depending on the vehicle's emissions. To determine emission
levels, second-by-second emission measurements are taken. The test computer continually monitors
the emission levels during the test and as soon as the emission rates indicate that a vehicle is
exceptionally clean, the computer automatically notifies the inspector to stop testing. This may occur
in as little as 30 seconds. For vehicles that are over or close to maximum allowable emission levels,
the test may continue for a full 240 seconds. Thus, while the complete driving cycle is 240 seconds
long, the average test time will be about two minutes.
                                  IM240 Driving Trace
               60

               50

               40
       Speed
        mph   30

               20

               10

                0
                  0    20   40   60   80   100   120  140  160  180  200  220  240
                                               Seconds

IM240 Failures

The emission standards used in the IM240 test are expressed in terms of grams per mile rather than
as a percentage or in parts per million, as is the case with steady-state tests.  Different standards are
set for each model year and reflect the technology that was in effect at the time of manufacture (see
following table of recommended standards). The standards are typically two to three times higher
than new vehicle certification standards for the model year.  EPA recommends that standards be
phased-in over two test cycles. The standards in the first cycle, referred to as phase-in standards in
the following tables, are set much looser than the new vehicle standards. The purpose of setting the
standards loosely  at first are many-fold:
Section Four
                                                                                    Page 4

-------
       •   About 40-45% of vehicles currently operating need emission-related repairs.  Failing all of
          these vehicles in the first cycle would overwhelm the repair industry and make the program
          much more expensive, since more testing capacity would be needed to conduct retests

       •   The phase-in standards will fail only the dirtiest vehicles in the first cycle - the vehicles that
          will yield the largest emission reduction.  About 20-30% of vehicles will fail the phase-in
          standards. This means the program will quickly see significant reductions even though
          looser standards are in place.

       •   By failing only the dirtiest vehicles at first, the repair industry will have plenty of time to
          develop the skills, acquire the training, and purchase the equipment needed to diagnose and
          repair the less dirty but harder to fix vehicles in the second and subsequent cycles.

       •   The phase-in period also provides an opportunity to fine tune the IM240 system to ensure
          that only vehicles that need repairs will fail the test in the second cycle when tighter
          standards apply.

 IM240  Test Equipment

 The equipment needed to perform the 1M240 is different from the equipment used for either the idle-
 test or the single-speed dynamometer tests used in some states (e.g., Arizona). These differences
 include dynamometer capabilities, video driver trace monitors, special sampling systems, and
 emission analyzers. In addition, the high-tech test system will use computer controls with integrated
 quality assurance functions, and will be completely automated.

 The primary difference between the dynamometer used for the IM240 and those used for single
 speed I/M tests is the addition of inertia flywheels or an electric motor that simulates inertia. The
 flywheels or the electric motor allow simulation of vehicle acceleration and deceleration by putting a
 load on the engine. This in turn allows the measurement of emissions under these normal driving
 conditions.  This type of dynamometer is widely available and is similar to the ones used by EPA
 and vehicle manufacturers for new vehicle certification.

 The selection of the inertia weight or load and test horsepower for an individual vehicle will be
 automatically determined by the test computer and is based on the type of vehicle being tested.

 The vehicle's mass emissions are determined by collecting the entire exhaust flow from the tailpipe
 with a device known as a Constant Volume Sampler (CVS). The CVS dilutes the exhaust with fresh
 air and measures the flow rate of the mixture. Mass emissions (for each second) are calculated by
 multiplying this flow rate by the measured concentration of pollutants in the mixture.  To arrive at the
 official test value in grams per mile, the mass emissions for each second are added together; this sum
 is then divided by the distance (number of miles) traveled over the test cycle.
Section Four
                                                                                     PageS

-------
                        Schematic of  the  IM240 Test Equipment
                                                                             Fan
The fresh air dilution is vital because it preserves the integrity of the sample and because it protects
the emission analyzers from high concentrations of water vapor produced by the vehicle.  The
dilution process also allows the measurement system to accommodate the differences in exhaust flow
between small engines and large engines while measuring the true amount of emissions from each
type of engine.

The dilute sample, however, lowers the concentration of pollutants to be measured, and hence
requires more sensitive emission analyzers than those used by traditional I/M programs. In addition,
the method for measuring HC emission uses a different and more accurate technique.  HC emissions
are measured with a Flame lonization Detector (FID), while CO and carbon dioxide emissions are
measured using non-dispersive infra-red analyzers. NOx emissions, which are not measured in
basic I/M programs, are measured with a chemiluminescense analyzer.

Evaporative  System Purge  Test

Since 1971, fuel tanks on vehicles have been designed as a closed system in which vapors diat
evaporate from the gasoline in the tank are not released into the atmosphere.  The system is sealed
and under pressure so that excess vapors are shunted to a container filled with charcoal known as the
evaporative canister.

The purge test is used to determine whether fuel vapors stored in the evaporative canister and present
in the fuel tank are being drawn into the engine for combustion. If the purge  system is not working
properly, the evaporative canister can become saturated and start to vent hydrocarbons into the
atmosphere. In addition to causing  HC emissions, failure of the purge system wastes gasoline and
reduces fuel economy.

The purge test is conducted while the vehicle is undergoing the IM240 on the dynamometer.  Purge
flow is measured by simply inserting a flow meter at one end of the hose that runs between the
evaporative canister and the engine.

Determination of an acceptable purge rate is based on the total volume of flow through the system
during the EM240. The vehicle must have a minimum of 1 liter of flow in order to pass. Most
vehicles in proper working order will accumulate 25 liters or more during the FM240.  As soon as a
vehicle exceeds 1  liter of volume, the purge test is complete. The entire IM240 driving cycle ends as
soon as  final results are determined  for the emission test.

The purge test requires a flow meter that can measure the total volume of flow over the transient
cycle. Additionally, hoses and universal fittings are required to hook up the flow meter as indicated
below.  Finally, a computer is needed to control the test process, collect and record the data, and
determine the pass/fail status.
Section Four
Page 6

-------
 Evaporative System  Pressure  Test

 The pressure test checks the system for leaks that would allow fuel vapors to escape into the
 atmosphere. A pressure decay method is used to monitor for pressure losses in the system. In this
 method, the vapor lines to the fuel tank and the fuel tank itself are filled with nitrogen to a pressure of
 14 inches of water (about 0.5 psi). Since the fuel system is designed to withstand pressures up to
 50-60 inches of water, there is no danger of over-pressurizing the system. To pressurize these
 components, the inspector must locate the evaporative canister, remove the vapor line from the fuel
 tank, and hook up the pressure test equipment to the vapor line. The system is automatically filled
 with nitrogen using computer controls and hardware flow controls. The pressure supply system is
 closed off and any  loss in pressure is monitored by the computer. If pressure in the system remains
 above eight inches of water, the vehicle passes the test.

 A source of nitrogen, a pressure gauge, a valve, and associated hoses and fittings are needed to
 perform the pressure test. In addition, a computer is used to automatically meter the nitrogen,
 monitor the pressure, and collect and process the results. Algorithms will be developed to optimize
 the test so that a pass/fail decision can be made in less than two minutes on most vehicles.

 Alternative Purge  and Pressure Tests

 The alternative pressure test differs from the standard test in that the fuel tank is pressurized through
 the fuel inlet rather than through the evaporative hose from the canister end. The canister hose is
 clamped in order to seal the system while the gas cap is checked on a separate rig to ensure that it
 seals properly. The system is pressurized with helium rather than nitrogen.  The alternative purge
 test is conducted by allowing the helium to flow through the canister during the IM240 tailpipe test
 and the exhaust is analyzed for the presence of helium using a mass spectrometer.  If helium is
 present in the exhaust in adequate quantities, the vehicle passes.

 EPA has approved  the alternative pressure procedure for use in IM programs.  State programs
 opting to use the alternative purge and pressure tests receive the same credit in MOBILESa as those
 that use the standard tests.
Section Four                                                                           Page7

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                 HOW TO PREPARE FOR AN ENHANCED I/M TEST

Before the Test

Before visiting the test station, check the vehicle to ensure that it does not have any problems that
would make it unsafe to test or could cause it to be rejected from testing due to being unsafe or
untestable. If any of these conditions exist, be sure to correct them before visiting the test station:
       •   Leaky exhaust system or missing tail pipe
       •   Excessive exhaust smoke
       •   Obvious fluid leaks
       •   Lack of engine oil
       •   Lack of transmission fluid
       •   Brake problems
       •   Overheating
       •   Tire damage such as cuts, bubbles, bare threads, or excessive wear
       •   Damaged or missing evaporative emission control canister
       •   Missing or disconnected evaporative emission control system hoses
       •   Damaged, misfit, or missing gas cap

Taking the Test

Before arriving at the test lane be sure that the vehicle is in the best possible condition for testing. In
particular check to see that:
       •   The tires  are fully inflated to recommended side wall pressure.

       •   The vehicle is fully warmed up.  Ideally, it should be driven for a minimum of 15
           minutes to ensure this, with some highway driving if convenient.

       •   Try to visit the test station when lines are short to prevent catalyst cool down or excessive
           heating of fuel (on hot days),  leading to evaporative canister loading - check the test
           program hotline for the best times.

The inspector will visually check the vehicle to ensure that tires are not severely under-inflated but
radial tires can be low on air and not show it. The inspector will also check to see if the vehicle is
properly warmed up  by checking the temperature gauge but this only indicates engine temperature
not catalyst temperature. So, while the inspector will spot gross, readily obvious problems, it is best
to take precautions to ensure that the vehicle is in optimum condition for testing.

Upon arrival at the test lane, be aware of the following:

       •   Turn off all accessories (air conditioning, defroster, heat, etc.) before the test starts.

       •   Turn off selectable four-wheel-drive or traction control, before you enter the test station.

       •   If the vehicle has fixed four-wheel-drive or non-selectable traction control and the test
           station has a lane with a four-wheel dynamometer, go to that lane (look for the sign).  If
           the station does not have such a lane, tell the inspector that the vehicle has fixed four-
           wheel drive or traction control.  In many cases, the inspector will have this data in the
           computer database, but because these features are often optional it may not be in the
           database and it will not always be readily apparent if a particular vehicle is equipped with
           the option.
o   •  c                                                                              Pa«e8
SecUon Four

-------
                 RECOMMENDED  IM240 EMISSION STANDARDS

 Phase-in IM240  Standards

 Phase-in emission standards are recommended for at least calendar years 1995 and 1996, and may
 also be used in 1997, depending upon when full implementation occurs.  The following standards
 are recommended for low-altitude areas and will yield a failure rate of about 20-30%.
                    Light Duty Vehicle IM240 Phase-in  Standards
     Model Years

     1994+Tier 1
     1991-1995
     1983-1990
     1981-1982
     1980
     1977-1979
     1975-1976
     1973-1974
     1968-1972
   Hydrocarbons
    grams per mile
       0.80
        1.20
       2.00
       2.00
       2.00
       7.50
       7.50
        10.0
        10.0
           Carbon Monoxide
             grams per mile
                 15.0
                 20.0
                 30.0
                 60.0
                 60.0
                 90.0
                 90.0
                 150
                 150
          Oxides of Nitrogen
             grams per mile
                 2.0
                 2.5
                 3.0
                 3.0
                 6.0
                 6.0
                 9.0
                 9.0
                10.0
Model Years

1994+Tier 1<3750LVW
1994+ Tier 1 >3750 LVW
1991-1995
1988-1990
1984-1987
1979-1983
1975-1978
1973-1974
1968-1972
Light  Duty Truck 1 IM240 Phase-in Standards

 Less than 6001 pounds Gross Vehicle Weight Rating

        Hydrocarbons    Carbon Monoxide  Oxides of Nitrogen
         grams per mile       grams per mile       grams per mile
            0.80              15.0               2.0
            1.00              20.0               2.5
            2.40              60.0               3.0
            3.20              80.0               3.5
            3.20              80.0               7.0
            7.50              100               7.0
            8.00              120               9.0
            10.0              150               9.0
            10.0              150               10.0
                   Light  Duty Truck 2 IM240 Phase-in Standards
Model Years
1994+ Tier 1 <5750 LVW)
1994+ Tier 1 >5750 LVW)
1991-1995
1988-1990
1984-1987
1979-1983
1975-1978
1973-1974
1968-1972
Greater than 6000 pounds Gross Vehicle Weight Rating

        Hydrocarbons    Carbon Monoxide  Oxides of Nitrogen
                                            grams per mile
                                                2.5
grams per mile
    1.00
    2.40
    2.40
    3.20
    3.20
    7.50
    8.00
    10.0
    10.0
grams per mile
   2C
                              60.0
                              60.0
                              80.0
                              80.0
                              100
                              120
                              150
                              150
                     4.0
                     4.5
                     5.0
                     7.0
                     7.0
                     9.0
                     9.0
                     10.0
Section Four
                                                                               Page 9

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Final  IM240 Standards
Final standards are recommended for use after at least one full test cycle has been completed using
the phase-in standards. The following standards are recommended for low-altitude areas and will
yield a failure rate of about 20-30% (after a full cycle of the phase-in standards).
     Model Years

     1994+Tier 1
     1983-1995
     1981-1982
     1980
     1977-1979
     1975-1976
     1973-1974
     1968-1972
  Light Duty Vehicle  IM240 Final Standards

   Hydrocarbons     Carbon Monoxide  Oxides of Nitrogen
    grams per mile       grams per mile       grams per mile
        0.60               10.0               1.5
        0.80               15.0               2.0
       0.80
       0.80
       3.00
       3.00
       7.00
       7.00
                 30.0
                 30.0
                 65.0
                 65.0
                 120
                 120
2.0
4.0
4.0
6.0
6.0
7.0
Model Years
 1994+Tier 1<3750LVW
 1994+Tier 1>3750LVW
 1988-1995
 1984-1987
 1979-1983
 1975-1978
 1973-1974
 1968-1972
  Light Duty Truck 1 IM240 Final Standards

 Less than 6001 pounds Gross Vehicle Weight Rating
        Hydrocarbons    Carbon Monoxide  Oxides of Nitrogen
                           grams per mile       grams per mile
                              10.0               1.5
                              13.0               1.8
grams per mile
    0.60
    0.80
    1.60
    1.60
    3.40
    4.00
    7.00
    7.00
                              40.0
                              40.0
                              70.0
                              80.0
                               120
                               120
     2.5
     4.5
     4.5
     6.0
     6.0
     7.0
                    Light Duty Truck 2 IM240 Phase-in Standards
Model Years
 1994+Tier 1<5750LVW
 1994+Tier 1>5750LVW
 1988-1995
 1984-1987
 1979-1983
 1975-1978
 1973-1974
 1968-1972
Greater than 6000 pounds Gross Vehicle Weight Rating

        Hydrocarbons    Carbon Monoxide  Oxides of Nitrogen
                           grams per mile       grams per mile
                              13.0               1.8
                              15.0              2.0
grams per mile
   0.80
   0.80
   1.60
   1.60
   3.40
   4.00
   7.00
   7.00
                              40.0
                              40.0
                              70.0
                              80.0
                               120
                               120
     3.5
     4.5
     4.5
     6.0
     6.0
     7.0
Section Four
                                                                               Page 10

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                                   IM240  RELIABILITY

 The Goal    Fail the vehicles that need repair and pass the vehicles that do not

    »    The most important consideration for an I/M test is its ability to distinguish properly
         functioning vehicles from vehicles that need repair.  This means it must fail most of the
         "dirty" vehicles without failing "clean" vehicles.

    »    All tests involving measurements produce results that are variable to some degree  The two
         key ways in which tests may vary are:

               pass/fail results that vary from one test to the next

         •     absolute emission scores that vary from one test to the next

 The  Challenge     Vehicle emissions can vary from test to test on clean and dirty cars

    »    Emission rates from vehicles vary for three basic reasons:  ambient conditions, vehicle
         conditioning or intermittent vehicle problems. The IM240 can effectively handle ambient
         conditions and vehicle conditioning, but intermittent vehicle problems are very difficult to
         deal with in any test.

               Ambient temperature, pressure, and humidity vary from test-to-test on the same
               vehicle and can influence emission levels.

               Engine temperature, catalytic converter temperature, tire pressure, and the amount of
               fuel vapor stored in the evaporative canister also vary from test-to-test and can affect
               emission levels.  For example, if the evaporative canister is  fully loaded with fuel
               vapor, when these vapors are purged into the engine, emission levels rise.

               Some vehicles have intermittent malfunctions which can cause emission levels to
               change from test to test. This could result in a false pass even though the vehicle
               needs repair.  For example, a sticky EGR valve might function fine on one test but
               cause a NOx failure on a second test because it happened to stick at that time.

    »    The steady-state tests previously used in I/M programs (idle test, two-speed test, etc.) do
         not effectively deal with any of these challenges.  Worse still, these tests pass many, many
         dirty vehicles and fail too many clean cars.

    »    It is important to realize that there is no total solution to the problem of variable emission
         scores. Emission scores even vary on the Federal Test Procedure (FTP), the test used to
         certify new vehicles prior to sale, even though variable factors are tightly controlled under
         laboratory conditions.

The Solution      IM240

    »    The IM240 was designed to address the problems that cause vehicle emissions to vary:

         •     The computer-controlled test equipment used for the IM240 continually adjusts for
              ambient conditions, such as atmospheric pressure and temperature.  It overcomes
              humidity problems through the use of dilute sampling.

              Vehicle conditioning is addressed in  several ways: first, the vehicle is tested on a
              dynamometer that creates a load that the vehicle must work to overcome. This causes
              the engine and the catalyst to warm up to normal operating temperatures. Second the
              inspector visually checks the tires to see that tires are  inflated. Third, vehicles are'


Section Four                                                                          _
                                                                                    Page 11

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               given two chances to pass the test within the 240 second cycle. The IM240 is
               composed of two "hills." When a vehicle shows high emission levels overall, the
               computer looks at the second hill separately.  If the second hill shows low emission
               levels, then the vehicle passes. Thus, the two-ways-to-pass feature helps insure
               vehicles are fully warmed up and excess fuel  vapors in the canister are purged.

               The IM240 is a transient test, that involves a wide range of vehicle loads, speeds,
               acceleration, deceleration, and cruise. This wide variety of operating modes helps
               minimize false passes and helps identify vehicles with subtle or intermittent problems.
               Nevertheless, some problems are going to show up one time but not the next.

         •     EPA estimates that second-chance testing would change results from fail to pass on
               only about 2% of vehicles. It should be noted that these 2% of vehicles still need
               repair even though they would change to a pass.  The overwhelming majority of
               vehicles that need repair have continuous problems and are clear cut failures on the
               EM240 test. By comparison, second chance testing on the idle test can cause  as many
               as one-third of initially failing vehicles to change results. It is virtually impossible to
               devise a test that would not result in some result shifting of vehicles close to the
               standard when repeat tests are performed.

         IM240 emission standards are substantially looser than the new vehicle standards:

         •     Vehicle manufacturers are required to design and build vehicles to meet specified
               emission standards, referred to as certification standards.  IM240 standards are set at
               levels-2-3 times above the certification standards.

         •     This provides a margin of safety that insures that clean vehicles dp not fail the test
               (given that standards are set based on model year). At the same time, however, it
               allows a small fraction of marginally dirty vehicles to pass even though they need
               repair.

         •     The IM240 program is designed to be phased in over at least 2 test cycles. In the first
               cycle, very loose standards are used. By failing only the dirtiest vehicles in the first
               cycle, the repair industry is not overwhelmed with vehicles that need repair. These
               vehicles are usually the easiest to fix and will yield large emission reductions. The
               phase-in also provides the repair industry with time to become accustomed to the new
               tests and acquire the training, equipment, and skills needed to fully repair cars. The
               standards are tightened in the second cycle, and in highly polluted areas in the third
               cycle too, such that additional vehicles will fail the test. Ultimately, the IM240 fails
               over 90 percent of vehicles that need repair while failing essentially no clean vehicles.

         The IM240 uses fast-pass for shortened test time

         •     Many vehicles tested on the IM240 will be so  clean that a full 240 second test is not
               needed to decide the vehicle passes.  So, starting at the 30-second point, and any time
               thereafter, if the vehicle is showing sufficiently clean results for all of the pollutants
               and has adequate purge levels, then the test is stopped.

               By using the fast-pass strategy, the cost of the IM240 test is substantially reduced.
               The average test time using fast-pass is about 2 minutes, versus 4 minutes if fast-pass
               is not used. By cutting the test time in half, the number of stations and lanes  needed
               to test the fleet is substantially reduced.
Section Four                                                                           Pa«c 12

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               Fast-pass emission scores are not as precise as a full, 240 second test's scores
               Likewise, repeating the IM240 on the same vehicle using fast-pass could yield
               different scores depending upon the actual length of the test and the ambient and
               vehicle conditions, but the overall result will be the same - the vehicle passes.  Also,
               during the phase-in period of the program when very loose standards are in effect,
               even some dirty vehicles can fast-pass the test. Repeat tests on such  vehicles are even
               more likely to yield different emission scores, and could result in failing one time and
               passing another - even though the vehicle needs repair.

               The loss  in accuracy of the scores on clean vehicles is the trade-off. But it is
               worthwhile: the purpose of the program is to find the vehicles that need repair and
               insure that they are properly fixed, not provide an absolutely accurate test result on
               every vehicle tested.  Note that full IM240 tests are done  on a random sample of all
               vehicles in the fleet to collect data on the overall effectiveness of the program  EPA
               also recommends that states conduct full IM240 tests when there are no vehicles
               waiting in the queue to be tested.
Section Four                                                                            _.
                                                                                      Page 13

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              COST OF HIGH-TECH I/M
Section Four                                           page 14

-------
     TEST FEES AND OVERSIGHT COSTS  OF ENHANCED I/M PROGRAMS

 The costs shown in the table below are for enhanced I/M areas that have awarded contracts and
 established test and oversight costs. The test cost is the amount the contractor receives for each paid
 test (typically the initial test and includes one free retest) and covers all of the costs of installing and
 operating the test network. The oversight cost is the portion of the total test fee collected that is used
 for oversight and management of the program by the state. Usually, the amount the motorist pays
 will be equal to the total test cost; however, in some states the fee the motorist pays is lower than the
 total test cost.  The cost varies based on several factors: the cost of land and labor, the extra services
 and facilities the contractor is required to provide, limits on a state's ability to keep costs low, the
 amount of competition in the contract process, the length of the contract, etc.
STATE
Maryland
Pennsylvania
Connecticut
Texas
Dallas
El Paso
Houston
Maine
Michigan
Ohio
Arizona
New York City
Colorado
TEST
COST
$14.00
na
na

$18.03
$19.38
$20.45
$22.00
$18.00
$18.45
$20.00*
$21.00
24.25*
OVERSIGHT
COST
$3.00
na
na

$2.97
$2.62
$2.55
$2.00
$5.00
$1.05
$4.30
$4.00
$1.75
TOTAL TEST
COST
$17
$17
$20

$21
$22
$23
$24
$24
$19.50
$24.30
$25
$26
The costs range from $17 to $25 per test, with the average (test-volume weighted) cost being about
$20 (every other year). Motorist currently pay an average of $12.50 per year for an I/M test.  Thus,
switching to biennial, enhanced I/M actually lowers the annual test cost for motorists in most states.
Some states, however, are pursuing hybrid programs that incorporate test-only and test-and-repair
elements. The cost estimates for these programs indicate that motorists in these areas may end up
paying a lot more than areas that exclusively implement test-only programs.

           The Cost of I/M  Depends on the  Type of  Program Implemented
                                                                         $75
                $25
   $26
                                                      $30
                $7

               •

               Basic
 Enhanced
Test-Only
Test-and-
 Repair
                                                                       Enhanced
                                                                        Hybrid
Section Four
                                                                                  Page 15

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             NATIONAL COSTS AND BENEFITS  OF ENHANCED I/M

Benefits Of Enhanced I/M

Enhanced, high-tech, test-only I/M will provide environmental and health benefits by decreasing
motor vehicle emissions of VOCs, CO, and NOx.  As shown in the following table, I/M programs
currently reduce annual emission by about 116,000 tons of VOC and  1.5 million tons of CO.
Enhanced, high-tech, test-only I/M will reduce annual emission by about 384,000 tons of VOC and
2.3 million tons of CO. Enhanced I/M programs will also reduce NOX emissions.

                     National  Emission  Reduction Benefits of I/M

                          Annual tons of emission reductions in 2000

                                             VOC              £Q_

             Reductions From Continuing I/M Unchanged

                             Centralized     55,540          775,228

                           Decentralized     60.476          791.167

                           Current Total     116,016         1,566,395

             Reductions from High Tech I/M

                        Enhanced Areas     384,130         2,345,278

                            Basic Areas     36.285          500.476

                    Total Future Benefits     420,415         2,845,754

Thus, enhanced I/M and improved basic I/M programs will result in national emission reductions
substantially greater than current I/M programs.

Cost Of Enhanced I/M

EPA has developed estimates of inspection and repair costs in the high-tech I/M program. A
conventional steady-state I/M test, including emission control device checks, currently costs $8.50
per vehicle on average in a test-only program, and $17.70 on average in test-and-repair programs.
The high-tech test costs about $20 per vehicle in an efficiently run, high-volume test-only program.
If the inspection were performed biennially the estimated  annual per vehicle cost would be about $10
(broader application of the IM240 is needed to make up for the loss in emission reductions associated
with switching from annual to biennial testing).

The average cost to repair vehicles failing the transient test for HC and/or CO is estimated to be
$ 150. Repairs for NOx failures are estimated at $ 100 per vehicle. Average repair costs for pressure
and purge test failures are estimated to be $38 and $70, respectively. It would be very rare for one
vehicle to need all three of these repairs.  Also, some vehicles will be repaired at no charge to the
owner, under warranty coverage provided by the manufacturer.

These repairs have been found to produce fuel economy benefits that will at least partially offset the
cost of repairs  Fuel economy improvements of about 6% for repair of pressure test failures and
purge test failures  were observed.  Vehicles that failed the IM240 at the established cutpoints enjoyed
a fuel economy improvement of 13% as a result of repairs. Fuel economy improvements persist
beyond the year of the test.
Section Four                                                                       Pa«e 16

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 The table below shows the costs and economic benefits of continuing IM unchanged as opposed to
 enhancing the program in required areas. This analysis shows that switching to test-only  IM240
 will reduce inspection costs by about $134 million, increase fuel economy benefits which offset
 repair costs (especially over time), and reduce overall cost to the nation by $350 million At the same
 time, the number of high paying jobs in the repair sector will increase
                         Program Costs and Economic Benefits
                        Test
                        Cost       Cost'
 Costs of Continuing I/M Unchanged
          Centralized     $ 182       $ 140
        Decentralized     $565       $252
               Total     $747       $392
 Expected Costs
      Enhanced Areas     $451       $489
         Basic Areas     $162       $113
         Grand Total    $613       $602
Millions of annual dollars in2000
                       Emission
  Emission    Evap     Test Fuel
 Test_Repair   Repair    Economy
              Cost      Savings
          Evap Test
             Fuel
          Economy
           Savings
               na
               na
              $221
              $221
 ($92)
($153)
($245)

($617)
 ($70)
($687)
  na
                                      na
($208)
($208)
            Net
           Cost*
$230
$664
$894

$336
$205
$541
        *  Net cost is derived by adding inspection and repair costs and subtracting fuel economy benefits.
 Cost  Effectiveness
 Cost-effectiveness - or the cost per ton of pollution reduced - takes into account the costs and
 benefits of an I/M program design. This includes test costs, oversight costs, repair costs, and fuel
 economy benefits. The enhanced I/M program has an estimated cost of just under $500 per ton Bv
 ^S^tw^tFF"^ Whicliare leSS effective and COSt more' ^P^y ^ve a cost per
 ton of about $15,000  (this figure vanes from area to area depending on test cost)  	
      Test-only Enhanced I/M is Far More  Cost-Effective  Than Test-and-Repair
                               Cost per Ton of VOC Reduced
                                                     $15,000
                             $500
                             •••i
                            Enhanced
                           Test-Only
                      Test-and-
                       Repair
Section Four
                                                                                 Page 17

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 National  Cost Of Doing  Less Effective  I/M

 If states were to continue implementing test-and-repair programs instead of switching to high-tech,
 test-only enhanced I/M, the result would be higher direct and indirect costs to the nation. As shown
 above, test fee costs drop with high-tech I/M. This is mainly due to reduced costs in areas that
 currently do test-and-repair, which is about twice as expensive as a comparable test-only program.
 Thus, the $350 million savings from switching from test-and-repair to test-only would be forgone.
 In addition, there are substantial indirect costs that would be incurred. The Clean Air Act requires
 states to meet specific milestones of 15% reduction in VOC emissions by 1996 and a 3% reduction
 per year thereafter, for a total of 24% by the end of 1999, when most areas must achieve the
 standard.  There are two ways for States to achieve these goals: impose additional controls on
 stationary sources (i.e., stricter requirements than those currently being implemented or previously
 implemented) or additional controls on mobile sources (e.g., no drive days).

 Enhanced I/M is the single most cost-effective source of VOC emission reductions, at a cost of $500
 per ton reduced. If enhanced I/M were not implemented, then additional stationary source controls
 would be needed to get the reductions required to achieve the 15% and 24% reductions. Stationary
 source controls, however, cost $5,000 to $25,000 per ton. If the 40 million vehicles that are
 currently in test-and-repair are not moved to more cost-effective test-only, enhanced I/M programs,
 then about 177,000 tons of VOC reductions will have to be obtained from stationary  sources instead
 (or from draconian mobile source controls like no drive days). At $5,000 per ton, this will cost
 about $885 million but at $10,000 per ton it will cost $1.8 billion. Adding in the forgone savings
 brings the total cost of continuing test-and-repair to between $1.1 billion and $2 billion.

 This does not take into account the loss in jobs and the anti-competitive effects additional stationary
 source controls will have. Especially hurt will be smaller businesses like dry cleaners, paint shops,
 bakeries, and so on that may be forced out of business because the cost of upgrading equipment and
 pollution controls will be too  expensive.
National Costs and Benefits
All Enhanced Test-only
Keep Basic & Test-and-Repair
Difference
Stationary Cost @ $5,000/ton
Total Excess Cost
Stationary Cost @ $10,000/ton
Total Excess Cost
Tons
Reduced
260,936
83,994
176,942




Cost in
Millions
$338
$574
$236
$885
$1,120
$1,770
$2,000
Section Four
                                                                                    Page 18

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    THE ECONOMIC IMPACT OF AN ENHANCED TEST-ONLY AUTOMOTIVE
                      INSPECTION PROGRAM IN  CALIFORNIA
                                    Executive Summary

 This report presents the results of a study undertaken for the American Lung Association by SRI
 International (SRI) to determine the economic impact in California of a federally proposed enhanced
 inspection and maintenance (I/M) program using dedicated test-only inspection centers.

 The program was analyzed by SRI using a model based on a proposed network of 130 stations in the
 four most serious air quality nonattainment regions in California. The model projected the job effects
 and other economic impacts in California of replacing the current Smog Check program with the
 proposed I/M 240 program in the four target areas for the period 1994-2002. The areas considered
 include over 60% of current Smog Check stations and  these stations perform almost 65% of all
 California emission inspections.

 Building the network of inspection stations for the enhanced I/M program would have an immediate
 positive economic impact in California:

        •   Construction and start-up of the network would create 4,541 jobs including
           800 construction jobs and 1,575 direct manufacturing and service jobs.

        •   The economic  impact of establishing the inspection station network would
           total $805 million including direct investment of $408 million.

 Operation of the 130 station network would create ongoing employment and economic activity.

        •   The inspection station network would employ an average of 2,575 full-time
           equivalent inspectors and staff over the 1996-2002 period. Multiplier effects
           would create an addition 3,286 jobs.

        •   From 1996-2002 the inspection network would stimulate an average of more
           than $120  million in economic activity.  For the 7-year period of operation
           studied, the cumulative impact would reach $837 million.

 More jobs would  be gained as a result of increased emission control system repair work under
 Enhanced I/M than would be lost from elimination of Smog Check inspections.

        •   Most Smog Check inspectors perform few inspections (they are primarily
           mechanics or technicians). Of the almost 16,000 inspectors in the enhanced
           areas, only 598 would loose their jobs.

        •   The most stringent and. thorough Enhanced I/M procedure would necessitate
           more repairs to emission control systems. The increased repair work would
           employ 1,634 additional parts and repair personnel over the seven year period
           of the study.                                                    r

        •   The net effect of the existing parts and repair business would be an average
           increase of 1,036 jobs.

 Implementation of Enhanced I/M in California would provide a net increase in employment and
 produce a significant positive economic impact.

        "   Tf ?U?gISyi?ient' including multiplier effects, would increase by an average
           of 8,378 full-time equivalent jobs during the 1996-2002 period.

             Ci I|?1I<:uinulative economic impact over the  period 1994-2002 would equal
             .1 billion.                                                      ^
Section Four
                                                                                page

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        TEST-AND-REPAIR VS. TEST-ONLY
Section Four                                         n  „,.
                                              Page 20

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          CAR OWNERS' ATTITUDES TOWARD EMISSIONS TESTING
                                    Executive Summary
Under contract with the American Lung Association, the Gallup Organization prepared a report
entitled "Car Owners' Attitudes Toward Emissions Testing and Other Proposed Measures to Reduce
Air Pollution," which was released in April 1993. In total, 1,001 adults, ages  18 years and older,
were interviewed by telephone from March 8-14, 1993. From this group, 912 were identified as
being members of households with a vehicle registered in the state of residence. The results
summarized below are based upon this group of 912, and have a margin of error of ± 3% at the 95%
confidence level.
The survey began by examining preferences concerning various types of vehicular pollution control
strategies, including enhanced I/M, reformulated gas, mandatory car pooling, parking taxes, stricter
parking restrictions, rush-hour toll roads, and odd/even drive day restrictions.  The measures are
ranked below in order of preference:

                    Measure               Favorable Response Rate
                    Improved I/M                    87%
                    Reformulated gas                80%
                    Car pooling                     45%
                    Parking tax                      41%
                    Parking restrictions               38%
                    Rush-hour tolls                  35%
                    Odd/even drive days             16%
Other questions involving inspection network design and convenience issues had the following
results:
       •   79% of respondents believe the separation of testing and repair is a good idea
       •   72% think separating tests from repairs helps ensure that correct repairs are done
       •   92% believe that retests should be performed by independent testers
       •   86% of those who do not favor centralized tests, still prefer independent retesting
       •   89% favor centralized test centers, if they are within 5 miles of home/work
       •   69% consider 45 minutes total travel and testing time to be reasonable
       •   81 % believe an annual test fee of $ 10 is reasonable
       •   71 % believe that even $20 per year is a reasonable test fee
Section Four
                                                                                  page

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      TEST-ONLY I/M IS EFFECTIVE AT REDUCING VEHICLE EMISSIONS

 The real test of any I/M program is whether it achieves its purpose of reducing in-use emissions from
 vehicles tested. The charts below show the emission rates from vehicles in the Arizona I/M program
 as compared to Indiana, an area that had only recently started enforcing its inspection requirement
 (thus, representing a non-I/M fleet). While emission levels start out about the same, as vehicles age
 the emission rates in Arizona are substantially lower than those in Indiana.  This shows that the test-
 only program in Arizona is resulting in substantially lower emission rates.  EPA uses data from in-
 use I/M programs and other studies of in-use vehicles to establish the emission reduction credits for
 I/M programs.
  Grams
1.8

1.6

1.4

1.2

  1
   per
   Mile  °-8
        0.6
        0.4

        0.2

          0
                  Test-Only I/M  is Effective in Reducing  Vehicle Emissions

                         Arizona vs. Non-I/M Area Average IM240 HC Emissions
                 D Indiana n=6,762

                 • Arizona n=4,519
                                        567

                                           Vehicle Age
                                                    8
                                                 10
                                                 11
        30

        25

        20
 Grams
   per  15
  Mik
        10
         0
                                  Average IM240 CO Emissions
          T
T
T
        D Indiana n=6,762

        • Arizona n=4,519
                                        567

                                          Vehicle Age
                                                                         11
Section Four
                                                                                Page 22

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 TEST-AND-REPAIR IS NOT EFFECTIVE AT REDUCING VEHICLE EMISSIONS

 The California Air Resources Board (ARB) recently completed a study using IM240 on a random
 sample of cars from the area around the ARB El Monte laboratory. The charts below show the
 emission rates from vehicles in Mesa, Arizona in 1994 as compared to the 1994 California sample
 While emission levels are about the same for new vehicles, the emission rates for both HC and CO
 among older vehicles in Arizona are substantially lower than those in California. This shows that the
 lest-and-repair program in California is not as effective as the Arizona program - by about 50%
 This is surprising since California emission rates should be lower, it has tighter new car standards
 than the rest of the country, it does a more comprehensive visual inspection than Arizona, and it does
 functional checks that are not done in Arizona.
                     California Emissions Are  Higher Than Arizona
                  Average IM240 Emissions in El Monte. CA vs. Mesa Arizona
                                      Hydrocarbons
             D California

             • Arizona
        93    92   91    90    89    88    87    86    85    84   83    &*>
                                       Model Year
                                   Carbon Monoxide
            D California

              Arizona
                                          87    86

                                       Model Year
Section Four

-------
 Neither Arizona nor California measures NOx exhaust emissions, so little difference would be expected
 when comparing the two. However, California's functional EGR check is intended to reduce NOx.  The
 chart below shows that NOx in California and Arizona are essentially the same.
                              Oxide of Nitrogen Emissions Are Similar
              D California

              • Arizona
        93
92    91     90    89
87    86     85    84    83     82    81
                                          Model Year
 Another important comparison is to look at I/M and non-I/M areas. The charts below show California
 emission rates vs. Indiana during initial start-up of its program (i.e., before repairs). California
 emission levels are essentially no different from Indiana's. This indicates that California's test-and-
 repair program has not been effective at reducing emissions.
          2

        1.5
 Grams
   per    1
  Mile
        0.5

          0
                      California Emissions are no  Lower Than Non-I/M
                                         Hydrocarbons
       I California

       I Indiana
                                         567

                                           Vehicle Age
                                                              10
                                      11
                                        Carbon Monoxide
                U California

                • Indiana
                                        567

                                           Vehicle Age
Section Four
                                                                                  Page 24

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                 EXCERPTS OF  COMMENTS ON EPA'S I/M RULE


Private Citizen  from a test-and-repair state

       "Smog checks do not accomplish anything except screw the car owner. If you fail, you just
       slip the man a twenty and you pass."


Mr. John Elston, New Jersey DEP

       "I once knew a mechanic in the State of New Jersey ... he said that, as far as equipment
       goes, 'You design it - we'll beat it.'"

California EPA

       "Preliminary results from the ongoing evaluation of our program show that it achieves
       roughly one half of the emission reductions required by the proposed performance standard.
       [emphasis  added]

       We urge EPA to delete the one-more-try-at-test-and-repair program option from the final rule,
       unless EPA can make an analytical demonstration that this type of program can be effective
       enough to comply  with the performance standard."

California I/M  Review Committee

       "The Review Committee agrees with EPA's views regarding the inherent advantages
       provided by I/M programs that separate inspections and repairs. Such programs eliminate the
       potential conflict of interest associated with inspections and repairs performed at the same
       facility."

South Coast  Air Quality Management District (California)

       "Although  the District favors a more flexible determination of performance standard
       compliance, we believe that EPA should require centralized test-only facilities."

Texas Air Control Board

       "The Air Control Board recently voted to... implement contractor-operated, test-only, high-
       tech emissions testing.

       One of the  things that we're looking at doing is a new twist on the centralized program
       concept. What Texas is proposing will allow private individuals that are local residents to
       actually operate the inspection facilities in a contracted program."

New York Department of  Motor Vehicles

       "If you [the test station] don't do bad inspections for anybody but regular customers then an
       undercover will never get you. And we [DMV covert auditors] spend days and days and
       days just trying to  get into  those stations, to get an appointment, but they won't give us an
       appointment because they  don't know us.

       And they have a list of our undercover cars. At one point there was a newsletter going
       around [that] published the plate numbers ... an association newsletter.
Section Four                                                                       Page25

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 New  York Department of Motor Vehicles - continued

        I should make the point that paper data is not good evidence in court. It is unacceptable. We
        have not been able to introduce paper evidence or quality control evidence as any kind of
        indication that there was cheating going on. You have to see it.

        We can suspend [stations] pending a hearing. And then we have to - within 30 days, we
        must provide a hearing. That screws up our administrative law system horrendously because
        everything is scheduled. All of a sudden, we have to take it out of the schedule - one of our
        hearings that we have had waiting for maybe months, and put this one in and get that one
        done. And then we get that revocation. Thirty days later, there is a stay [and the station is
        back in business].

 New  York Department of Environmental Conservation

        "New York agrees that EPA staff is right in assigning a 50% credit discount for a
        decentralized program against the model program. New York has one of the most
        sophisticated decentralized programs in operation. Our 4600 test-and-repair stations have
        computer controlled analyzers and each is on a telephone modem which allows DMV to poll
        any given station. Inspectors must log into the analyzer using a bar coded badge. Extensive
        use of the analyzer's computer controls and storage capability is made during the test
        process. Undercover investigations, and numerous other enforcement provisions are
        constantly underway. Over 50% of concealed identification vehicles set to fail are
        nonetheless,  passed by stations."

 STAPPA/ALAPCO

        "Second,  the associations firmly oppose the proposed provision to allow both the testing and
        repair of vehicles to be conducted at the same facility; we urge the deletion of this provision.
        It has been clearly demonstrated that separation of the testing and repair functions is essential
        to achieving the highest possible emission reductions from the I/M program. By providing
        the states with the opportunity of pursuing this clearly inferior approach, EPA is condoning
        an action that is cost-ineffective and will unnecessarily delay implementation of an enhanced
        I/M program that will achieve the performance standard and improve air quality."

 NESCAUM

        "We are, however, very concerned about the provision in the proposed rule to 'grant states
        the opportunity to attempt to make an enhanced, test and repair system achieve the
        performance  standard.' Such language would sanction the continuation of decentralized test
        and repair programs for the remainder of the 1990's which have little chance of meeting the
        enhanced I/M performance standard."
Section Four                                                                         Page 26

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  NATIONAL AUTOMOBILE DEALERS ASSOCIATION'S COURT CHALLENGE
                                   TO THE I/M RULE
                             Key Points from the Court's Decision

          Decided May 6, 1994 by the U.S. Court of Appeals for the District of Columbia

 First, NAD A claims that the EPA exceeded its authority under section 182 of the Clean Air Act by
 issuing its model I/M program in the form of a final rule ... rather than an informal "guidance"
 Second, NADA advances a number of arguments against the final rule aimed at exposing what it
 views as an unlawful and arbitrary bias against decentralized "test-and-repair" networks.

 We uphold the EPA's final rule against both of NADA's challenges. To the extent Congress
 required certain components of the EPA's model program to be binding on the states, the agency was
 authorized, if not required, to engage in ... rulemaking. ...  Finally, we conclude that the EPA
 properly exercised its authority to determine the manner in which decentralized testing facilities
 would be deemed equivalent to centralized facilities.

 EPA's deviation from its pre-1990 practice of issuing informal, nonbinding guidance documents is
 fully understandable ...  EPA provided a reasoned explanation for resorting to rulemaking - namely
 the agency s  experience over the last 15 years has shown that the lack of federal minimum
 requirements has led to less than effective I/M programs."

 NADA advances several related arguments in an attempt to establish that the EPA's enhanced model
 I/M program reflects an unlawful and arbitrary bias against decentralized "test-and-repair" networks
 It first questions the EPA's authority to impose  the 50 percent emission credit penalty on test-and-
 repair systems that do not establish equivalency with centralized systems. Failing that, it claims that
 the EPA failed to justify its methodology for arriving at the 50 percent effectiveness estimate Next
 it argues that the EPA unlawfully failed to establish criteria under which "enhanced" test-and-repair'
 systems ... could be considered equivalent to centralized systems. Finally, NADA contends that the
 EPA arbitrarily included the IM240 test in its enhanced model program over other, allegedly less
 costly and more effective tests.

 Each of these arguments is unavailing. In requiring states to adopt centralized networks unless
 decentralized networks were shown to be equally effective, the EPA acted with both Congress'
 blessing and good reason.  NADA can point to nothing in the statute that  prevents the EPA from
 imposing the penalty if equivalency is not shown. As the EPA has the authority to require a
 demonstration of equivalency between centralized and decentralized networks, it follows naturally
 that the agency must be allowed to establish criteria for making the comparison and a means by
 which to account for the relative ineffectiveness of the decentralized system... The 50 percent
 emissions credit penalty is simply the agency's expression of the relative  effectiveness of the two
 network types.

 Furthermore, ample evidence in the record supports the EPA's imposition of the 50 percent penalty
 The final rule cites several studies resulting from both overt and covert audits testing facilities that
 demonstrate considerable levels of improper testing and emission control  tampering in states with
 decentralized test-and-repair networks. ... The fundamental problems with these networks appear to
 be the incompetence of unlicensed and ill-trained testers and the inherent incentive on  the part of
 testers simply to pass cars along for a quick fee (or the customer's satisfaction) instead of engaging
 in time-consuming repairs. The audits also revealed that testers frequently pass the vehicles of
 familiar customers, and that customers sometimes "shop" test-and-repair  stations in search of a free
pass.  ... the agency surely did not create the 50 percent estimate out of whole cloth.

 NADA mischaracterizes the final rule in suggesting that the EPA refused to treat any decentralized
 networks as equally effective; in fact, the EPA deems decentralized test-only networks equally
effective to centralized systems. ... These features  of the final rule give teeth to Congress' clear
preference for centralized testing, and at the same time provide the states ample flexibility to adopt
equally-effective decentralized networks. ...  Finally, we conclude that the EPA presented sufficient
support for the inclusion of the IM240 emissions test in its model program.


Section Four                                                                         Page ^

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 QUANTITATIVE ASSESSMENTS OF TEST-ONLY AND TEST-AND-REPAIR  I/M
                                      PROGRAMS

                                     Executive Summary

 »  In the early 1980s, EPA established I/M program credits after conducting a large-scale study of
    the test-only I/M program in Portland, Oregon.

 »  For the enhanced I/M rulemaking, EPA used data from over 10,000 covert audits to assess the
    effectiveness of I/M programs. These results, along with the tampering survey data, form the
    basis for EPA's 50% effectiveness discount for test-and-repair programs.  (It is important to note
    that covert audits assess the inspector's response to strangers, not to regular customers with
    whom there is an on-going business relationship that might be jeopardized by a test failure and
    resulting undesired repairs. Hence, these data may underestimate the actual extent of improper
    testing in test-and-repair programs.)

       •   Over 10,000 covert audits conducted by state agencies with vehicles set to fail the tailpipe
           test and/or the visual anti-tampering inspection show that improper testing in test-and-
           repair programs occurs 48% of the time.

       •   293 covert audits conducted in 12 test-and-repair states by EPA, also with vehicles set to
           fail, show improper testing 81% of time.

       •  Audits of 49 test-and-repair I/M stations in Missouri and New York,  both of which use
          the most advanced B AR90 analyzers, found improper emission testing 34% and 46% of
          the time on the initial test. Taking into account retests, improper emission tests are
          estimated to occur between 56% and 71% of the time.

       •   Audits of 13 test-only programs found no instances of improper emission testing on
          either initial tests or retests.

       •   Visual inspections are conducted in a few test-only programs and improper testing has
          been found in those that had not implemented quality assurance programs. Good quality
          assurance resulted in only rare occurrences of improper visual tests.

 »   EPA used data from national tampering surveys of over 60,000 vehicles to assess the
    effectiveness of anti-tampering programs.

       •   Tampering survey data taken in Portland, Oregon, the site of a test-only program, were
          used as the original basis for tampering check credits in the MOBILE model. These
          credits recognized visual check effectiveness levels ranging from 33% - 95%, varying
          with type of check.

       •   Subsequent state and national tampering surveys in test-and-repair states, show that test-
          and-repair programs have not been as effective in finding and fixing tampered vehicles.

 »   The California I/M Review Committee conducted a study involving 1100 vehicles that were
    recruited, screened, and sent to test-and-repair stations for testing and repair.

       •   The Committee concluded that vehicles were inspected correctly only 24% of the time.
          There was no significant change in inspection effectiveness from the  previous study,
          despite the introduction of BAR90 analyzers and tougher enforcement.

       •   The Committee also found that the emission reduction shortfall from the program ranged
          from 59%-68% depending on pollutant.


Section Four                                                                        Pa8e 28

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    EPA used all of these data to adjust the emission reduction credits in MOBILE5a to reflect current
    knowledge about the effectiveness of test-only and test-and-repair I/M programs.

    Testimony and other comments on EPA's proposed option, to grant provisional equivalency to
    test-and-repair enhanced I/M programs pending a subsequent demonstration of equivalent
    emission reductions, overwhelmingly indicated that there is no known way to make test-and-
    repair program equivalent to test-only.

    The conflict of interest in test-and-repair programs for failing a good customer is likely to
    intensify in enhanced I/M programs where that customer would face as much as $450 in repair
    costs.
Section Four                                                                         p

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     Quantitative Assessments  Of Test-Only  And Test-And-Repair I/M Programs

 1.0    Introduction

 Over the last 15 years, EPA has amassed a vast array of quantitative information about the
 effectiveness of inspection and maintenance programs. Many thousands of vehicles have been
 involved in studies, covert audits, and other investigations that contribute to this array of data. EPA
 has used these data in developing the emission reduction credits that are available to I/M programs in
 the MOBILE model, currently MOBILESa. These data came from audits of I/M programs conducted
 by both EPA auditors and state auditors, dozens of tampering surveys conducted on roadways
 across the country, and studies conducted by states and EPA laboratories (or contractors to EPA).
 This paper explains these data and the methodologies used to acquire the information.

 There are three primary sources of data that EPA uses to establish credits:  audit data, tampering
 survey data, and, for lack of better term, special study data. Each  of these sources will be discussed
 in depth in the following sections. Before getting into the details of these data, however, it is useful
 to review the requirements of the Clean Air Act and the process EPA went through to establish the
 I/M rules.

 2.0    Background

 The Clean Air Act Amendments of 1990 (the Act) require serious and worse ozone  areas and carbon
 monoxide areas with a design value  over 12.7 parts per million to implement an enhanced I/M
 program. The Act requires EPA establish a performance standard  for enhanced I/M programs, to
 establish binding guidance (i.e., regulations), and to require that enhanced programs have certain
 specified features. The most controversial of those required features is specified in
 §182(c)(3)(C)(vi):

     Operation of the program on a centralized basis, unless the State demonstrates to the
     satisfaction of the Administration that a decentralized program will be equally  effective.

 Section 182(a)(2)(B) requires EPA to take "into consideration the Administrator's investigations and
 audits of such programs."  In April of 1991, EPA issued draft guidance for I/M programs.  Public
 workshops were held on April 22 and April 25 to explain and get comment on the proposed
 guidance. Prior to issuance of the draft guidance, EPA met with state air agency representatives,
 environmental groups, motor vehicle manufacturers, I/M industry representatives, and automotive
 dealer and service station associations to explain "high-tech" I/M testing including IM240 and
 evaporative system pressure and purge tests. Public comment was positive to EPA's proposals to
 establish new high-tech test procedures as the basis for the enhanced I/M performance standard.
 Over 300 written comments were reviewed by EPA prior to publication of a Notice of Proposed
 Rulemaking for I/M requirements in the Federal Register on July 13, 1992. The proposed rule called
 for a high-option performance standard for areas required to implement enhanced I/M programs.
 The proposed regulatory text was published in the Federal Register on July 28, 1992.  Public
 workshops on the proposal were held in Washington, D on August 12  and August  13,  and public
 comments were accepted through August 27, 1992. The final I/M rule was published on November
 5, 1992.

 In the NPRM, EPA asked for comments on three different ways for States to submit a decentralized
program which could be approved as "equally effective" to a centralized system.  In the first option,
 "presumptive" equivalency would be granted to decentralized, test-only programs.  EPA based this
on two important features of the decentralized test-only approach: the conflict of interest which
contributes to improper testing in test-and-repair networks is eliminated and the focus of the
decentralized test-only business is solely on testing.  In the second option, "provisional" equivalency
would be granted to upgraded test-and-repair programs for initial plan approval provided there was
clear legislative authority and a commitment to abandon the network should formal evaluation show


Section Four                                                                        Pa8e 30

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   >•    |D°A  mS WUJ ^P^P61" ?stmg' oversight and quality control were present. In the third
 option EPA proposed that "case-by-case" equivalency would be granted to Lt-and-repak programs
 if a state could demonstrate based on past performance, that the program would achi*ESKS
 reductions greater than the default level credits. Special credits would be assigned in sucKes
 NESCAUM the American Lung Association, NRDC, STAPPA/ALAPCO*, the New York DEC
 the New York Department of Motor Vehicles (DMV), the California EPA, the California IM Review
 Committee, and many others commented that in light of evidence that decentralized test-and-reDair
 progr™ cannot mwt a centraliasd, test-only performance standard, it was inappropriate and
 probably illegal for EPA to allow for provisional equivalency. They stated that no evidence has been
 provided that decentralized test-and-repair programs can work as well as test-only programs  These
 commenters also argued that to grant provisional equivalency without some confidence in the
 prospects for success is irresponsible, in that it would allow ineffective and costly programs to
 continue while air quality improvement suffers. The National Automotive Service Association urged
 EPA to be clear in setting equivalency requirements so that small business owners were not misled
 The organization was concerned that a change to test-only after evaluation would mean that owners'
 would not have time to recover their investments. Parties argue that either test-and-repair programs
 should not be allowed at all, or up-front equivalency demonstrations should be made

 Parties arguing that test-and-repair programs could not and would never be able to meet a centralized
 •esi;01r?ly enhanced Performance standard cited past experience, especially with the B AR90 systems '
 in California and New York. They also believed that the inherent conflict of interest the large
 number of stations, and the  institutional barriers they faced made it impossible for a decentralized
 test-and-repair system to work equally effectively. Even with its highly motivated program
 management and after spending from $6-7 per vehicle on oversight, the California program is still
 experiencing high improper testing rates;  it is not likely that any other state can or will do better.

 EPA was impressed by the fact that the state agencies that are charged with implementing enhanced
 1/M programs stated in no uncertain terms that they knew of no solution to the problem of test-and-
 repair ineffectiveness and virtually all urged EPA to eliminate provisional equivalency from the final
 rule.  EPA was also surprised to hear that many representatives of the decentralized, test-and-repair
 industry were not in favor of the provisional equivalency approach taken in the rale  They
 considered it a non-option because of the uncertain situation it created and the political difficulty such
 an annroach would far*                                                r         *i«.«iijr au^u
an approach would face.
Two states, California and New York, were in a particularly good position to comment on the
equivalency of test-and-repair networks due to the length of their experience, the size of their
programs, and the strength of their oversight efforts. California is recognized by most observers as
having the most effective and comprehensive decentralized, test-and-repair system in the country
The California I/M Review Committee's Draft Fourth Report to the Legislature, issued on September
8, 1992 reinforced the findings discussed in the proposed rule that test-and-repair I/M programs
were achieving only 50% (at best) of the potential emission reductions. The report shows that the
SSfT^n^PSS?1 HS? U£d £ California is achieving only 42% of the potential for HC,
32% for CO, and 34% for NOx. The Committee also writes that:
      "Limited evidence available to the Review Committee suggest that improper Smog
     Checks may occur more frequently under circumstances where the vehicle owner has had
     a  previous business  relationship  with the Smog Check station.   Under these
     circumstances, there is an inherent conflict of interest between the desire of the Smog
     Check station to satisfy the customer and the need to perform a proper and thoroueh
     inspection that may cause the vehicle to fail "                                uiuiuugn
* STAPPA/ALAPCO -  State and Territorial Air Pollution Program

 DEC - Department of Environmental Conservation.
Section Four
                                                                                   Page 31

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 The Review Committee also concluded that given the enormous expenditures on enforcement in
 California, additional expenditures on enforcement to improve compliance would not be cost-
 effective.

 The New York DMV presented extensive testimony on the pitfalls of implementing a test-and-repair
 program. New York is using the most advanced BAR90 arrangement with modem hook-ups to a
 centralized data processing system and automatic polling of stations.  The Department testified that
 the 50% credit reduction estimated for test-and-repair programs by EPA is supported by the
 Department's findings. The DMV set out in designing its BAR90 system to "close every loophole"
 Nevertheless, the testimony from New York demonstrates that despite having the most sophisticated
 analyzers, excellent data collection and analysis, and aggressive covert audits, other fundamental
 problems impeded effective performance. EPA views many of these problems as major stumbling
 blocks and encourages the reader to review the docket for the full text of this testimony. Two
 examples will provide a flavor. First, New York testified that data analysis alone is insufficient
 evidence in court, that in order to successfully prosecute, the State must catch the inspector doing the
 improper testing. Second, the State found, as have California and others, that catching inspectors
 actually doing improper testing is extremely difficult. NY DMV testified:

      "If you [the inspection station] don't do inspections for anybody but regular customers -
      bad inspections for anybody but regular customers, or [for] good, strong referrals - from
      either another station or some person you know and trust - then an undercover will never
      get you."  (underline reflects oral emphasis)

 This is a fundamental limitation in the test-and-repair system. EPA's experience with covert audits is
 that it is very hard to overcome the natural suspicion of inspectors at stations. They know the state is
 out doing covert audits and most take the necessary precautions to avoid being detected engaging in
 improper testing; many times EPA covert auditors are discovered by the station and confronted.
 Thus,  a quality assurance system has two effects: It eliminates egregious improper testing and it
 makes inspectors cautious about for whom they improperly test. However, it also makes improper
 testing harder to detect because it is driven underground. California showed that with the
 expenditure of vast amounts of resources it could reduce the covert audit false improper test rate from
 about  80% to about 20-30%. But the I/M Review Committee's work shows that much of this
 change was a diminution in detection not wholly a reduction in actual improper testing or an
 improvement in program performance.

 The due process system makes it virtually impossible to detect, stop, and prevent improper testing in
 test-and-repair systems.  New York DMV found that while the BAR90 system has improved its
 ability to detect improper testing through data analysis, the legal system essentially doesn't allow data
 to be introduced as evidence. Even when an inspector is caught doing an improper inspection during
 a covert audit, the plea before the judge is that an isolated mistake was made inadvertently - even
 when data indicated a larger problem. The inspector gets off with a reprimand, or a short
 suspension.  Even when a revocation is obtained, the inspector can get a stay within 30 days and is
 back in business, or the business simply reincorporates with different principals (often in-laws).
 Under these circumstances, the type of analyzer, the type of test, the amount of oversight, and the
 expenditures made are essentially irrelevant.

 The House Committee Report on the Clean Air Act gives some insight into the Committee's thinking
 on this question when it states, "The intent of the Committee is that enhanced inspection and
 maintenance programs as required under this subsection are to either be centralized, or to include
 other program elements which taken together allow a decentralized system to be as effective as a
 centralized system in identifying noncomplying motor vehicles, and causing such vehicles to be
 repaired." (House Report 101-490, Part 1, p. 240) The basic  problem with the provisional
equivalency approach was that neither EPA nor the states or other commenters know  of any "other
program elements taken together" that will achieve equal effectiveness, except the separation of test
 and repair. While some comments indicated concern over particular aspects of the definition of a


Section  Four                                                                         Page 32

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 decentralized test-only system, most concurred with EPA that such a system could be equally
 effective. However, the docket was conspicuously lacking in ways to make decentralized, test-and-
 repair programs equally effective (i.e., none in addition to those that have already been tried and
 failed).

 In light of the absence of known elements to make test-and-repair equally effective, EPA shared the
 concern that provisional equivalency for test-and-repair systems would simply delay the
 implementation of effective enhanced I/M programs, that it would create more confusion and
 hardship than a transition to a test-only network, and would be inordinately expensive to attempt
 Therefore, EPA dropped the provisional equivalency option for test-and-repair systems from the
 final rule. Nevertheless, besides implementing a decentralized, test-only system, states still have the
 option under the provisions of case-by-case equivalency to demonstrate that their existing
 decentralized, test-and-repair programs will be as effective as a test-only system. States will have to
 make this demonstration at the time of SIP submittal as contemplated by the statute.

 3.0   Covert Audit Data

 EPA first started auditing I/M programs in 1984.  Since that time, 94 audits have been conducted in
 31 states that are required to implement enhanced or basic I/M under the Clean Air Act Amendments
 of 1990 (a complete list is included in Appendix A). These audits were conducted under the auspices
 of the National  Air Audit System. The National Air Audit System procedures for I/M audits were
 developed with the participation of STAPPA/ALAPCO and with the advice of General Accounting
 Office.  The audits consist of a range of activities aimed at assessing the effectiveness of I/M
 programs and include such things as records review, data analysis, overt audits of inspection lanes
 and stations, and other activities. The audits found significant problems in test-and-repair programs
 which were  documented in several reports published throughout the 1980s.  In 1988 EPA began
 conducting covert audits with vehicles set to fail tampering checks during audit site visits In
 conducting these audits, EPA randomly selected stations and lanes in the inspection network in order
 to achieve an unbiased sample. Different geographic areas within the region being audited were
 covered. The number of covert vehicle runs depended on the size of the program and the time and
 resources available during the site visit. EPA also began encouraging states to use this technique
 because it quickly became evident that this was a powerful tool for identifying improper testing.
Section Four                                                                          n
                                                                                    Page 33

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 Figure 1 shows the results of EPA covert audits in test-and-repair I/M programs. The sample size is
 shown on each bar in the chart and the fraction of vehicles that were improperly passed is shown on
 the end of each bar. Overall, out of 293 covert audits, 81 % of them were done improperly. The
 range is from a low of 28% improper testing and a high of 100%.
                                           Figure 1
                                 Test-and-Repair Programs
                    Fraction of Improper Tests in EPA  Covert Audits
           Overall

     Massachusetts

          Virginia

         Michigan

    New Hampshire

       New Jersey

         Missouri

      Pennsylvania

        New York

           Nevada

         Colorado

          Georgia

      New Mexico
 Figure 2 shows the results from covert audits of test-and-repair stations conducted by State oversight
 agencies. One major difference between EPA covert audit studies and state covert audit studies is
 that sample sizes from state audits - which are conducted year round - are much larger. Overall, state
 covert audits show lower improper test rates than EPA covert audits. There are several contributing
 factors. One of the biggest problems with covert audits is the risk of being discovered by the
 inspection station. EPA auditors have a much lower risk of discovery because, typically, EPA
 auditors and covert vehicles are new to the area. State agencies have sometimes found that lists of
 state audit vehicles are circulated among stations, allowing inspectors to identify the vehicle when it
 arrives for inspection. Another factor is that EPA audits always involve setting the vehicle to fail the
 test. State auditors often do covert audits with vehicles set to pass as well, and some of these are
 mixed into the data in Figure 2. As a result, these covert audits do not effectively assess the rate at
 which test stations improperly pass vehicles. Nevertheless, using a program weighted average, the
 state audit results show that improper testing occurs about half of the time for perfect strangers on the
 initial test.
Section Four
Page 34

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                                           Figure 2

                                 Test-and-Repair Programs
                    Fraction of Improper Tests in State Covert Audits
    New Hampshire

      Massachusetts

             Ohio
         Michigan

          Virginia
         Missouri

           Alaska
        New York

          Georgia
           Nevada

        California

             Utah

         Colorado
53%
      Total: 10,120
 Covert audits in test-and-repair systems understate actual levels of improper testing since covert
 auditors are strangers in the test stations in which they get tested.  This is especially true of emission
 tests since improper testing on this aspect requires active intervention by the inspector to get a
 passing result, as opposed to a tampering check which involves passively neglecting to perform the
 test The  fourth report to the legislature by the California I/M Review Committee states-  "Limited
 evidence available to the Review Committee suggests that improper Smog Checks may occur more
 frequently under circumstances where the vehicle owner has had a previous business relationship
 with the Smog Check station." Information collected during EPA covert audits and analysis of test
 data confirm this.                                                                J

 Analysis of test data from test-and-repair programs shows that vehicles that initially fail frequently
 get one or more retests resulting in a pass immediately after the initial test. EPA covert audit
 experience shows that inspectors will do unauthorized retests (or multiple initial tests) to get a
 passing result. A wide variety of strategies are used to accomplish this:  dilute the sample, change
 engine speed, test another vehicle (clean piping), etc.  State quality assurance data show evidence of
 innumerable cases of issuance of certificates of compliance in test-and-repair programs without
 having done proper emission inspections.

 Figure 3 shows EPA data on covert audits in test-only programs. EPA has done covert auditing  less
 frequently in test-only programs, mainly because overt audits have never indicated any improper
 testing problems with emission testing. With the  addition of visual inspections to test-only programs
 in the late 1980s, EPA initiated covert audits with vehicles set to fail both the emission test and the
 visual check. The audits confirmed earlier findings with regard to the emission tests:  that imororjer
 emission testing was not a problem. The results on the  visual check, however, showed verv low
 levels of improper testing with the exception of the State-run system in New Jersey
Section Four
                                                                                    Page 35

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                                         Figure 3
                                   Test-Only  Programs
                   Fraction  of Improper Tests in EPA Covert Audits
          Improper Visual Test Rate

          Improper Emissions Test
          Rate
                  50%
                              11%
          0%     0%
           Maryland
      0%
Arizona
                                                                         23%
Covert audits reveal the improper testing rate when vehicles are brought in for initial testing by
customers unknown to the testing facility. EPA believes that improper testing will occur at least as
often when retests are performed following an initial failure. B AR90 equipment was designed to
make it difficult, or at least inconvenient, to perform an improper test. It was hoped that BAR90
programs would overcome the problem known to exist in test and repair networks.   The most
relevant data on whether increased oversight and technological innovation can stop improper testing
comes from recent studies of BAR90I/M programs. The results of the California I/M Review
Committee study are discussed in Section 5.  EPA's audit of the Missouri BAR90 I/M program
found that inspectors improperly passed vehicles set to fail the emission test 34% of the time.
Because at a minimum, improper testing occurs on the retest at the same frequency, the overall
improper emission test rate in Missouri is estimated to be 56%. Covert audits of the New York
BAR90 I/M program showed similar results.  In that case, vehicles set to fail the emission test were
improperly passed 46% of the time, yielding an estimated overall improper emission test rate of 11%

It is important to note that covert audits assess the inspector's response to strangers, not to regular
customers with whom there is an on-going business relationship that might be jeopardized by failing
the customer and subjecting him or her to undesired repairs. Hence, these data may underestimate
the actual extent of improper testing in test-and-repair programs. This conflict of interest associated
with failing a good customer is likely to intensify in enhanced I/M programs where that customer
would face as much as $450 in repair costs. The pressure to falsely pass such customers will likely
be much greater.

4.0  Tampering Survey Data

With the cooperation of State and local governments, EPA has conducted roadside tampering
surveys of motor vehicles in cities throughout the country each year since 1978. These surveys
provide information about national tampering rates and trends in tampering behavior. The surveys
are conducted for 5 days in each city visited.  Generally, 5-10 different sites are selected through out
Section Four
                                                Page 36

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  the city, and with the aid of local or state police, motorists are randomly pulled over and their
  vehicles emission controls are inspected.  The typical survey covers about 500 vehicles. Appendix B
  provides a list of the tampering survey locations and the number of vehicles inspected in each In all
  40 states have been visited and over 65,000 vehicles have been inspected.

  In developing MOBILESa credits, EPA analyzed the tampering survey data from the late 1980s to
  assess whether test-and-repair programs and test-only programs were being effective at reducing
  tampering rates and keeping them low. Until 1984, when Houston, Texas  and California began
  comprehensive anti-tampering programs, the test-only program in Portland, Oregon was the only
  one that inspected the complete range of emission control components. Portland's test-only I/M
  program has been intensively studied by EPA (see discussion in Section 5) and the impact of the
  visual inspection program was used as the basis for establishing emission reduction credits in
  MOBILES for anti-tampering programs.

  Figures 4  and 5 show the tampering rates found in each individual city for programs that were"
  operating  for at least 2 years at the time of the survey.  Two no-I/M-program areas are included for
  reference  and the rates are all from 1987 and 1988 surveys. Figure 4 shows that test-and-repair
  programs  show high overall tampering rates (i.e., for catalyst, inlet, air, PCV and evaporative
  canister) compared to the test-only program in Oregon.
                                      Figure 4

                Overall Tampering Rates in Select I/M Programs

 San Antonio  ESSSSfr^WSfr^^

     El Paso

Baton Rouge

    Houston

       Tulsa

New Orleans  Ks/vXNxV^^XNXs^Xxxx^M 12.9%

      Dallas  ^^•••I^I^^BHH 12-7%




     Raleigh  ^^••^^^^•^•10.4%

     Fresno  ^^^^^^^^^^^^H 9.3%

                              6.3%
        Medford

        Portland  [
                                    D No Program

                                    • Test-and-Repair

                                    D Test-Only
J 5.5%
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                                                                                  Page 37

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Similarly, Figure 5 shows that even for the simplest of the visual checks - catalyst and inlet - the anti-
tampering programs in test-and-repair states were not as effective as those in the test-only program in
Oregon.
                                         Figure 5
             Catalyst and Inlet Tampering Rates in Select I/M Programs
 San Antonio
     El Paso
      Dallas
       Tulsa
     Raleigh
Baton Rouge
New Orleans
     Fresno
    Charlotte
    Houston
                                                7.1%
                              2.9%
                            2.6%
                         1.8%
       Portland  |    |  1.0%
        Atlanta  ^[0.9%
       Medford  I    10.9%
E3 No Program
H Test-and-Repair
D Test-Only
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 With the exception of Oregon, test-only programs did not include any visual anti-tamperine checks
 until the late 1980s; they only did emission tests. Nearly all of the test-and-repair programs include
 visual anti-tampenng checks. Since the steady-state emission tests often would not fail a vehicle
 with a missing catalyst, for example, one would expect to find that combined anti-tamperine and
 emission test programs show lower tampering rates then those that perform only emission tests
 Figure 6 compares the tampering rates in seven test-only and twelve test-and-repair programs for
 each major check. Contrary to expectations, the tampering rates are lower in the test-only programs
 despite the fact that only two of them do tampering checks while all but one of the test-and-reDair
 programs do tampering checks.                                                      ^
                                         Figure 6

             Tampering Rates in Test-and-Repair  and Test-Only Programs
          • Test-and-Repair

          D Test-Only




                      8%
                                                                        15%
                         13%
            12%
         2%
              2%
           PCV
Catalyst
Inlet
  Fuel
Switching
 Evap
Canister
                                                                       Air System
Section Four
                                                                                 Page 39

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Another objective measure of the effectiveness of anti-tampering programs is the frequency with
which aftermarket catalysts are found during tampering surveys, i.e., evidence of actual replacement
of catalysts. Since aftermarket catalysts are much cheaper than original equipment manufacturer
parts, one would expect them to be the replacement of choice in all programs. Figure 7 shows the
findings for aftermarket catalysts from areas with catalyst inspections. The three test-only programs
show high rates of aftermarket catalyst installation.  On the other hand, the test-and-repair programs
show low rates of aftermarket catalyst usage, in some cases no different than non-I/M areas.
                                         Figure 7

               Aftermarket  Catalyst Usage in Anti-Tampering Programs
            Phoenix


            Medford


             Tucson


              Tulsa


      Oklahoma City


             El Paso


        San Antonio


          Covington


              Dallas


       New Orleans

                                                 5:6%
                                       t t t t
N\\\ \SNSXX\\S\ \ N \ \
                                              5.4%
                                     4.5%
      1.5%
                   C_I No Program

                   • Test-and-Repair

                   E3 Test-Only
Section Four
                                                 Page 40

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                                         Figure 8

              Tampering Rates in I/M  and Non-I/M  Areas in California
         60
         50
         40
         30
         20
         10
                  Pre 1975
1975-1979        1980-1983

       Model Years
Overall
                                      I/M
              D NON  I/M
A variety of sources of data on test-and-repair anti-tampering programs are available. The California
I/M Review Committee has done extensive review and evaluation of the California test-and-repair
program. The study used a variety of techniques including roadside tampering surveys.  One of the
many important findings of this study was that roadside tampering rates for the items checked in the
I/M test did not differ substantially between the vehicles that had already been subject to I/M and
those that had not.  It should be noted that California uses a broader definition  of the term
"tampering" for both its survey and I/M checklist than that used by EPA; thus, the overall rates are
not comparable to EPA's national survey rates. These results are illustrated in Figure 8.
Section Four
                                                Page 41

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                                        Figure 9
     Frequency of Proper Tampering  Tests in California's Covert Audit Program
      100%

       90%

       80%

       70%

       60%

       50%

       40%


       30%

       20%


       10%


        0%
                                 Full Effectiveness  Level
  Observed Effectiveness Level
                Inlet
   Evap
Canister
PCV
Air System   Catalyst
 In addition to the survey data, audits of test-and-repair anti-tampering programs find improper
 inspections.  Covert investigations continually find that inspectors fail to check for components, fail
 to fail tampered vehicles, and sometimes fail to do the inspection at all.  California's covert audit
 work indicates that licensed inspectors neglect to fail tampered vehicles in the majority of cases.
 Figure 9 shows the results by component.  During EPA overt audits in test-and-repair programs,
 inspectors have been asked by auditors to demonstrate an inspection, and are frequently unable to do
 the check correctly, either neglecting to check for one or more components or improperly identifying
 components.
Section Four
                                                 Page 42

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5.0  Maior Studies
Several major studies have been conducted to evaluate the effectiveness of I/M programs.  Two of
those studies will be discussed here:  an EPA study of the test-only program in Portland, Oregon
and work performed by the California I/M Review Committee.

The Portland, Oregon study was conducted in the late 1970s and was used as the basis for
developing the credits for I/M programs that are contained in the original MOBILE model.  At the
time, Portland was one of three operating I/M programs, all of which were test-only. EPA's study
of Portland involved about 2,300 vehicles in Portland and about 600 vehicles in the non-I/M area of
Eugene, Oregon. Passing and failing vehicles were recruited in Portland to determine how well the
program identified vehicles that needed repair, what effects commercial repairs had on those
vehicles, the effectiveness of the retest, and the duration of the emission reductions achieved. .A
variety of other issues were addressed as well, including fuel economy and cost-effectiveness.
Vehicles recruited in Eugene were used as a control group.  The study found that the program was
achieving a 47% reduction in HC emissions and a 42% reduction in CO emissions among  vehicles
that failed the test.  The results of EPA's study of this test-only I/M program form the basis for I/M
credits that were part of the 1982 State Implementation Plans.  EPA did not at that time make a
distinction between the amount of credit for test-only programs vs. test-and-repair programs.

The California I/M Review Committee's "Evaluation of the California Smog Check Program and
Recommendations for Program Improvements: Fourth Report to the Legislature" is one major study
that played a central role in EPA's latest adjustments to the credits in the MOBILE model. As part of
the evaluation the California Air Resources Board (GARB) recruited a large sample of in-use vehicles
to evaluate the effectiveness of the inspections and the changes in emissions resulting from vehicles
going through the program.  The vehicles were covertly taken to licensed Smog Check facilities for
regular inspections and the results were monitored.

Vehicles were selected randomly from the registration files and were further sorted in order to obtain
a representative cross-section of model years and technology types (i.e., the combination of fuel
metering and emission control system). Owners were offered a variety of incentives to allow their
vehicles to be used for the study. Candidate vehicles were given an initial screening consisting of a
complete emission and visual check to find failing vehicles. Previous studies by CARB had found
that vehicles that ought to pass are rarely falsely failed; hence, this study focused on the fate of
vehicles that were high emitters. Vehicles that failed  the initial screening were given a confirmatory
Smog Check, a thorough diagnosis of emission defects, and a baseline FTP test, including
evaporative SHED tests if the diagnosis indicated problems with the vehicle's evaporative  control
system.  Vehicles that were found to have passed the initial screening were returned to the owners
and dropped from the program. A total of 1,110 participated in the next phase of the program as
undercover cars.

The undercover vehicles were taken to official Smog Check stations by either CARB staff or student
assistants posing as motorists in need of a certificate  of compliance.  Smog Check stations were
randomly selected and visited until one of the following occurred: the vehicle was failed and properly
repaired, as determined by a diagnosis performed afterwards; the vehicle was failed and qualified
for, and received a waiver; the vehicle (improperly)  passed Smog Checks at two separate stations.
All vehicles received thorough diagnoses and FTPs after completion of the field testing to determine
the change in emission levels as a result of any repairs that were performed.

The study found that, on vehicles with at least one underhood defect only 58.5% failed the Smog
Check. By comparison, in a 1986 study using 795 undercover vehicles 59.6% of such vehicles
failed the Smog Check. Hence, quality of these inspections did not change significantly despite
B AR90 analyzers, retraining of inspectors, and tougher enforcement instituted since that time  When
looking at all types of tests, it was found that only 24% of the test vehicles received a complete,


Section Four                                                                         page43

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 proper inspection. Thus, many vehicles were passed with defects that were not detected or fixed.
 The improper test rate on the tailpipe emission test alone was not analyzed by the Committee. The
 study found that the California Smog Check program was achieving a reduction of 19.6% for HC,
 15.3% for CO, and 6.7% for NOx. These results are 41 % of the potential HC benefits,  32% of the
 potential CO benefits, and  34% of the potential NOx benefits. In other words, the emission
 reduction shortfall ranges from 59% to 68% for the three pollutants.

 6.0  Conclusions

 The data EPA has used in making decisions about I/M programs comes from several sources,
 including national tampering surveys, EPA and state audits, and special studies like the one
 conducted by the California I/M Review Committee and EPA's study of the Portland, Oregon I/M
 program.  These studies gathered quantitative data on the testing of well over 10,000 vehicles in
 programs across the country.

 EPA initially developed the tailpipe emission test credits in the MOBILE model from the results of a
 large-scale study of the test-only program in Portland, Oregon. EPA subsequently developed anti-
 tampering program credits based on a tampering survey of the Portland area in 1982.  The roadside
 results were used as an objective measure of the effectiveness of the Portland program. These
 credits were initially made available to all I/M programs regardless of network type. Many test-and-
 repair programs instituted visual inspections and claimed credit in the SIP for these tests.
 Subsequent national tampering surveys in these cities showed that the credits EPA established were
 not reflected in the roadside tampering surveys conducted after the programs were in effect for
 several years. Program audits snowed that inspectors routinely pass vehicles that should fail. EPA
 used the data on visual anti-tampering inspection effectiveness from the audits and national tampering
 surveys to adjust the emission reduction credits in MOBILE5a to reflect the results of a well run,
 test-and-repair program. The benefits were reduced by 50% or 75% depending on the emission
 control component tested.

 Similarly, EPA found in audits of I/M programs, that emission testing was done objectively in test-
 only I/M programs. While minor procedural violations were apparent in some programs (e.g.,
 neglecting to shut off accessories during the test), there was never any evidence that inspectors were
 attempting to get vehicles that should fail to pass improperly. On the other hand, the data shows that
 inspectors in test-and-repair programs routinely attempted to get failing vehicles to pass the initial
 test, and this for perfect strangers.  EPA believes that the rate of improper emission testing in test-
 and-repair programs is at least as great on  retests as that found on initial tests. These data led EPA to
 reduce the emission test credits by 50%  in MOBILESa for test-and-repair programs.
Section Four                                                                         Page 44

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     NATIONAL
                    Appendk A
AIR AUDIT  SYSTEM  AUDITS PERFORMED
                           1
                           Is       Location
                           I
                           I Maryland
                           I Maryland
                           I Maryland
                           i Massachusetts
                           I Massachusetts
                           I Massachusetts
                           |Medford,OR
                           I Memphis, TN
                           I Memphis, TN
                           I Memphis, TN
                           • Memphis, TN
                           • Michigan
                           I Michigan
                           1 Missouri
                           I Missouri
                           I Missouri
                           I Nashville, TN
                           I Nevada
                           B
                           • Nevada
                           I New Hampshire
                           I New Hampshire
                           I New Jersey
                           I New Jersey
                           I New Jersey
                           I New Jersey
                           I New Mexico
                           I New York
                           I New York
                           I New York
                           I North Carolina
                           I North Carolina
                           I Northern Kentucky
                           I Northern Kentucky
                            Northern Kentucky
                            Pennsylvania
                            Pennsylvania
                            Portland, OR
                            Provo, UT
                            Provo, UT
                            Salt Lake City, UT
                            Seattle, WA
                            Seattle, WA
                            Spokane, WA
                            Virginia
                            Virginia
                            Wisconsin
                            Wisconsin
Location
Anchorage, AK
Arizona
Arizona
Arizona
California
Cincinnati, OH
Cleveland, OH
Colorado
Colorado
Colorado
Colorado
Connecticut
Connecticut
Connecticut
Connecticut
Dallas, TX
Dallas, TX
Davis County, UT
Davis County, UT
Delaware
Delaware
Delaware
District of Columbia
District of Columbia
District of Columbia
District of Columbia
El Paso, TX
Fairbanks, AK
Georgia
Georgia
Georgia
Georgia
Houston, TX
Houston, TX
Houston, TX
Houston, TX
Houston, TX
Illinois
Illinois
Indiana
Indiana
Indiana
Indiana
Louisiana
Louisiana
Louisiana
Louisville, KY
Type
Test&Repair
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test-only
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test-only
Test-only
Test-only
Test-only
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test-only
Test-only
Test-only
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test-only
Date *
August 86 1
May 84 1
July 91 1
August 91 1
January 86 ^
June 89 i
June 89 1
May 84 1
August 85 1
August 88 1
July 901
May 841
September 85 1
September 86 1
February 89 1
March 871
December 88 1
August 871
October 851
March 851
June 88 1
November 89 1
June 841
March 851
November 88 1
August 90 1
June 87 i
August 86 i
January 85 1
January 86 1
June 86 i
November 88 1
March 85 i
April 85 1
August 85 1
April 86 i
January 88 1
May 87 1
June 89 1
August 85 i
January 87 1
February 90 1
November 90 1
December 86 •
December 87 1
March 89 1
March 86 •
•'ORMED BY EPA
Type
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test-only
Test-only
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test-only
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Hybrid
Hybrid
Hybrid
Hybrid
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test&Repair
Test-only
Test&Repair
Test&Repair
Test&Repair
Test-only
Test-only
Test-only
Test&Repair
Test&Repair
Test-only
Test-only
Date
November 85
June 90
June 91
May 84
July 86
June 89
October 88
May 90
June 84
June 86
March 88
March 87
April 90
March 85
May 87
August 92
November 85
October 84
December 90
October 88
September 90
July 84
November 86
March 89
September 90
June 90
December 84
June 86
April 89
March 85
July 88
October 87
August 89
August 90
March 86
May 89
April 85
January 87
August 87
October 85
February 86
December 88
September 87
June 84
April 90
July 85
July 90
Section Four
                                                                                     Page 45

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                                                     Appendix B
                             NATIONAL TAMPERING  SURVEY  SITES
                                                                                                 Number of
                                                                                   Site      Year  Vehicles
                                                                             Camden        1986    498
                                                                             Covington      1986    500
                                                                             Seattle         1986    504
                                                                             Los Angeles    1986    505
                                                                             Tucson         1986    499
                                                                             Baton Rouge    1986    500
                                                                             Kansas City     1985    469
                                                                             Kansas City     1985    475
                                                                             Fresno         1985    466
                                                                             Charlotte       1985    430
                                                                             Raleigh         1985    501
                                                                             Louisville      1985    456
                                                                             Wilmington     1985    502
                                                                             Portland        1985    436
                                                                             D.C. Suburbs    1985    380
                                                                             Long Island     1985    305
                                                                             Philadelphia    1985    446
                                                                             Cleveland      1985    383
                                                                             baton Rouge    1985    438
                                                                             Houston        1985    450
                                                                             Albuquerque    1985    449
                                                                             Bakersficld     1984    320
                                                                             Reno          1984     83
                                                                             Dallas          1984    268
                                                                             Birmingham    1984    300
                                                                             Washington     1984    300
                                                                             Cincinnati      1984    325
                                                                             Various Sites    1984    270
                                                                             New York      1984    308
                                                                             Boston         1984    286
                                                                             Tampa         1984    327
                                                                             St. Louis        1984    314
                                                                             Portland        1984    603
                                                                             El Paso         1984    334
                                                                             Milwaukee     1984    388
                                                                             Cook County    1983    268
                                                                             Sedgwick County 1983    290
                                                                             Houston        1983    374
                                                                             Denver         1983    332
                                                                             Los Angeles    1983    270
                                                                             Phoenix         1983    297
                                                                             South Dade Co.  1082    309
                                                                             Baton Rouge    1982    183
                                                                             Houston        1982    293
                                                                             Tulsa          1982    282
                                                                             Several Location 1982    290
                                                                             Several Location 1982    324
                                                                             Minneapolis    1982    307
                                                                             Seattle         1982    312
                                                                             Portland        1982    310
                                                                             Los Vegas      1982    275
                                                                             Houston        1981    209
                                                                             Chattanooga    1981    190
                                                                                            1979    328
                                                                                            1979    330
                                                                                            1979    300
                                                                                            1979    318
                                                                                            1979    274
                                                                                            1979    236
                                                                                            1979     98
                                                                                            1979    616
                                                                                            1978    306
                                                                                            1978    416
                                                                                            1978    216
                                                                                            1978    324
                                                                                            1978    335
                                                                                            1978    356
                                                                             62,565

State
Texas
Kentucky
North Carolina
West Virginia
Kentucky
Florida
California
Massachusetts
Indiana
Texas
Tennessee
Kentucky
North Carolina
Florida
California
California
Arizona
Texas
Louisiana
Florida
Michigan
Ohio
Ohio
Wisconsin
Montana
Missouri
Alaska
Alaska
Colorado
Arizona
Arizona
California
Louisiana
Texas
Texas
New Mexico
Oklahoma
Texas
South Carolina
New York
New Jersey
Alabama
Florida
Oregon
Florida
Oklahoma
Texas
Texas
Texas
DC Suburbs
New Jersey
Florida
North Carolina
Tennessee
Georgia
Washington
Oregon
California
Louisiana
Kentucky
Missouri
Illinois
Florida
Texas
Tennessee
Pennsylvania
Virginia
Connecticut

Site
Beaumont
Covington
Greensboro
Huntington
Lexington
Miami
Santa Barbara
Boston
Gary
Houston
Knoxville
Louisville
Raleigh
Tampa
San Diego
Bakersfield
Phoenix
Dallas Suburbs
Baton Rouge
Jacksonville
Detroit
Cincinnati
Cleveland
Milwaukee
Missouri
Springfield
Anchorage
Fairbanks
Denver
Tucson
Phoenix
Stockton
Baton Rouge
Houston
El Paso
Albuquerque
Oklahoma City
San Antonio
Columbia
New York
Various Sites
Birmingham
Orlando
Medford
Miami
Tulsa
El Paso
Houston
Dallas
Maryland
Newark
Orlando
Charlotte
Nashville
Atlanta
Spokane
Portland
Fresno
New Orleans
Covington
St. Louis
East St Louis
Jacksonville
Houston
Memphis
Pittsburgh
Richmond
Hartford

Year
1990
1990
1990
1990
1990
1990
1990
1990
1990
1990
1990
1990
1990
1990
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1989
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1987
1986
1986
1986
1986
1986
1986
1986
1986
Number of
Vehicles
500
610
570
600
610
500
542
611
536
580
575
951
525
500
500
520
465
422
4967
580
441
390
368
490
500
540
503
436
465
424
450
500
523
550
515
500
505
533
505
406
520
500
500
328
450
500
500
500
508
450
431
575
600
505
531
382
531
500
500
500
413
551
477
507
580
504
500
428

State
New Jersey
Kentucky
Washington
California
Arizona
Louisiana
Missouri
Kansas
California
North Carolina
North Carolina
Kentucky
Delaware
Maine
Virginia
New York
Pennsylvania
Ohio
Louisiana
Texas
New Mexico
California
Nevada
Texas
Alabama
D.C.
Ohio
New Jersey
New York
Massachusetts
Florida
Missouri
Oregon
Texas
Wisconsin
Illinois
Kansas
Texas
Colorado
California
Arizona
Florida
Louisiana
Texas
Oklahoma
New Jersey
Rhode Island
Minnesota
Washington
Oregon
Nevada
Texas
Tennessee
Arizona
Delaware
Minnesota
New Jersey
Tennessee
Texas
Virginia
Vermont
Washington
Virginia
Texas
Tennessee
Maine
Delaware
Total
Section Four
Page 46

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   ANALYSIS  OF INVALID EMISSION TESTING IN THE CALIFORNIA SMOG
                                  CHECK PROGRAM
                                    Executive Summary

 Under a work assignment with EPA's Office of Mobile Sources, the environmental consulting firm
 Sierra Research, prepared a report entitled "Analysis of Invalid Emission Testing in the California '
 Smog Check Program,  which was finalized on April 27, 1994, and was principally the work of
 authors Thomas C. Austin, H. Anthony Ashby, and Thomas R. Carlson. Sierra Research an active
 participant and[primary research consultant to the California I/M Review Committee, was p'articularlv
 well positioned to perform this study, having conducted the original 1,100 vehicle study upon which
 the Committee's Fourth Report to the Legislature was based. Data from this same sample were used
 in preparing the report here summarized.                                       F

 Thereport presents the results of Sierra's comparison of before- and after-repair emission scores for
 1,100 defective vehicles. Posing as ordinary motorists, California Air Resources Board (CARB)
 employees presented these vehicles to random Smog Check stations, where before- and after-rer/air
 emission scores were gathered Before- and after-repair confirmatory tests were also performed at a
 separate CARB test site including both an official California Smog Check idle inspection and a
 Federal Test Procedure (FTP) transient test. Based on a comparison of the Smog Check versus
 CARB emission scores it was found that the Smog Check station emission test results were invalid
 for approximately 17.5% of the vehicles. This is the fraction of defective vehicles for which the
 lower readings reported by Smog Check stations cannot be explained by test-to-test variability  In
 most cases these vehicles failed the emission standards at CARB after "passing" a post-repair retest
 at a Smog Check station.                                                        v

 On average, the vehicles showing the greatest discrepancy between the Smog Check and CARB test
 results had significantly higher overall FTP and idle emissions during the initial (pre-Smog Check)
 testing at CARB  While the final Smog Check test results for these vehicles indicate that idle
 emissions have been reduced to the same level as other vehicles (presumably the result of repairs),
 the before and after CARB test results reveal that no significant change in either FTP or idle
 emissions actually occurred. This lack of an FTP emission reduction suggests that the idle emission
 reduction reported by the Smog Check station was not the result of any actual repairs and mav be
 the result of fraud.                                                      r    »       J

 For vehicles where the last Smog Check test was confirmed by CARB testing,  idle CO emissions
 were reduced from an average of 1.63% to 0.73%  - a 55% reduction.  In such  cases, the FTP scores
 also showed notable before- and after-repair emission reductions, as follows: HC - from 3 86 to
   7Sf? \\l   Ieduct\on£ C0 -JT?m 40'5 to 32-7 8foM (a 19% reduction); and NOx - from 2.20
 to 1.92 (a 13% reduction). For vehicles with a large discrepancy between the Smog Check and
 CARB results, not only were the idle CO emissions higher to begin with (3.0% on average) the idle
 emissions after the vehicle was returned to CARB were actually higher (3.36%), while the Smog
 Check stations in question reported (falsely) that the idle CO emissions had been reduced to 0 69%
 The FTP emissions before Smog Check - 7.41 g/mi HC, 64.6 g/mi CO, and 2.00 g/mi NOx - were
 substantially higher than for the other vehicles.  After return from the Smog Check station  FTP
 emissions were shown to be reduced on average as follows: HC  - from 7.41 to 6.65 g/mi (a 10%
 reduction); CO - from 64.6 to 65.0 g/mi (a 0% reduction); and NOx - from 2.00 to  1.79 g/mi (an
 11% reduction).                                                              &    v

Because the occurrence of improper after-repair retesting was determined to be  proportional to the
emissions of vehicles, it is estimated that such improper retesting reduces the benefits of the Smos
(5C
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            CONVENIENCE OF TEST-ONLY INSPECTION NETWORKS

No subject associated with enhanced I/M has seen as much mis-information circulated as this one.
Critics of test-only I/M claim that motorists will have to drive half-way around the world and wait
three life times to get a test-only test. The only problem with this claim is that there is a substantial
track-record available on the performance of test-only programs.  Providing convenient testing
services is not terribly difficult:  it merely requires building enough stations and lanes and staffing
them so that motorists do not have to travel too far or wait in line when they get to the station.
Indeed, EPA's rule requires that states make a demonstration in the SIP that the network of test
stations is sufficient to  insure short wait times and short driving distances, and that regular testing
hours are established and motorists are not arbitrarily refused a test.

Several features of an I/M program may affect convenience.  Test frequency is the single most
significant factor influencing I/M convenience. If motorists only  have to get tested every other year
instead of annually, inconvenience is cut in half. The IM240 test only needs to be performed every
other year and, as a result, motorist convenience is greatly improved over the annual testing done
today.  Apart from test  frequency, other influential features include: cost, driving distance, certainty
of service, hours of operation, wait times, and necessity for multiple trips.

The most successful test-only systems are those operated  by a contractor that wins exclusive rights to
provide testing services for an entire metropolitan area or state, in a bidding process that factors in
convenience, as well  as price and technical competence.  Convenient, contractor-run, centralized
programs are currently  being operated in a wide range of large and small cities in  15 states as a result
of good network design, contractual requirements to insure convenience, and competition in the
bidding process. Contracts typically require station siting such that 80-90% or more of all motorists
are within 5 miles of a test facility.  Contracts also include operational features that insure service
delivery, including a provision that when there are more than 4  vehicles in a queue waiting to be
tested, spare lanes be opened and additional staff employed to reduce wait times.  Test-only systems
also use telephone hot lines and signs out in front of stations so that motorists get information on
station locations, hours of operation, current wait times and the like. As the charts below show,
these programs have been highly successful at providing convenient service.
                Wait Times in the Wisconsin Test-Only Program


                           1 % Wait More Than 15 Minutes
                          99% Wait Less Than 15 Minutes
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                       Wait Times in the Illinois Test-Only Program
                                     Overall Monthly Average
                                                                      TWR
                          Operating Days in the Month of April, 1991
The data shown for Illinois and Wisconsin are typical for contractor-run, high-volume, test-only I/M
programs. By contrast, test-and-repair networks are not as convenient when it comes to wait times.
Since test-and-repair stations do not usually maintain statistics on how long motorists wait, telephone
polls have been used instead. Two polls by Riter Research have addressed these issues; one
performed in  1987 and another in 1991. The Atlantic-Richfield Corporation, ARCO, has a franchise
of test-and-repair stations in California known as SMOG PROs. ARCO asked their franchisees to
keep statistics on wait times and driving distances.  The charts below show the results.  These data
show that motorists in the California test-and-repair program generally wait much longer to get a test
than in those well-run, test-only systems. In the last two audits of basic I/M programs conducted by
EPA, the audit team kept track of how long it took to get a test during covert audits of test stations.
In the Arizona test-only system, the average wait time for a test was 6 minutes.  In the Missouri test-
and-repair system, the average wait time for a test was 45 minutes.


                          ARCO Smog Pro Takes Longer Than Test-only
     >30 minutes
   21-30 minutes
     <20 minutes
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                                                                                  Page 49

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                        ARCO Smog Pro Customers Drive Just as Far
      < 10 miles
       < Smiles
91%
                   Average Wait Time in Minutes for a Test-and-Repair Test

                               Based on Telephone Polling by Riter Research
       Georgia
     Michigan
     California
    New York
 Government-run test-only systems (especially those in New Jersey and the District of Columbia)
 tend to be inadequate both in terms of convenience and quality. Long lines often form at these
 government-run test stations. This is mainly because there are an insufficient number of lanes and
 personal to handle the volume of vehicles involved. Antiquated equipment and procedures also
 contribute to inconvenient service.

 Test-only programs also provide convenient hours.  Motorists do not have to talce off from work in
 order to get tested. Early morning, evening, and weekend hours are provided in contractor-run
 systems. The hours are fixed so you know when you arrive at the station that it will be open for
 business. When you arrive at the station, you know you will get your vehicle tested and not be
 asked to  return at some other time, make an appointment, or go to another station. According to a
 Riter Research poll ("Attitudes and Opinions Regarding Vehicle Emission Testing", September
 1991) many motorists in test-and-repair stations do not get such convenient service, as shown
 below.
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                   Most People Do Not Get Immediate Service in Test-and-Repair
                                                                                        59%
            Had to Wait
            Left Vehicle
    Had to Go Elsewhere
          Had to Return
In test-only programs, motorists that fail the test have to take the vehicle to a repair shop of their
choice to get repairs made.  In test-and-repair programs, the potential is there to get repairs done at
the same location where the inspection is performed. However, recent polling research indicates that
over 50% of motorists that fail the test in test-and-repair networks go to another repair shop to get the
repairs performed. This is understandable given that 1) the motorist get the test performed at which
location is convenient, and 2) most motorists go to their regular repair shop once the vehicle fails.
Thus, the  "one-stop shopping" notion is not the typical pattern of behavior.

While convenience is often  a concern of residents in an area about to implement a test-only program
once the program is running, most vehicle owners' actual experience is satisfactory to them  In
every contractor-run test-only program, the overwhelming majority of motorists express satisfaction
with the systems in every poll conducted on the subject. Recent national surveys reinforce these
findings.  A majority of motorists reported in the Riter Research poll that testing centers were
conveniently located in both centralized and decentralized networks. Despite all of the hyperbole
coming from test-only critics, test-only  networks are convenient to motorists.
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              MAINTENANCE ISSUES
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                               GENERAL  REPAIR ISSUES

Effective and efficiently performed repairs are vital to the complete success of an I/M program
While effective tests are necessary to identify the high-emitting vehicles, and good oversight is
necessary to ensure that the program runs smoothly overall, it is through the repairs that the actual
environmental benefits are achieved. While some repair technicians are familiar with the diagnosis
and repair of driveability problems, they often have considerably less experience diagnosing and
repairing emissions problems. This is because many malfunctions that cause high emissions do not
produce driveability problems; hence, motorists do not notice them and do not seek to have them
repaired until these problems cause their vehicles to fail an I/M test. EPA, state and local
governments, repair industry associations and others are undertaking a number of efforts to develop
a high level of expertise in the repair industry in I/M areas in order to ensure that vehicles are
properly diagnosed and fully repaired at the lowest possible cost and in the most efficient manner.

In the past, most I/M areas took a completely laissez fake approach to the maintenance side of the
I/M equation.  The assumption was that market forces would be  effective in generating demand for
adequate training, leading to efficient and effective repairs. There is some evidence that this has been
effective to a limited extent in the better run test-only I/M areas.  In these areas, the rigor of the test
and the amount of the waiver are critical to creating the market forces that lead to industry
improvement.  To the extent that enhanced I/M further increases the rigor of the I/M program  the
demand for effective repairs will grow and the need for better training programs will also increase.
Rather than wait for these market mechanisms to flow, EPA believes it is important for states to take
several actions to facilitate industry improvement.  EPA's I/M rule requires states to monitor
technician performance and provide motorists  with statistical information on success rates, to insure
that adequate training programs are available to technicians in the community on advanced diagnosis
and repair, and to provide technicians with technical assistance to help them understand the program
and make effective repairs. These three requirements are further discussed below.

Performance  Monitoring

The concept behind performance monitoring is to let vehicle owners know how well repair facilities
are doing in terms of getting cars to pass re-inspection on the first trip back to the inspection station.
Performance monitoring also lets repair facilities themselves know how they are doing so they can
learn to do better. Finally, performance monitoring lets I/M program officials know each repair
facility's success rate so they can actively counsel the technicians who are most frequently causing
the public the unnecessary inconvenience and expense of multiple repair trips.

Performance monitoring is a new concept in most I/M areas, but has been done in some areas for
many years with general acceptance by the repair industry and public appreciation for the service. At
a minimum, four statistics are tracked on each repair facility: the number of vehicles submitted for a
retest after repair by the repair facility, the percentage passing on first retest, the percentage requiring
more than one repair/retest trip before passing, and the percentage receiving a waiver. This
information is compiled into a list and given to motorists that fail the enhanced I/M test. (Note that it
will take some time after initial start-up of enhanced IM programs to accumulate sufficient data to
publish these statistics). Some states may gather and provide alternative statistics which convey
similar information on the relative ability of repair facilities in providing effective and convenient
repair,  in light of the age and other characteristics of vehicles presented for repair at each facility.

On an annual basis, each repair shop in the state that does repairs on vehicles that fail the enhanced
I/M test will receive a "report card" showing how well they have been doing repairing vehicles.
These report cards will show statistics similar to those provided to the public and any additional
information states decide would be useful to include.  The idea here is to provide objective feedback
to repair shops to help them continuously improve the business.
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 By making information on the performance of repair facilities available to the public, performance
 monitoring enables motorists to make informed choices as consumers of automotive repair services,
 which enables market forces to drive improvements in repair industry performance.

 Technical Assistance

 Like performance monitoring, technical assistance programs have been in place in some I/M areas for
 many years and have been positively received by the repair industry in those areas. The concept
 behind technical assistance is that the state develop outreach programs to keep the repair industry
 informed of changes in the inspection program, training course schedules, common problems being
 found with particular engine families, diagnostic tips and the like on a regular basis. Some states
 also have trained technicians on staff that can actually assist commercial technicians with specific
 repair problems.  These state technicians also provide assistance to repair shops in such areas as
 equipment calibration, testing procedures, and similar technical issues.

 Many states distribute a newsletter to repair shops that provide these kinds of information.  Examples
 are the California Bureau of Automotive Repair's Repair Reporter and the State of Wisconsin
 Department of Transportation's The VIP Analyzer. Also, some states in the process of developing
 enhanced I/M programs are requiring the I/M contractor to provide technical assistance services.

 A variety of independent I/M newsletters are published these days.  One such newsletter is The
 CSCV I&M Quarterly Update. This newsletter was developed by the Coalition for Safer, Cleaner
 Vehicles and is published for CSCV by the Aftermarket Research Institute, Inc. (CSCV is a
 nonprofit organization formed to assist states in the adoption of effective emissions and safety
 inspection programs.) More information on The CSCV I&M Quarterly Update can be obtained by
 writing to:

              Coalition for Safer, Cleaner Vehicles
              32 ID Street, NE
              Washington, DC  20002
              Phone:        202-543-4499
              Fax:          202-544-7865

 Newsletters are also published by several private companies. Technician ONLINE publishes a
 monthly newsletter, Driveability Technician.  Automotive Information Systems, Inc. also publishes a
 newsletter. Autoliner.  Additional information and addresses for these companies can be found in
 Appendix 3.  Brentwood Communications publishes a newsletter titled Emission Repair Monthly.
 which provides information on emissions theory, diagnostics and computerized vehicle repair
 procedures. Information on this newsletter can be obtained by writing to the following address:

              Brentwood Communications
              P.O. Box 2595
              Vista, California  92083
              Phone:        800-697-9678

 In addition, Carter Environmental Communications publishes a newsletter titled I&M Update, which
 provides information on I/M-related issues. Information on this newsletter can be obtained by
 writing to the following address:

              Carter Environmental Communications
              18 North Street
              Portland, Maine  04101
              Phone:        800-246-3388
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Another newsletter, The Automotive Emissions Repair Network, provides information on IM240
emissions and diagnostics, including working with scan tools, multimeters, lab scopes, 4 and 5
exhaust gas analyzers and repair grade IM240 equipment.  Information on this newsletter can be
obtained by writing to the following address:

              The Automotive Emissions Repair Network
              Rural Route Number 1, Box 122
              Barnstead,NH 03218
              Phone:        603-664-2955

Newsletters are not the only way to provide information to the industry. One state has already
discussed plans to develop an electronic bulletin board to provide technicians and repair facilities
with access to performance results and I/M program information.  In addition, EPA is aware of at
least one electronic bulletin board which has been established informally by repair technicianslo
share information on I/M issues.  Also, Technician ONLINE, a private company, operates an
electronic bulletin board which enables a technician to access technical bulletins and service
information compiled directly from field experiences. This bulletin board also functions as a hotline
service.

Hotline services are another important element of technical assistance programs. The state program
agency must provide a hot line service that provides a basic level of technical service in order to
assist the technician during the repair process and also answer legal and policy questions related to
specific vehicle conditions and repairs. Some state have chosen to contract for some of these
services.

Certification and  Training

Mandatory repair technician certification is not an EPA requirement but EPA strongly encourages
states to purse certification programs. EPA does require that the state take action to get adequate
diagnosis and repair training programs started at local community colleges or vocational schools, or
to attract private training providers to offer the kinds of training needed. States need to ensure that
training in the following areas is available:

       1)  Diagnosis and repair of malfunctions in computer controlled, close-loop vehicles;

       2)  The application of emission control theory and diagnostic data to the diagnosis and repair
          of failures on the transient emissions test and the evaporative system functional checks;

       3)  Utilization of diagnostic information on systematic or repeated failures observed in the
          transient emission test and the evaporative system functional checks;

       4)  General training on the various subsystems related to engine emission control.

Certification programs offer the additional advantage of conferring recognition on technicians and
facilities that make the effort to upgrade their emission repair capabilities, which in turn gives the
public a way to find facilities and technicians with  emission repair expertise. There are a number of
certification programs carried out nationally by private organizations. The American Automobile
Association (AAA) has a facility  certification program, while the National Institute for Automotive
Excellence (ASE) has a technician certification program. A number of states have programs to
certify facilities, technicians, or both.  In most states the program is voluntary, only the state of
Michigan requires that technicians be licensed in order to practice. In a number of states, repairs
must be performed by a certified  technician (or at a certified facility) in order to have the expenditures
count toward a waiver. In some  states technicians are required to pass a course or test developed by
the state in order to be certified.  In others they are  required to achieve a specified level of
certification through a national organization, and some states require both. Facility certification


Section Four                                                                           p&ge55

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 requirements generally include a requirement that one or more technicians at the facility gain national
 or state certification, and that certain types of repair equipment be present.

 Vehicle  Maintenance Initiative

 EPA has undertaken a number of activities in conjunction with repair industry associations and
 educational organizations to increase the availability of emission repair training, increase the
 awareness in the industry of the importance of developing emission repair expertise, and to raise the
 profile of the professional repair technician.

 As part of this initiative, EPA awarded a three-year grant to the National Automotive Technicians
 Education Foundation (NATEF) in September 1992, to improve the quality and increase the number
 of automotive education programs in specific urban areas that have the worst air quality. The
 objective of the grant is to increase the number of industry-certified secondary and post-secondary
 auto tech programs in ozone and CO nonattainment areas. The grant authorizes NATEF to set up a
 mentoring process between automotive education institutions in selected areas so that schools that do
 not have ASE certification can be assisted by qualified personnel from an ASE certified program to
 achieve certification of their programs. EPA is also assisting a number of educational organizations
 in developing courses and instructional materials on emission repairs, and is also working to
 publicize the availability of the various training opportunities.

 EPA publishes VMI Update on a bimonthly basis to provide information on various VMI initiatives,
 training activities and other I/M program information. Contact Marilyn McCall at U.S. EPA, 401 M
 Street, SW, Washington D.C. to get on the mailing list.
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                      DIAGNOSTIC EQUIPMENT AND TOOLS

 Repair facilities should have a number of basic diagnostic tools.  Following is a list of these basic
 tools, along with a brief description of their functions.

 H   Digital Multimeter.  A digital multimeter (DMM) is a test instrument capable of measuring
           several properties of electricity. These properties are:

           a)    Voltage: the electrical force that pushes the electrons through the electrical circuit.
                 This force is called the Electro-Motive Force (EMF) and is measured in volts.

           b)    Current: the movement of electrons in a circuit. Current is measured in terms of
                 amperage,  which represents the number of electrons (expressed in units of
                 coulombs, where one coulomb = 6.28xl018 electrons) that pass through a circuit
                 in a second.

           c)    Resistance: the electrical force which opposes the movement of electrons through
                 the circuit.  One unit of electrical resistance (which is equal to that of a conductor
                 in which a current of one ampere is produced by a potential of one volt across its
                 terminals) is referred to as an ohm.

           A digital multimeter measures direct current (electrical current flowing in one direction)
           and alternating current (electrical current which alternates direction). If a repair facility
           does not have a DMM, they should have a AC/DC voltmeter, an ammeter to measure
           current, and an ohmmeter to measure resistance.

2)   Scanner. A scanner is also known as a diagnostic readout tool. It converts computer pulses or
           signals directly into a digital or number display.  This device makes it easier to read
           electronic trouble codes.

3)   Laboratory Oscilloscope.  An oscilloscope is a cathode ray tube that displays a line pattern
           representing voltages  in relation to time. Voltage is shown along the vertical axis and
           time  is shown along the  horizontal axis.  Repair facilities may have a  laboratory
           oscilloscope as part of an engine performance analyzer. An engine performance analyzer
           essentially consists of several pieces of test equipment mounted in one cabinet. Besides
           an oscilloscope, the analyzer may  include a DMM, tach-dwell,  exhaust gas analyzer,
           pressure-vacuum gauge, cylinder balance tester, compression tester, cranking balance
           tester, vacuum pump, and timing light.  An oscilloscope must have a time base and
           amplitude resolution adequate for troubleshooting vehicle sensors.

4)   Temperature Gauge. A temperature gauge (pyrometer) is frequently used  to measure the
           temperature of various components, such as radiator temperature. The temperature
           obtained with the  gauge can be compared to specifications.   An electronic digital
           pyrometer is often used to make very precise measurements, such as the temperature of
           the exhaust manifold at each exhaust port. Lower temperature at any exhaust port would
           indicate a misfiring cylinder.

5)   Pressure Gauge. A pressure gauge is frequently used to measure air and fluid pressure in
           various systems and components, such as fuel pump pressure or engine compression
           stroke pressure. Some pressure gauges can also be used to measure vacuum.

6)   Vacuum Gauge. A vacuum gauge is used to measure  vacuum, such as the vacuum  in an
           engine's  intake manifold, vacuum diaphragms, vacuum solenoid switches  and the
           carburetor mixture solenoid.
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 7)    Vacuum Pump.  A hand held vacuum pump provides a source of suction and is used in
           conjunction with a vacuum gauge to test various vacuum devices.

 8)    Gas Flow Meter. A gas flow meter is used in detection and diagnosis of purge failures.

 9)    Compression Tester Or Cylinder Leak Down Tester. A compression tester is used to measure
           the amount of pressure during the engine compression stroke.  A cylinder leak down
           tester performs a similar function, measuring the amount of air leakage out of the engine
           combustion chambers. If readings from these devices are out of specifications, such
           problems as bad intake valves, burned exhaust valves, bad rings, pistons, or cylinders,
           or a blown head gasket may exist.

 10)   Timing Light With Advance Capability.  A timing light with advance capability not only
           measures engine timing, but also exact distributor advance with the distributor installed in
           the engine. (Timing advance occurs when the spark plugs fire sooner on the engine's
           compression strokes.  More timing advance is needed at higher engine speeds to give
           compression enough time to develop pressure on the piston's power stroke.) This type
           of timing light has a degree meter built into the back of its case, which will register exact
           advance. Most large engine analyzers also have this feature.

 11)   Four Or Five Gas Exhaust Emission Analyzer.  An exhaust gas analyzer draws a sample of the
           exhaust gas out of the car's tailpipe.  A four gas analyzer measures the amount of CO,
           HC, CO2,  and O2 in the exhaust. A five gas analyzer, which also measures NOx, may
           be needed in  enhanced I/M areas, where there is a NOx performance standard. The
           information provided by  a gas analyzer indicates the air fuel ratio entering the engine.
           Repair facilities may have a gas exhaust  emission analyzer  as part of an engine
           performance analyzer.

 12)   Tachometer. The tachometer measures engine speed in revolutions per minute.  It is used to
           adjust engine speed settings and perform other tests.

 13)   Dwell Meter Or Duty Cycle Meter.  A dwell meter measures the amount of time that voltage is
           applied to  the ignition coil to energize it (duration of distributor point contact) and is
           measured in degrees of distributor rotation. A dwell meter is used primarily with older
           ignition systems. In cars without electronic ignitions, variation in the dwell meter reading
           indicates distributor wear problems. With electronic ignitions, dwell change with engine
           speed can be normal.  A duty cycle meter measures duration of an electronic pulse. The
           duration is expressed as a percentage representing the width of the pulse relative to the
           width of the cycle from pulse to pulse. In a vehicle with an electronic ignition, the duty
           cycle will increase at high speeds and decrease at low speeds.

 14)   Breakout Box. A breakout box is essentially a box with a series of test terminals, or lugs,
           which can be connected to the vehicle's computer wiring harness.   A DMM can be
           touched to specific box terminals which correspond to various systems, and test values
           can be compared to specifications.

 15)   Service Information.  Access to service information in electronic form via modem  during
           operating hours.
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                     ADVANCED  DIAGNOSTIC  PROCEDURES

In order to diagnose causes of emission failures in today's complex computer-controlled vehicles,
and to ensure that a repaired vehicle will pass an EM240 retest, advanced diagnostic procedures wili
be necessary to pinpoint the causes of many emissions failures.  The following sections briefly
discussed how advanced procedures such as wave form diagnostics using an oscilloscope and use of
repair grade IM240 can be used to diagnose emission failures. Use of new technology to diagnose
catalyst failure is also briefly discussed.

Development of  Diagnostic  Procedures

Clearly, there are a large number of possible repairs which may be necessary to correct emission
failures.  Thus, accurate and  complete diagnosis is critical to effectively repair new technology
vehicles. In earlier EPA studies, one of the major causes of continuing to fail emission cutpoints
was  insufficient diagnosis.  Thus, EPA has undertaken  studies to develop better diagnostic
procedures.  In a recent study, which has not yet been released in report form, EPA used "advanced
diagnostic procedures" to diagnose and repair 31 vehicles with failing emissions. These procedures
relied heavily on wave form diagnostics (RG240 and other dynamometer emissions data were not
used). All 31 of the vehicles were successfully repaired.  Nine of these vehicles (29%) required
catalyst repairs, 21 vehicles (67%) required oxygen sensor repairs, and 6 vehicles (20%) required
both catalyst and oxygen sensor repairs.  Similar procedures are now being marketed in the repair
industry.

Trace-Based Diagnostics

EPA'S I/M rule requires that motorists that fail the I/M test be provided with software generated,
interpretive diagnostic information based on the particular portions of the test that were failed. One
way this requirement could be met is through analysis of IM240 trace patterns from failing vehicles.

If the typical pattern of second-by-second emissions during the IM240 driving cycle is known for
both a vehicle in proper condition and for vehicles with certain common defects, the repair technician
may be- able to narrow the focus of his or her diagnostic efforts just by interpreting the data from the
official emission test.  For example, a certain emissions pattern during the final deceleration of the
IM240 might be associated with leaking fuel injectors, a problem that is otherwise difficult to
diagnose. It is likely that vehicles of different models would have somewhat different typical and
aberrant emissions patterns, so the interpretation task would be assisted by a computerized data base
of this information. Possibly, a computer could do the pattern analysis also, and print a list of likely
problems which even less sophisticated technicians could investigate.  While this idea is potentially
very powerful, it is clear that a considerable data base of testing and repair experience must be
assembled before its practicality can be tested. This issue is further discussed in the section below
entitled, Second-by-Second IM240 Emission Report.

Advanced  Diagnostic  Strategy  Involving Oscilloscope

An oscilloscope can be used to diagnose problems in any vehicle system that has a voltage output
which changes in amplitude over time.  The pattern of voltage values over time is  known as a
waveform. A properly functioning vehicle system typically has a characteristic waveform which a
repair technician can easily recognize. Deviations from this characteristic waveform represent  some
system malfunction, and specific types of malfunctions have characteristic deviations in  some
property of the waveform.  Waveform diagnostics may be particularly useful in diagnosing problems
with fuel injectors and oxygen sensors.

Advanced Diagnostic Strategy  Using Repair Grade  IM240
Section Four
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 The EM240 transient emissions test is performed with specialized testing equipment that costs more
 than what the overwhelming majority of repair shops can afford, somewhere between $75,000 and
 $125, 000 per installation.  Thus, diagnosing failed vehicles and verifying that subsequent repairs
 are sufficient to adequately reduce emissions to passing levels is believed by many to be made more
 difficult because official test equipment won't be available in repair shops.  In response to this, EPA
 has worked with the equipment industry to develop equipment for this purpose and conducted a
 preliminary study of low cost IM240 repair verification equipment system.  This repair verification
 (or repair grade) equipment system is termed the RG240 in order to avoid confusion with the more
 thorough official EV1240 test equipment.

 The RG240 was developed using the same operating procedures and equipment concepts as the
 IM240. The RG240 uses the same driving schedule as the IM240. It also uses a dynamometer and
 measures mass emissions.  RG240 mass emissions are calculated for each second and summed to
 get a composite total following the same procedure as the IM240.

 The RG240 system shows an acceptable correlation with the IM240 emissions test for repair
 verification. The RG240 system can be used to determine if repairs have adequately reduced
 emissions from IM240 failing vehicles. Due to compromises in the RG240 system design to
 minimize costs, the RG240 cannot determine the actual IM240 mass emissions of a vehicle.  Because
 of the qualitative nature of the RG240 emission levels, repair technicians using the RG240 should
 repair vehicles to levels as low as feasible below the RG240 target scores.

 RG240 Test Equipment

 One of the main concerns during the development of the RG240 concept was to keep the "retail" cost
 of the developed system as low as possible. Accordingly, the RG240 is based on equipment which
 already exists in repair shops, or is substantially less expensive than the corresponding IM240
 equipment.

 Costs for the RG240 were reduced by using a simpler dynamometer which  is adjustable for vehicle
 load, but has more limited inertia weight capability.  HC, CO, CO2, and NOx emissions analyses are
 performed with a BAR90 emissions gas analyzer.  The constant volume sampler uses a critical flow
 venturi rated at approximately 100 standard cubic  feet per minute (SCFM) (i.e., a much lower
 capacity CVS).

 The use of a fixed 2000 pound inertia weight on the RG240 will under load heavier vehicles on the
 acceleration portions of the driving schedule in comparison to the IM240. This should cause lower
 RG240 emissions, but because the RG240 determines a more qualitative change from the before and
 after repair tests, the effect should be negligible  (the test will only be used on vehicles that have
 already failed, so the potential for false failure is not a major problem as it is with the official test).
 RG240 manufacturers are offering products with simulated inertia that should improve the load
 simulation of the RG240.

 In order to measure mass emissions from vehicles during testing, it is necessary to know both the
 volume  of exhaust air flow and emission concentration. Both the EM240 and RG240 equipment
 systems use a CVS which performs two functions, dilution of the exhaust with air, and a surrogate
 measurement of the vehicle exhaust flow through measurement of an air diluted exhaust mixture.
 Both emissions tests also use an exhaust collection tube which is much larger in diameter than a
 vehicle's exhaust pipe. The collection tube is positioned around the vehicle's exhaust pipe and
 draws additional air used for dilution around the exhaust pipe.  The vehicle's exhaust is diluted so
 that water condensation and further reaction of emissions will not occur. The air flow in the CVS is
 typically regulated by the use of a critical flow venturi (CFV). The CFV limits airflow by creating a
 sonic shock wave in the throat of the venturi. Once a CFV has been calibrated, the air flow volume
can be determined by measuring the inlet temperature and pressure at the venturi.  The diluted
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exhaust flow is also sampled at the inlet to the venturi and transported to the emissions analyzer
benches.                                                                        J

The recommended flow rate for an IM240 CVS is approximately 700 SGFM (without heated sample
lines) while the RG240 CVS flow was approximately 100 SCFM. The lower flow rate was selected
for the RG240 in order to reduce equipment costs by using a lower power CVS blower motor  and
to keep the emission concentrations in the range of a B AR90 type emissions analyzer. The IM240
CVS uses a "L" type probe to sample emissions from the center of the flow stream. Because the
RG240 CVS design produces less cross-stream mixing of the diluted exhaust, the RG240 probe was
redesigned to sample across the entire flow stream. The redesigned probe substantially improved
calibration of prototype units, and reduced variability due to incomplete cross mixing.

IM240 emission analysis is performed with three different types of gas analyzers.  A flame ionization
detector (FID) for HC, while CO and CO2 analysis are performed with a nondispersive infrared
(NDIR) analyzer.  Oxides of nitrogen (NOx, which includes both NO and NO2) are measured using
a chemiluminescense type analyzer.  In contrast, the RG240 equipment uses a BAR90 type NDIR
gas analyzer for HC, CO, and CO2. NO measurements are performed with either an electrochemical
or a repair grade chemiluminescense analyzer. Both of these sensors measure only NO.

Advanced  Diagnostic  Strategy for  Catalyst Failure

It can often be difficult to determine if catalytic converter problems are really the root cause of
emission failures. Only about 30% of vehicles with emission failures studied by EPA require
catalyst repairs. Sometimes, damage to a catalyst can be diagnosed by tapping on the shell.  If the
shell sounds hollow,'the substrate may be missing, or if it rattles, the substrate may be broken up, or
the inner baffles and shell may be deteriorated. At other times, a repair technician may suspect mat
high emissions in  a vehicle are the result of a damaged catalytic converter, but his or her suspicions
may only be confirmed or contradicted by removing the catalyst and visually inspecting it and/or
measuring the pressure drop across the catalyst. Even then, visual inspection or measuring the
pressure drop might not detect catalyst contamination. Also, replacing the catalyst may reduce
emissions enough to bring a vehicle into compliance but still not correct some other malfunction,
resulting in high emissions again shortly after replacement of the catalyst.

EPA is investigating additional tools  for visual diagnosis of catalyst problems. A boroscope, which
is a fiber optic tool which extends down through the O2 sensor to the catalyst, may be developed so
that it is practical for inexpensive routine use inspecting catalysts.

Readings from a gas analyzer may also lead a technician to suspect contamination of a catalyst, even
when visual inspection or pressure drop measurements do not indicate a problem. If O2 readings are
above about 5%, indicating there is enough oxygen for the catalyst to burn the emissions, but CO
readings are still  above 0.5% (and other systems are operating properly), this indicates that the
catalytic converter is not oxidizing emissions from the engine and may need to be replaced.

For the present, EPA's advice is as follows:

             Always check for engine problems before replacing the catalyst.

             If significant engine problems are found  and then fixed, get another test before
             replacing the catalyst unless it is obvious from external inspection that the catalyst or
             its content is missing or damaged.

             Observe EPA rules for selection of a replacement catalyst  (see following section).
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                 SECOND-BY-SECOND IM240 EMISSION  REPORT

Test Report Description

During the IM240, four exhaust pollutants, the purge flow through the evaporative canister, and the
actual driving distance are measured for each of the test's 240 seconds. The four pollutants are HC,
CO, NOx, and carbon dioxide (CO2). The amount of each pollutant emitted by a vehicle is measured
in grams (g). The canister purge flow is measured in units of liters (L), and the driving distance of the
test in units of miles (mi).  The standards for this test allow the vehicle  to emit a certain number of
grams of pollution for each mile traveled and are reported as grams per mile of pollutants (gpm).

The IM240 test cycle speed, emissions, and evaporative purge of a typical high emitting vehicle are
shown in the figure below. The profiles are created by plotting the vehicle's speed, emissions, and
purge value for each second of the IM240. Also, shown in each graph, are the composite IM240
emission results for each pollutant.  The composite or average score is  the sum of the emissions from
each of the 240 seconds. It is compared with the I/M pass/fail standard.  All emission results are
shown in terms of grams of pollutant, per mile of driving distance. The vehicle's purge trace is shown
as liters of purge per second and the total purge is also reported in the box in the graph. The actual
state emission test report will also contain various text fields to identify the vehicle, the test site, vehicle
loading information, and other parameters..

The use of gram per mile units allows the emission profile to be graphically compared with the I/M
emission standard for each pollutant. The IM240 emission standards in this case are 0.8 gpm for HC,
15 gpm for CO, and 2.0 gpm for NOx and are shown as dark horizontal lines on each graph. These
lines allow for easy identification of specific high emitting operating modes in a vehicle's overall
profile. A vehicle is not necessarily considered an I/M failure if one or more modes exceed the
standards.  Instead, it is only considered a failure if the composite score exceeds the standard. Also, it
should be noted that many  vehicles (high and low emitting) will have a high emission spike when
starting from zero speed. This spike occurs because the distance traveled on the dynamometer during
the first few seconds is very small while the emissions are relatively large. The division of a large
emissions number by the small distance number produces a relatively larger gpm number. The spike is
very evident at the beginning and around second 100 in the CO2 profile. Data smoothing programs are
being developed which will reduce the severity of these low  speed spikes. These smoothing programs
are expected to be applied to all emissions traces from state I/M programs.

Emission  Test Report  Use As  a Diagnostic Tool

The IM240 emission test profile provides a visual representation of a vehicle's emission performance
over an entire operating cycle. The additional detail provided by this method allows easier
identification of specific vehicle operating  modes where high emissions predominate. For example, it
is not uncommon for a vehicle with low emission levels (i.e., that passes overall I/M standards) to
occasionally have emissions above the cutpoint during the  hard acceleration portions of the IM240.
However, a failing vehicle  with a malfunction of the emissions control  system will remain above the
standards during long periods of the IM240.

Currently, the IM240 emission test profiles should be viewed only as a first step in the diagnosis of a
vehicle with high emissions.  To a skilled engine diagnostician, they can provide information such as
which operating mode produces high emissions, and can generally serve as the starting point for
diagnosis. Once the high emitting modes are identified using the IM240 emission profiles, other more
specific vehicle diagnostic  tools (i.e., engine analyzers, oscilloscopes, catalyst testing equipment, etc.)
can be used to isolate specific vehicle components  which are malfunctioning.

IM240 emission test profiles should not be considered as tools which can pinpoint specific problems
on emission control devices, or used as a replacement for standard diagnostic methods. This is
because emission profiles from high emission vehicles are  often quite variable, and contain few


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definitive patterns which can be used to identify specific problems. Also, many failing vehicles have
more than one emission control system problem which makes a specific diagnosis more difficult.
Finally, the tremendous number of different vehicle engine calibrations adds to the variability, and
makes it very difficult to collect enough data to relate emission profiles to specific engines and
problems.

Future large scale emission data collection and analysis may make it possible to develop IM240 pattern
recognition algorithms and relate them to specific vehicle problems on an engine family basis. If
perfected, these could then be used with some confidence to quickly diagnose typical problems.
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                        EMISSION CONTROL PARTS  ISSUES

 After-market  Parts and EPA Tampering Policy

 According to EPA policy, the Agency does not consider it to be tampering for automotive dealers (or
 any persons) to use a non-original equipment aftermarket part as a replacement part for the purposes
 of maintenance or replacement of a defective or worn out part, if the dealer has reasonable basis for
 knowing that such use will not adversely affect emissions performance. The same applies to the use
 of aftermarket parts used as part of an add-on, auxiliary, augmenting, or secondary part or system.
 Adjustments or alterations of a particular part or system parameter, if done for purposes of repair or
 maintenance according to the vehicle or engine manufacturer's instructions, are also acceptable. The
 policy memorandum also clearly defines what constitutes a reasonable basis for knowing that use of
 aftermarket parts will not adversely affect emissions performance.

 Aftermarket  Part Certification Program

 EPA has a Voluntary Aftermarket Part Certification Program.  This program was amended in an
 August 8, 1989 rule. Essentially, this rule states that any aftermarket part manufacturer that wishes
 to certify its emission-related part must demonstrate that use of its part will not cause a vehicle to fail
 Federal  emission standards during the vehicle's useful  life.  Furthermore, the rule specifies that
 vehicle  manufacturers cannot deny a performance warranty claim on the  basis that use of the
 aftermarket part is improper maintenance or repair if the  part is  certified under the voluntary
 aftermarket part certification  regulations.  Finally, this rule has a durability demonstration
 requirement.

 It should be pointed out that, to date, no aftermarket part has been certified under the  Aftermarket
 Parts Certification Program.

 Aftermarket Part Warranty Requirements

 The August 8,  1989 rule also requires that all certified aftermarket parts be warranted by the part
 manufacturer not to cause emission noncompliance of the vehicle on which the part is installed.
 Certified parts must be warranted for the remaining warranty period of the vehicle, as required under
 Sections 207(a) and 207(b) of the Clean Air Act.  For instance,  the warranty  period under Section
 207(a) for emission related devices is 50,000 miles for pre-1995 light-duty vehicles. If the device is
 replaced with an aftermarket replacement part at 25,000 miles, the replacement part is warranted for
 the next 25,000 miles, when the mileage on the vehicle is 50,000 miles.  The vehicle manufacturer is
 required to repair or replace without charge those certified emission related components  necessary to
 remedy that emission failure if it occurs within  the prescribed warranty period.  The vehicle
 manufacturer may then obtain reimbursement from the certified part  manufacturer for the warranty
 claim. However, since no aftermarket part has been certified under the Aftermarket Part Certification
 Program, manufacturers are not currently required to replace any non-original  aftermarket emission
 related part free of charge.

 Locating Parts

 As a result of more stringent I/M programs and increased emission related repairs, especially on
 older cars, location of emission related parts to make the necessary  repairs could pose a potential
 problem. The California Bureau of Automotive Repair has addressed this problem by establishing a
 parts availability hotline. The hotline helps the public buy and locate new, used, and rebuilt emission
 parts.  Motorists are given exemptions for emission parts which are  no longer available. (Such
 exemptions  would not be permissible in an enhanced I/M program except with respect to visual
 inspections.) The California Bureau of Automotive Repair has a contract with the California Youth
Authority to administer the program.
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EPA Policy on  Sale and  Use of Aftermarket  Catalytic Converters

According to Section 203(a)(3) of the Clean Air Act, the installation, sale or manufacture of a
converter which is ineffective or less  effective than the new original equipment converter could
constitute tampering.  Thus,  EPA issued an interim enforcement policy on August 5, 1986. As of
January 1, 1988, only converters meeting the requirements specified by this policy or new original
equipment or equivalent converters may be sold and installed.

Aftermarket converters are required to have a five year, 50,000 mile warranty on the converter shell
and  end pipes.  They are also required to be warranted to meet EPA's emission performance
standards for 25,000 miles  when the vehicle is properly used  and maintained. Used original
equipment converters are only required to meet the performance requirements that applied at the time
of sale; no additional warranty is required. All manufacturers of new and used converters who meet
the EPA requirements must state that fact in writing.  Usually this statement is made in the warranty
information or vehicle application catalog.

Aftermarket catalysts must also be labeled according to the format specified in the August 5, 1986
interim  policy.  The labels include information on  whether the converter is new or used, a code
which indicates the manufacturer, a numerical designation of the vehicle application or part number
and the month and year of manufacture.

Generally, aftermarket converters can only be installed in three situations: 1) the converter is missing
from the vehicle when brought in for exhaust system repair; 2) the state and local inspection program
has determined that the existing converter has been lead-poisoned, damaged, or otherwise needs
replacement; or 3) the vehicle is more than five years old or has more than 50,000 miles, and there is
a legitimate need for converter replacement that has been established and appropriately documented
(e.g., a plugged converter or unrepairable exhaust leaks). Furthermore, EPA specifies installation
requirements. Among these requirements are that the same type of converter (oxidation, three-way,
or three-way plus oxidation) be  installed, the converter must be  properly connected to any air
injection components, the converter must be installed in the same location as the original, and the
same configuration (single exhaust, dual exhaust, dual in-line catalyst catalysts, etc.) must be used.

Aftermarket catalysts sold in California must be capable of meeting more stringent California
emission standards.  However, these catalysts must meet the same warranty requirements specified
under federal policy; that is, the vehicle must meet emission performance standards for 25,000 miles
when the vehicle is properly used and maintained.

Special  Situations

Often, repair facilities must repair vehicle emission systems on vehicles which have modifications or
other special situations which make it difficult for the facility to determine what it must do to comply
with EPA policy.  For instance, a repair shop may receive a vehicle  in which an original engine has
been replaced with an engine from an  older vehicle, and the exhaust system needs replaced.  The
original engine may also be smaller (e.g., 6-cylinder) than the replacement engine (e.g., 8-cylinder).
In such  a case, the facility must replace the exhaust system with  one equivalent to the certified
configuration of the same model year or newer vehicle of this type. If the vehicle was certified for a
single exhaust with a three-way plus oxidation catalyst, it must be replaced with an exhaust system
of this configuration. Furthermore, the exhaust system (and catalytic converter)  would have to be
able to handle the capacity of the larger replacement engine.

Repair facilities may also be confused about how to comply with EPA policy when repairing vehicles
which have been tampered with by do-it-your-selfers. Essentially, if a repair facility must perform
any work on any  part of the vehicle which has been previously  tampered with, the facility must
perform the correct repair or not do it  all in order not to be liable for tampering. This is true
regardless of the age or mileage on the vehicle and  applies to any motor vehicle or motor vehicle


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engine which was designed to meet federal emission standards (all 1968 or newer model year for
passenger cars and light-duty trucks).

There are a number of other special  situations which could cause confusion for repair facilities
performing exhaust system repairs.  If a repair facility has questions about how to comply with EPA
policy and what  acts may constitute tampering, they  should contact EPA by calling the Field
Operations and Support Division (6406J), U.S. Environmental Protection Agency, Washington, D
20460 (phone 202-233-9100).
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         CAUSES  AND  REPAIR  OF PURGE AND PRESSURE FAILURES

Purge Failures

The evaporative purge test is conducted during an IM240 transient dynamometer test to detect
vehicles with inoperative  evaporative  canister purge systems.  The  test procedure includes
disconnecting the test vehicle's vapor purge line running from the canister to the engine, and
installing a gas flow meter in the line. After installing the flow meter in the evaporative purge
system, the vehicle is operated over the IM240 transient cycle, and the cumulative vapor purge flow
in units of liters are recorded. The vehicle is recorded as a failure if its cumulative vapor puree is
less than 1.0 liter.

An alternative purge test can be used  if the Administrator determines that such a test would not
adversely affect the proper determination of system integrity or the proper operation of the vehicle.
One alternative purge test has been proposed by Environmental Systems Products, Inc. (ESP). The
alternative purge test is conducted by allowing  the helium to flow through the canister during the
IM240 tailpipe test and the exhaust is analyzed for the presence of helium using a mass spectrometer.
The EPA has approved this test in concept; however, the pass/fail limits and algorithms  require
additional research and development before this procedure is ready for use in official I/M test lanes.

There are a number of typical causes of purge failures. First, the canister purge solenoid or vacuum-
operated valve can be missing, disconnected or bypassed, have vacuum leaks, stick, or be otherwise
inoperative.  In addition, vacuum or vent lines can be disconnected or missing, plugged, damaged,
or misrouted. Moreover, the purge hose can be disconnected, missing, split, or not sealed. Also, the
canister purge thermal vacuum switch  can be stuck, or there may be no emissions control module
signal to the purge solenoid. Furthermore, simultaneous purge and pressure test failures can result
from a missing canister or EFE control switch, a disconnected or leaking carburetor bowl vent line
or a disconnected bowl vent solenoid or fuel line to the canister. Purge failures are usually caused by
an inoperative canister purge solenoid or valve, or disconnected, missing, or damaged purge hoses.

Pressure Failures

The pressure test, or evaporative system integrity test, is used to determine the integrity of a vehicle's
evaporative system, and fuel tank. In order to perform evaporative system pressure testing, the
following equipment is needed - an air or nitrogen gas bottle, a standard regulator, hoses connecting
the tank  to a pressure meter and to  the vehicle's evaporative system, and computer hardware to
interface the metering system with a computerized analyzer.  The test  sequence consists of the
following steps:

1)     Test equipment is connected to the fuel tank canister hose at the canister end. The gas cap is
       checked to ensure that it is properly, but not excessively tightened.

2)     The system is pressurized to  14±0.5 inches of water without exceeding 26 inches of water
       system pressure. Fuel tank pressurization is done by modulating the nitrogen flow into the
       fuel system by successive opening and  closing  of the control valve by the operator
       Modulating the nitrogen flow into the system allows a higher pressure nitrogen flow to be
       safely used to pressurize the system.

3)     The gas cap is loosened,  and  the vehicle is allowed to stand for up to two minutes to
       determine if it can continue to hold pressure.

4)     If pressure in the  system remains above 8 inches of water after two minutes the  vehicle
       passes the test.                                                          '
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 An alternative test procedure may be used if is shown to be equivalent or better to the satisfaction of
 the Administrator. As with the purge test, an alternative pressure test has been proposed by ESP,
 Inc., and approved by the EPA. The alternative pressure test differs from the standard test in that the
 fuel  tank is pressurized through the fuel inlet rather than through the evaporative hose from the
 canister end.  The canister hose is clamped in order to seal the system while the gas cap is checked
 on a separate rig to ensure that it seals properly.

 Pressure failures  indicate the potential existence of leakage on vehicles' evaporative emissions
 control system components, which include the gas cap, filler neck, sending unit, rollover valve,  and
 vent hoses. The most common cause of a pressure failure is a faulty gas cap. As mentioned in the
 previous section, simultaneous purge and pressure test failures can result from a missing canister or
 EFE control switch, a disconnected or leaking carburetor bowl vent line, or a disconnected bowl vent
 solenoid or fuel line to the canister.

 Alternatives to  Repair

 The Clean Air Act Amendments of 1990 define "programs to encourage the voluntary removal from
 use and the marketplace of pre-1980 model year light duty vehicles and pre-1980 model year light
 duty trucks" as a transportation control measure in Section 108(f).  A vehicle scrappage program
 could be such a measure. A scrappage program has the potential to create additional flexibility, for
 governments  and industry alike, by allowing the  generation of emission reduction credits from
 existing mobile sources that could be traded to stationary sources.  EPA analysis indicates that
 scrappage  programs for pre-1980 model year vehicles can exhibit a wide range of effectiveness,
 depending on both the program design and the very uncertain values of a number of important
 variables.

 A state or  local government can design a scrappage program as a SIP measure or, in conjunction
 with  a private company, as a program to generate emission credits to satisfy existing or new source-
 specific requirements.  Programs would basically work in the following way. A state or local
 government or company would advertise for the purchase of certain vehicles.  Owners would then
 voluntarily sell their vehicles to the sponsor of the program and the vehicles would be removed from
 the fleet.  The  sponsor would receive an emission credit for each car removed from operation
 equivalent to the difference between the emissions from the retired vehicle and the emissions from
 the replacement vehicle.  An agency-sponsored scrappage program could be financed by a surcharge
 on registration or testing.

 There are a number of variations on this basic program, which could decrease fraud and misuse,
 decrease the effects of uncertainty, and increase cost effectiveness. For instance, the Environmental
 Defense Fund and General Motors Corporation have proposed a scrappage program design that
 targets high-emitting vehicles regardless of age, awards emission reduction credits on the basis of
 emissions testing  for each scrapped vehicle, and  creates an emissions reduction "pool" for  the
 purpose of nullifying the incentive to tamper with individual vehicles.

 Also, programs that use a remote sensing device (RSD) to target  vehicles for participation in a
 scrappage program may reduce some of the uncertainty found in programs with eligibility based only
 on age and improve cost-effectiveness.  Specifically, RSD may increase program cost-effectiveness
 by helping identify older cars that are higher emitters than the average car of their age, and it may
 reduce credit overestimation by helping identify vehicles which are actually in active service and  not
just being stored or used very infrequently. Scrapping only vehicles identified by on-road remote
 sensing should, therefore, produce more emission reductions per scrapped vehicle.

 Adding a vehicle scrappage option to an I/M program is another way to improve program benefit
 and/or reduce costs.  Vehicles that fail an I/M test, and which have not yet been successfully
 repaired, or are known to need repairs costing greater than a predetermined amount, would become
eligible for a scrappage program. Depending upon the estimated cost of repair, emission reduction


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credits would be based upon either the vehicles' emission levels from an IM240 test, or emission
estimates from the MOBILE model. Scrappage program designs that incorporate an I/M element in
this way will not only have greater assurance that they are retiring high emitting vehicles, but could
possibly offer lower incentives since the vehicle owner is faced with immediate repair costs if the
vehicle is not scrapped.

While no owner would be pleased to have to get rid of a difficult-to-repair car and purchase a new or
used vehicle as a replacement, the reality is that it might be the logical thing to do for some cars. An
option to scrapping the old car  is to sell it  to an owner living outside the boundary of the I/M
program. The free market will surely see some of this happen. I/M agencies may wish to discourage
or facilitate it. They certainly should consider and be ready to deal with the issues of purchasers who
commute into the I/M area, I/M area residents who try  to use an  out-of-area address or name to
register a vehicle while garaging the vehicle in the I/M area, and the issue of consumer protection for
the person who may buy a high emitting vehicle without realizing its history.
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              THE ASM EMISSION TEST
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                         BACKGROUND ON  THE ASM TEST

In 1988, the State of California, Southwest Research Institute, and Sierra Research, Inc. did
developmental work on a series of loaded steady-state test modes known as Acceleration Simulation
Modes or ASMs. EPA was involved in reviewing the results of the testing that California had
undertaken at that time. The testing, based on 18 vehicles, found that two ASM modes - ASM5015
and ASM2525 (the first two digits refer to the load factor while the second two refer to the speed of
steady-state operation) - had some potential for identifying vehicles with NOx problems related to
exhaust gas recirculation valve malfunctions (that were induced in the vehicles tested) A Society of
Automotive Engineers (SAE) paper (#891120) was issued and the authors found that the tests did
poorly on the identification of hydrocarbon and carbon monoxide failures. The SAE paper
concluded that retention of the idle and two-speed tests would be necessary and that the primary
benefit of the ASMs was for NOx testing.

During the process of developing the enhanced I/M regulations, several parties suggested that the
ASM may be good enough for the purposes of enhanced I/M. The argument was that ASM would
be cheaper than IM240 because it relied on less expensive equipment. EPA believes that in high-
volume, test-only stations the difference in equipment cost is negligible; the  most important factor is
throughput time and the ASM test does not promise appreciable faster through put (a cost analysis
follows). The argument was also made that ASM could be done in both official test stations and
would be affordable by repair shops. The RG240, however, serves this purpose  as well without
compromising the quality of the test procedure.  EPA nevertheless conducted a more in-depth study
of the test and found that, while it was better than other steady-state tests, the ASM did not approach
the effectiveness of the IM240. The executive summary from EPA's report is presented on the next
page. EPA has issued credits for ASM testing for basic I/M states or for areas that want to combine
IM240 and ASM testing.

Vancouver, British Columbia also began pilot testing of the ASM5015 and the ASM2525 along with
idle and 2500 rpm modes in its regular I/M lanes in 1992. British Columbia officials found serious
problems with the ASM5015 and the Province decided to drop the mode from its official test
procedure.

The California Air Resources Board is also conducting a study of the ASM and IM240 in its
laboratory in El Monte, California. The results of that study are due to be available by the end of
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          EVALUATION OF A FOUR-MODE STEADY-STATE TEST WITH
 ACCELERATION SIMULATION MODES AS AN ALTERNATIVE I/M TEST FOR
                            ENHANCED  I/M PROGRAMS

                                    Executive Summary

Purpose

On November 5, 1992, the U.S. Environmental  Protection Agency (EPA) promulgated a regulation
for state-operated enhanced Inspection and Maintenance (I/M) programs. This regulation established
the IM240 as the benchmark I/M test, against which any alternative test must be found equivalent, or
nearly so but with compensating improvements  in other program aspects.

EPA performed tests on over 1500 vehicles in Mesa, Arizona to evaluate a four-mode, steady^state
procedure utilizing two Acceleration Simulation Modes. (This four-mode test procedure will herein
be referred to as the "ASM" test, although only the first two modes are strictly ASM modes.) This
evaluation was designed for determining whether the ASM is a suitable alternative to the IM240 for
enhanced I/M testing.

The ASM test utilizes equipment costing about half of the anticipated cost of the equipment required
for IM240 testing. This equipment is less expensive because the ASM does not involve transient
driving and the equipment only approximates mass emissions via pollutant concentration
measurements. In contrast, the IM240 is a transient test requiring more expensive equipment
measuring true mass emissions during typical driving.

The purpose of this document is to provide:

       EPA's evaluation regarding the effectiveness of the ASM test;

       a description of the analysis techniques EPA used;

       the data used in the evaluation; and

       a description of the test program.

This is the only ASM study conducted in an official I/M station.  The vehicles were randomly
selected and tested under the widely varying ambient conditions and preconditioning that normally
attend official I/M tests. Many more cars were tested than in any other ASM study. Also, this is the
only study to use one sample to develop the ASM mode weighting factors and an independent
sample to evaluate their effectiveness. EPA strongly believes that this study should be given far more
weight than all previous ASM studies.

Findings

EPA's findings are based on performance comparisons between  the ASM and the IM240 regarding
five important considerations:

    -  their relative ability to fail malfunctioning vehicles (needing exhaust emission control system
      repairs) and to avoid failing properly functioning vehicles;

    -  their relative ability to distinguish repaired vehicles (exhaust-repairs) that are sufficiently
      repaired from those that are insufficiently repaired;

    -  their relative ability to distinguish between functioning and malfunctioning evaporative
      canister purge systems;

    -  their relative costs; and

    -  the adequacy of the ASM for Enhanced I/M Programs using MOBILESa.


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              ASM FAILS TOO MANY CLEAN AND MARGINAL CARS WHEN
                 CUTPOINTS ARE TIGHT ENOUGH TO ACHIEVE EQUAL
                             IDENTIFICATION RATES TO IM240
        92%   92%
                93%
                         78%
                                68%
                                                  83%
                                       ASM At Matching HC
                                       IDR

                                       IM240 at Recommended
                                       Cutpoints
                                                            46%
                                                                   18%
                                                                             12%
                                                                                     1%
         HCIDR
CO IDR
NOX
 IDR
Failure
 Rate
Probable
   Ecs
Ability to Correctly  Identify  Vehicles Needing Repair

EPA commonly uses the rate of excess emissions identified during an I/M test to objectively and
quantitatively compare I/M test procedures. Excess emissions are those FTP-measured emissions
that exceed the certification emission standards for the vehicle under consideration.  For example, a
vehicle certified to the 0.41 g/mi HC standard whose FTP result was 2.00 g/mi, would have excess
emissions equaling 1.59 g/mi HC (i.e., 2.00 - 0.41 = 1.59).

The excess emissions identification rate (IDR) equals the sum of the excess emissions for the
vehicles failing the I/M test divided by the total excess emissions.  The more excess emissions an I/M
test identifies, the better the test.

EPA uses IDR instead of merely comparing the number of vehicles that correctly fail and correctly
pass. The IDR better contrasts the relative merits of competing I/M test procedures because failing
vehicles with high emissions  is more important than failing those that are only slightly above their
certification standards. For example, take two I/M procedures that correctly failed 100 of the 500
vehicles that had FTP emissions greater than their certification standards, but only 50 cars failed both
tests. If the fifty cars that failed Test A were high FTP emitters, and the other 50 cars that failed Test
B had FTP emissions only slightly above their standards, obviously Test A would be preferred, and
its EDR would reflect its better performance. Test A's better performance is not evident in comparing
the number of vehicles that correctly fail.
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 The ASM does not find high emitting vehicles as well as the IM240. Some high emitters which could
 be caught with the IM240 give low ASM scores. Table 1 .2. 1 shows the percent decrease in the
 excess emissions identification rate that would accompany substituting the ASM for the IM240.  For
 example, an IM240-based I/M program's HC and NOx IDRs will suffer nearly a 20% decrease by
 substituting the ASM test at the same failure rate (18%) that is produced by EPA's recommended
 cutpoints for biennial I/M programs.

           Table  1.2.1   Loss  in  Identification Effectiveness  With  ASM  Test


           Scenario                            HC         CO        NOx

           Failure Rate Held at 18%               19.0%      9.5%      18.5%
              0.8/15/2.0 IM240 Cutpoints

           Best IDRs with Ecs Held Below 5%     14.0%      14.3%      17.5%
                                         so? 2 74 7)
These values are % differences. For example: '         ' * 100 = 19.
                                                           2
                                                                          0%
 An aggressive I/M program, tolerating both higher failure rates and higher false-failure rates would
 relinquish about 15% of its inspection effectiveness by substituting the ASM test.

 Additional related findings are listed below:

  •   The ASM fails cars that are actually clean more often than the IM240. About 1 in 10 cars failed
      by the ASM did not appear to need repair, compared to about 1 in 30 for the IM240. EPA
      knows from other testing that more preconditioning can eliminate IM240 errors; we are not
      sure whether it can for ASM failures.

  •   Making ASM cutpoints more stringent in an attempt to get the same effectiveness as the IM240
      increases the failure rate and/or the error rate beyond what EPA believes any I/M program
      would want or is willing to commit to in binding regulation form.

 The comparative ability to identify vehicles needing repair is fully discussed in Section 5.3 (of the
 full report). Why IDRs and associated criteria are important, how the criteria are derived, and the
 tradeoffs associated with increasing cutpoint stringency to increase IDRs are discussed in Section 5.2
 (of the full report).

 Ability to  Distinguish Sufficiently Repaired Vehicles  From  Insufficiently Repaired
       Vehicles

 Vehicles that do fail the ASM test and get repaired, can pass  ASM cutpoints with repairs that are not
 as effective as the repairs needed to pass IM240 cutpoints, even when repaired in good faith. Also,
 the ASM modes are prone to "adjust to pass/readjust after" strategies like the idle and 2500/idle tests.

 Several of the 17 cars which failed the Arizona test and the ASM were repaired in local shops, after
 which they passed the Arizona and ASM test but still had high IM240 emissions. This is the same
 pattern seen in 2500/idle I/M programs. Repair analyses are discussed in Section 5.6 (of the full
 report).
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Ability to Distinguish Between  Functioning and  Malfunctioning Evaporative
       Canister Purge Systems

In purge testing, the ASM and the IM240 should do equally well in identifying malfunctioning purge
systems, so their comparative ability to fail vehicles with malfunctioning purge systems has not been
an issue.  Therefore, the research issue has been whether, and how many properly functioning
vehicles would fail. That is, EPA is more concerned with errors-of-commission than with errors-of-
omission.  About 4-6% of the vehicles failed the ASM evaporative canister purge system test but
were actually properly functioning. This is about 38% to 52% of all cars that failed the ASM purge
About 1% of the vehicles failed the IM240 purge system test, but were actually properly functioning
This is about  12% to 18% of all cars that failed the IM240 purge.

Unlike transient IM240 testing, which requires vehicles to operate through a wide range of speeds
and loads, the four steady-state modes of the ASM do not provide a purge opportunity for a  '
significant portion of the fleet. The purge system test results are discussed in Section 5.7 (of the full
report).

Test  Costs

The 180 seconds required for this four-mode ASM test is the same as would be needed for the
IM240 if special algorithms are used to pass obviously clean cars and fail obviously dirty cars early
in the cycle. So, the ASM does not save test time or reduce the number of lanes required. A shorter
test based  on fewer than four modes would have even less benefit.

The only cost advantage for this ASM test is that up to about half the equipment cost can be avoided
by not having variable inertia capability in the dynamometer and low-concentration measurement
capability  in the gas analysis instruments.  This savings works out to about 75 cents per test in a
centralized program. Test costs are discussed in Section 7 (of the full report).

Adequacy of the ASM for Enhanced I/M Programs

The MOBILESa analysis results show that even in a maximum annual program, covering all weight
classes, with ASM, purge, and pressure testing of all model years and comprehensive anti-tampering
inspections, the ASM test yields insufficient benefits to meet the performance standard for HC CO
or NOx.
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           ECONOMIC COMPARISON OF IM240 AND FOUR-MODE ASM

 Key Cost Factors:

 •      Throughput (the number of vehicles tested per hour on average and at peak capacity) is the
        key factor affecting test costs in high volume test centers.

 •      The main cost elements are equipment, facilities, staff, and overhead (spread over the total
        number of lanes and stations in a program).

 •      Throughput is a direct function of the time it takes to test a car; high volume operations use an
        assembly-line approach that allows rapid throughput.

 •      In low-volume test centers, equipment and operating costs become more important tha'n how
        long it takes to run a test.

 •      Equipment and facilities are one-time expenses amortized over a multi-year period.

 •      Staff and overhead are recurring expenses paid out on an on-going  basis.

 Cost of ASM relative to IM240

        The cost of equipment depends on the volume of purchase.  High-volume purchases for the
        IM240 may be as low as $40,000. Low volume purchases are estimated in the range of
        $80,000-$ 120,000. ASM equipment cost is estimated at about $40,000.  Operating costs for
        ASM are substantially higher than current BAR90 systems.

 •       Average test time for IM240 is 2 minutes.  ASM has a 4 minute average initial test time and
        second-chance testing would be needed for vehicles that fail the ASM-purge test.  Peak
        throughput for the IM240 is 20 vehicles per hour; for the ASM it is  about 12 per hour.

 •       In a high-volume, test-only network the estimated per vehicle cost for the IM240 is $ 16, of
        which test equipment only accounts for $ 1.39. Because of the lower throughput due to the
        longer test time and the need for retesting, the cost for the ASM in a high-volume network
        would be $20, even though test equipment accounts for 61 tf of the total cost.

 Neighborhood Test-Only Networks

 •       As the number of test stations and lanes increases, the average test volume at each decreases,
        driving up the per vehicle test cost.

 •      If test volume is reduced to where throughput is equal for both tests  (despite longer test time
       and the need for retesting with the ASM), the per vehicle cost for ASM testing is about the
       same.  For example, if each station (with two lanes each) tested roughly 37,000 vehicles per
       year (i.e., operating near maximum capacity),  the per vehicle cost for the IM240 or the ASM
       would be about $30. Equipment costs would still be a minor part of the overall cost (about
       $1-2).

 •      Decreasing the volume further by increasing the number of stations would make the ASM
       slightly cheaper than the IM240, but would significantly raise the cost for either test. For
       example, if each station tested 19,000 vehicles per year, the per vehicle cost for the IM240
       would be about $51 compared with $48 for the ASM.
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                 COVERAGE ISSUES
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                                  DIESEL VEHICLES

Diesel engines emit paniculate matter (smoke), oxides of nitrogen, hydrocarbons, and carbon
monoxide. Diesel participates are the small, solid and liquid particles that make up the visible and
most annoying exhaust from diesel vehicles. On a per vehicle basis, CO and HC emissions from
diesel vehicles are much lower than those from comparable gasoline engines, as shown in the table
below.  Plus because there are many fewer diesel vehicles than gas vehicles, they contribute only a
tiny fraction of the overall emissions of CO and HC from mobile sources. Heavy diesel trucks do
contribute a significant share of the NOx emissions and EPA is working on ways to test such
vehicles.

                   1995 Vehicle Emission Rates in Grams Per Mile

Exhaust CO gpm
% of Total
Exhaust HC gpm
% of Total
Exhaust NOx gpm
% of Total
Gasoline
Cars
22
53%
1.7
52%
1.6
39%
Light
Trucks
31
30%
2.5
32%
2.0
20%
Heavy
Trucks
117
13%
5.2
8%
5.3
6%
Motor-
cycles
25
0.6%
2.0
0.7%
0.8
0.2%
Diesel
Cars
2
0.03%
0.8
0.1%
1.7
0.3%
Light
Trucks
2
0.02%
1.1
0.1%
1.9
0.1%
Heavy
Trucks
12
3%
2.6
8%
14.6
34%
New  Diesel Vehicle  Emission Control

EPA has authority under the Clean Air Act Amendments of 1977 and 1990 to regulate diesel
emissions from new vehicles and engines. The following diesel paniculate emission standards apply
to the model years listed below:

                      Heavy Diesel Vehicle  Particulate Standards
                                   over 8500 pounds GVWR
Model Years Emission Standards Coverage
grams/brake horsepower/hour
1988 - 1990
1991 - 1992
1993
1994-1995
1996+
0.6
0.25
0.10
0.25
0.07
0.10
0.05
0.10
AllHDVs
AllHDVs
Urban buses
All Other HDVs
Urban Buses
All Other HDVs
Urban Buses
All Other HDVs
                             Light Diesel Cars and Trucks
Model Years
1982-1986
1987+
Emission Standards
grams per mile
0.6
0.2
Coverage
All light duty vehicles
All light duty vehicles
As can be seen in the above tables, the standards for heavy duty vehicles are set to become more
stringent in the 1990's. Prior to 1993, heavy-duty diesel standards could be met with relatively
minor design changes, while post-1993 standards are expected to require more substantive re-
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 engineering on the part of the diesel engine industry, and may require more advanced exhaust after-
 treatment technology.  These post-1993 standards represent more than a 90% reduction in particulate
 emissions, compared to pre-1984 levels.

 In-Use  Diesel  Emission Control

 Once a diesel vehicle is put into use, the carbon monoxide  and hydrocarbon emission remain fairly
 stable throughout the life of the vehicle. This is a major difference between diesel and gasoline
 powered vehicles and the reason diesels are not typically part of state-operated vehicle emission
 inspection programs. The Clean Air Act requires that these programs reduce excess emissions of
 carbon monoxide and hydrocarbons but it does not require particulate emission reductions.
 However, particulate emissions from diesel vehicles may increase during use, especially if not
 properly maintained. Some states do require diesel vehicles to participate in vehicle inspection
 programs, where they are checked for smoke emissions.  Some states have laws limiting allowable
 smoke levels from all types of vehicles.

 Other methods for decreasing in-use diesel emissions include fuel reformulation to decrease sulfur
 content, the retrofitting of older vehicles with oxidizing traps, and holding older engines that are
 rebuilt to more stringent standards.  Although tighter, post-1993 standards will apply to all newly
 built engines, EPA's efforts to reduce  in-use diesel emissions have focused on urban bus fleets.
 This concentration is due to the size of the fleet in question, the fact that they tend to be centrally
 fueled, and also operate in urban centers where their emissions impact is more keenly felt.
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                 CONTRIBUTION OF OLD CARS VS. NEW CARS

Many people have suggested that the problem with motor vehicles is limited to a small percentage of
the fleet, typically 10%. The thinking goes that if we could find a way to identify the 10% worst
emitters without having to test all of the vehicles, we would solve the problem. The table below
shows the contribution of different fractions of the fleet ranked by CO emission levels. CO was
chosen for the ranking only because the Remote Sensing Device CO channel is reasonably capable of
accurately testing instantaneous emissions (although instantaneous emissions are not very
representative of overall performance of a vehicle). The table shows that while the worst 10% of the
CO emitters represent about 50% of the CO emissions, these vehicles only contribute 33% of the HC
and 11% of the NOx. Moving down the table, you find that in order to get a significant fraction of
all of the pollutants you need to fail a much larger fraction of the fleet. EPA estimates that about 40-
45% of the vehicles in the fleet need repair. EPA recommends that states phase-in emission
standards on the IM240 over at least two test cycles. By doing this, the overall failure rates will be
in the 30-40% range.  With the looser standards, the dirtiest cars will fail in the first test cycle, which
will yield the biggest emission reductions and benefits.
               CO
            Emitters
            Top 10%
            Top 2Q%
            Top 30%
            Top 40%
            Top 50%
                      More Than 10% of the Fleet Needs Repair
                                          Percent  of Total Emissions
Fraction
Of Fleet
   10%
   20%
   30%
   40%
   50%
H£
33%
49%
60%
69%
75%
52%
67%
77%
83%
88%
NOx
 11%
 24%
 37%
 48%
 59%
Some people argue that the problem could be solved by scrapping old vehicles or requiring only old
vehicles to participate in VM. While EPA believes that new vehicles don't need to be tested until 2 or
4 years of age, testing or scrapping only old cars will not achieve the air quality goal.  The figure
below shows that while most older vehicles need repair, so too do newer vehicles.

              Percentage  of Vehicles Failing Stringent  IM240 Cutpoints
             100%
          UH
               0%
                   15   14  13   12   11
               10  9    8   7   6
                  Age of Vehicle
Up to 20% of five year old vehicles fail either the evaporative system test of the tailpipe exhaust test
If these newer vehicles are not fixed along with the older vehicles, then air quality goals will not be '
achieved. It is especially important to identify problems when vehicles are young so that they
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                                                                                Page 80

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 problems can be corrected before they lead to further problems and ultimately much more expensive
 repairs.  Another important factor recognize is that old vehicles are not driven nearly as much as
 newer vehicles. So, a dirty old car that's only driven a thousand of miles per year is no worse than a
 dirty new car that is driven 15-20,000 miles per year. At this time, pre-1981 vehicles only contribute
 about 18% of the VOC total emissions to the mobile source inventory. Enhanced I/M is designed to
 get a 32% reduction in the mobile source VOC inventory. So, even eliminating all pre-1981 vehicles
 would not solve the problem and it would not be cost-effective.  The most cost-effective approach is
 to find all of the vehicles that have significant excess emission levels and require them to be repaired.
 The only effective way to do that is to test all of the vehicles (except possibly the newest vehicles)
 and repair the ones that need it. This is not only the most effective in terms of emission reductions
 but it also the most equitable approach.
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                REMOTE SENSING
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                BASIC  INFORMATION ABOUT REMOTE SENSING

What is Remote  Sensing?

Remote sensing is  a way to measure pollutant levels in a vehicle's exhaust while the vehicle is
traveling down the road.  Unlike most equipment used to measure vehicle emissions today, remote
sensing devices (RSD) dp not need to be physically connected to the vehicle. The concept of RSD as
an efficient tool to monitor the vehicle fleet and identify excessive polluters has great appeal as a
complement to traditional mobile source emission control programs.  A number of instrument
manufacturers are actively developing RSD systems.

What Pollutants are Measured by RSD ?

RSD systems can measure hydrocarbons, carbon monoxide, and oxides of nitrogen in the exhaust
stream.  RSD cannot, however, measure "evaporative" emissions - gasoline vapors that vent into the
air from hot engines and fuel systems. Fuel evaporation is a very significant source of hydrocarbon
pollution that can exceed tailpipe emissions on hot days.

How  does Remote  Sensing  Work?

Commercial RSD systems employ an infrared absorption principle to measure HC and CO
emissions. These systems operate by continuously projecting a beam of infrared radiation across a
roadway. It is expected that RSD systems for NOx will use either a beam of ultraviolet light, or light
from a tunable diode laser projected across the road.

As a vehicle passes through the RSD beam, the device measures the ratio of CO (and exhaust HC) to
carbon dioxide (CO2) in front of the vehicle and in the exhaust plume behind.  The system uses the
"before" measurement as a base and calculates the vehicle's CO emission rate by comparing the
"behind" measurement to the expected ratio for ideal combustion.  Exhaust HC is calculated in a
somewhat similar manner by comparing the total carbon content of exhaust HC, CO, and CO2 to the
total carbon content of the gasoline the vehicle burns. The CO2:CO ratio determined by current RSD
systems will still be needed to calculate NOx emissions.

RSD systems employ a freeze-frame video camera and equipment to digitize an image of the license
plate number so that it can be processed by a computer. This allows the computer to store emissions
information for each monitored  vehicle, based on the license plate number. Appropriate authorities
can then identify and contact owners of vehicles  with high RSD readings.

Methods to measure a vehicle's speed and acceleration as it passes through the infrared beam may
also be  used. This is important because the operating mode (e.g. acceleration, cruise, etc.) can
significantly affect the instantaneous emission level from a vehicle. Some types of operation during
an RSD test may be cause for invalidating a particular test.

Computerized diagnostic technologies may also  play a role in future RSD systems. Vehicle onboard
diagnostic  systems, capable of identifying certain malfunctions in a vehicle's emission control
system, are required beginning with 1994 models.  The malfunctions could be reported to roadside
RSD systems by a small electronic device on the vehicle called a radio frequency transponder.
Similar transponder concepts have been used to time runners in marathons and transponder systems
are being used to assess toll road fees in some areas.
Section Four
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                                          IR SOURCE
                VIDEO
                I.D.
                GAMER
                              COMPUTER

 Will Enhanced Inspection and Maintenance Programs Include RSD?

 Yes. RSD and other "on-road" emission measurement methods will be an important part of state
 strategies to reduce emissions from motor vehicles.  The Act requires that enhanced I/M programs
 include on-road emission testing of a portion of the eligible vehicle fleet. RSD technology is
 expected to play a major role in these supplemental emission measurements:

 •  RSD will likely be used to identify vehicles with  malfunctioning emission controls between
    scheduled I/M  tests.  Air quality benefits can result from early repair of vehicles that would
    otherwise not be identified or repaired until the next annual or biennial test.

 •  EPA studies have shown that properly repaired vehicles maintain low emissions for a long time.
    However, some individuals may tamper with their vehicle's emission control systems. The
    mobility of the RSD provides a way to identify tampered vehicles between periodic I/M tests and
    a way to enforce repair requirements  on those vehicles found to be dirty.  Other studies have
    found that RSD is more effective in identifying tampered vehicles than the currently used random
    roadside pull-overs.

 •   RSD can detect  unregistered or improperly registered vehicles. This will allow authorities to pick
    out drivers who cheat on registration or register out of the  area to avoid participating  in an I/M
    program.

 •   To  take advantage of RSD's potential to identify dirty cars, EPA is requiring enhanced I/M
    programs to conduct supplemental emission measurements on at least 0.5% of vehicles subject
    to I/M testing each year.  Vehicles that fail an RSD  test would be required to be retested by the
    regular I/M test.  Repairs would be required for any vehicle failing this out-of-schedule I/M
    emissions check.

 Can RSD Replace Enhanced Inspection and  Maintenance Programs?

 No. The Clean Air Act provides for use of RSD as a supplement to enhanced I/M programs but not
 as a substitute for periodic emission testing. While RSD can be extremely useful, it does have some
 limitations:

 •   RSD fails vehicles that do  not need repair and passes many that do.  Studies by EPA, the
    California Air Resources Board, and others have  found  that when  RSD measurements are
    compared to emissions measurements  made by accepted testing methods, the RSD incorrectly
    fails vehicles that are not in need of repair.

•   The Clean Air Act mandates that enhanced I/M programs include an interrogation of the onboard
    diagnostic system to  check for emission control system malfunctions on 1994 and  newer
    vehicles. Current RSD systems cannot  access the onboard diagnostic system.


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•  The emission reductions from the evaporative emission tests are essential to meeting the
   enhanced I/M performance standard. RSD cannot conduct this test.

The RSD false failure rate has been around 20% or more for CO and as high as 60% for HC. More
importantly, for clean air, EPA studies indicate that RSD does not identify 80% to 90% of the dirty
vehicles that need repair.  This means RSD alone could not be used to  meet the enhanced I/M
performance standard.  EPA  believes that these results do  not reflect on the instantaneous
measurement accuracy of the RSD. Rather, EPA believes these results are indicative of changes in
vehicle emission levels that typically occur when a vehicle is operated under driving conditions
different than those observed by the RSD.  A bibliography of studies is attached.

Implementing RSD in Inspection and  Maintenance Programs

There are a number of administrative factors to consider in establishing I/M programs that include
RSD.  Some RSD advocates have suggested that RSD is capable of monitoring much more than
0.5% of the fleet.  EPA agrees that RSD could be used by the I/M programs to measure emissions
from more cars, given adequate resolution of the following issues:

» Placement  of Roadside Monitors

   Current RSD technology can only measure emissions of vehicles driving in a single lane of
   traffic. It is not easy to find enough sites where appropriate single traffic lanes exist to monitor
   the majority of vehicles subject to I/M testing. Restricting multiple lanes to a single lane for RSD
   measurement may not be practical in many cases, particularly during times of heavy traffic such
   as rush hour. Yet RSD testing during peak traffic periods would probably be necessary to avoid
   missing high-emitting vehicles that could be parked during business hours.

   EPA has successfully used RSD monitors along multiple lane roadways in some studies without
   restricting traffic to a single lane. But pylons had to be placed between  the lanes to protect some
   of the RSD equipment.  With such a set-up, drivers could choose not  to drive through  the
   measuring lane.

   Another issue involves limiting RSD  placement to locations where representative vehicle
   operation will be observed.  It will be important for I/M programs to avoid creating situations
   where a measurable portion of vehicles fail RSD monitoring at one location but pass at another
   location. For example, sites of high acceleration would likely be avoided because emissions tend
   to be higher during acceleration than during steady-speed driving.

»  Appropriate Pass/Fail Levels

   A difficult issue involves selecting an emission standard (cutpoint) for the RSD that will identify
   vehicles that need repair while minimizing false failures. EPA studies indicate that RSD mis-
   identification of clean vehicles as dirty is substantially reduced by measuring emissions from the
   same vehicle several times.  However, multiple measurements also result in more dirty vehicles
   passing the test.

»  Notification

   Administrative systems need to be established so authorities can follow up with owners of
   vehicles that register high emissions during an RSD check. Whether vehicle owners are pulled
   over immediately at the time of the check or notified later by mail, oversight will be necessary to
   ensure that dirty vehicles undergo further testing and repair if necessary.
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 »  Driver Behavior

    To date, RSD emissions testing has occurred only in demonstration type projects with no
    consequences for drivers whose vehicles fail the test. In the future, RSD failures in enhanced
    I/M programs will result in mandatory  retesting and repair. These consequences may prompt
    drivers to change their driving route or regime (e.g., observing RSD testing in the opposite lane
    on the way to work,  and choosing a different route home), or otherwise alter their driving
    behavior to avoid passing an RSD monitor.  The political implications of failing motorists,
    especially falsely, with this type of program may be a significant problem.

 The prototype studies conducted to date do not provide the type of practical information I/M program
 managers need to effectively use RSD on a day-to-day basis. However, EPA believes that most of
 these administrative issues will be resolved with experience, as states begin to integrate RSD into
 actual I/M programs.  By starting out with a small fraction of the fleet (0.5%), I/M program offices
 can begin to develop administrative  systems that will allow RSD to achieve its potential as a full
 player in the vehicle emission control program of the future.
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     ANALYSIS  OF THE  EFFECTIVENESS AND COST-EFFECTIVENESS OF
                            REMOTE SENSING DEVICES

                                       Executive Summary

Under a work assignment with EPA's Office of Mobile Sources, the environmental consulting firm Sierra
Research, prepared a report entitled "Analysis of the Effectiveness and Cost-Effectiveness of Remote
Sensing Devices," which was finalized on May 18, 1994, and was principally the work of authors Thomas
C. Austin, Francis J. DiGenova, and Thomas R. Carlson. Based upon an analysis of data from the current
California I/M program, the authors assess how the use remote sensing devices (RSDs) impacts the
effectiveness and cost effectiveness of conventional I/M programs. The authors looked at two possible uses
of RSD - as a supplement to a conventional I/M program, and as an I/M screen or replacement The authors
also looked at the more general question of how driving styles effect RSD pass-fail results. A summary of
their conclusions follows:                                                                  J

RSD AS AN I/M PROGRAM  SUPPLEMENT

For a supplemental RSD program adequate to cover the South Coast Air Basin, the authors assumed the use
of six teams of RSD van operators, Highway Patrol officers, and inspectors who move from site to site on a
daily basis, with the ability to cover about 1,000 different sites each year. The annualized cost was
estimated at $3.3 million (based upon vendor-supplied estimates for emissions measurement equipment and
freeway ramp modifications, fully burdened labor costs, and other miscellaneous costs).

Used as an I/M program supplement, RSD was found to produce some cost effective benefits, due to
additional tampering-deterrence resulting from the public's perceived risk of being detected. Since only
about 3% of the vehicles in the  current California fleet appear to have excessive emissions caused by
mtentjc-nal (i.e., currently undeterred) tampering of which the current vehicle owner is aware  the potential
benefit associated with additional tampering deterrence  is relatively small. Using California's current
decentralized I/M program as the base, the authors estimate that a limited RSD-based pullover program could
increase overall reductions in HC by an additional 1.9%, CO by 2.3%, and NOx by 0.6%. The overall cost
effectiveness of the program was projected to improve slightly from $1.75  per pound to $1.67 per pound
Using, a centralized, enhanced I/M program as a base, emission reductions would increase by about half as
much (due to the fact that an enhanced I/M program already detects more tampering than the current
California program). The additional benefits resulting from the use of RSDs have almost  exactly the same
cost per pound as the enhanced program without RSDs, resulting in  a net cost effectiveness of $1.10/pound.

RSD AS I/M SCREEN OR REPLACEMENT

The use of annual prescreening by RSDs, in conjunction with a pullover program, would reduce the
effectiveness of the current I/M program by 3.9% for HC and 10.1% for NOx, while increasing CO
reductions by approximately 3.4%.  Based on 100% annual prescreening at a network of fixed sites the cost
effectiveness of the program ($1.00/pound) would be only slightly better than that of an enhanced I/M
program and the benefits would be much lower.  These  estimates assume the use of 21  test sites to cover the
South Coast Basin, with one fixed RSD lane and a maximum of three IM240 lanes per site.

The benefits of a program based on prescreening via remote sensing would reduce the current program's
benefit by 6.6% for HC, 2.7% for CO, and 10.2% for NOx if the prescreening were done at freeway ramps
instead of fixed sites.  Under this approach, 29 sets of RSDs and license plate readers would be moved on
average once per week, among 1,300 freeway ramps in the South Coast Basin. The annualized cost for this
element of the program was calculated to be $8.4 million.  The loss in benefits results from the difficulty in
getting a valid reading on each  vehicle when only using freeway ramps. The cost-effectiveness ratio of this
approach is slightly lower than  the other scenarios considered at $0.97/pound.

The loss of emission reductions associated with RSD-based screening or I/M replacement occurs because
RSDs are not capable of identifying many commonly occurring emissions-related defects includine defects
in evaporative emissions controls, crankcase emissions  controls, and cold-start controls,  'in addition

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 currently available RSDs will not accurately measure NOx and HC emissions.  Although RSD technology
 can accurately measure instantaneous CO concentrations, accurate measurements of "drive-by" emissions of
 CO, NOx, or HC are not as effective as transient testing. The inherent lack of control over the operating
 conditions of the vehicles being tested by RSDs introduces substantial variability in the test results, making it
 more difficult to separate defective vehicles from properly maintained vehicles. In addition, the inability of
 RSDs to measure the mass emissions rate makes the exhaust of all vehicles with the same emissions
 concentration appear to be the same even when the mass of emissions may be substantially different.

 THE  IMPACT OF  DRIVING STYLE ON RSD RESULTS

 A popular misconception arising from previous analyses of RSD results is that  10% of all vehicles are
 responsible for more than 50% of all vehicle emissions. This conclusion can only be drawn by assuming
 that: 1) instantaneous emission measurements made by RSDs represent the average emissions from each
 vehicle measured, and 2) emissions not measured by the RSD (e.g., evaporative hydrocarbons) are perfectly
 correlated with exhaust CO emissions, which are consistently and accurately measured by the RSD.

 To demonstrate the fallacy the above two assumptions, the authors compared two sets of second-by-second
 CO emissions from the same vehicle equipped with a portable emissions measurement system. The vehicle
 was thoroughly inspected before and after each trip, and the vehicle was found  to pass both idle and IM240
 standards. The vehicle was driven twice along the same route from downtown Sacramento to a residential
 area in the southwest portion of the city. The only difference between the two trips was the relative
 aggressiveness of the driving style (i.e., whether or not the trip included hard accelerations).

 For the first, more conservative trip, almost all measurements were below 1% CO and the average mass
 emissions rate for the trip was 2.2 g/mi CO.  The instantaneous CO emissions measured during the second,
 more aggressive trip exceeded 3-4% (a frequently recommended RSD cutpoint range) at least 13 different
 times and the average CO emissions for the same trip were almost twenty times higher at 39 g/mi. Peak CO
 concentrations were in the range of 8-9%, which occurred during hard accelerations. All of the difference in
 emissions between the two trips was due to driving style, with the result that the first, conservative driver
 would be  identified as driving a clean vehicle, while the second driver would be found to be driving a clean
 vehicle while cruising, and a gross emitter while accelerating.
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                Section  Five
Studies,  Papers,  and Reports  on  I/M


  This section provides EPA's response to recent studies, reports, and testimony
            critical of various aspects of the I/M program.

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                         EPA REVIEW OF GAO TESTIMONY

On October 29, 1993, GAO testified before the House Subcommittee on Oversight and
Investigations on a variety of issues related to Clean Air Act implementation. One of the issues was
the emission reduction credits for test-only and test-and-repair I/M programs
GAO testimony states (pages 18-19):

     "We reviewed the data and studies upon which EPA based its 50-percent reduction
     decision and generally found that while this information provides qualitative support that
     test-and-repair programs have in  the past been less effective, it does not provide
     quantifiable support for a 50-percent reduction."

EPA response:

     GAO does not explain the basis for its conclusion.  There is a significant body of
     quantitative data on the emission reduction effectiveness of both test-only and test-and-
     repair I/M programs.  Both the California I/M Review Committee work as well as EPA's
     research in the test-only programs in Portland, Maryland, Indiana, and Arizona provide
     measurements of actual emission levels from vehicles in the fleet. The various tampering
     surveys and audits have generated numerical data on the rate of tampering in the fleet and
     the rate of improper testing in I/M programs.  Copies of a recent report summarizing this
     data are available from EPA's Office of Mobile Sources.

GAO testimony states (page 19):

     "While state and local agencies choosing to implement decentralized I& M programs may
     petition EPA for less severe reductions in their emissions reduction credits, such claims
     must meet certain demonstration requirements, which some state and local agencies have
     stated that they have  neither the resources nor time to do. According to these state and
     local agencies, EPA is strongly encouraging them to adopt centralized I&M programs."

EPA response:

     Section 182(c)(3)(C)(vi) of the Clean Air Act Amendments of 1990 requires a centralized
     program unless "the State demonstrates to the satisfaction of the Administrator" that a
     decentralized program would be equally effective.  EPA attempted to ease the States'
     burden in two ways:  EPA  proposed that separation of testing  and repair in a
     decentralized program would be one way to meet the requirement without having to make
     any additional demonstration. At least two states are pursuing this approach. The other
     way was  to establish criteria using data available in well  run test-and-repair I/M
     programs.  Massachusetts, for example, recently conducted such a study (and found the
     test-and-repair system was not working).  States have had ample time since 1990 - three
     years - to collect and compile data on the effectiveness  of I/M programs that combine
     testing and repair.

     With regard to centralized testing, in addition to carrying out the intent of Congress  EPA
     is indeed strongly encouraging states to implement test-only programs - centralized or
     decentralized.  The reason for this is quite clear - test-only programs have a long history
     of being less expensive and more effective at achieving emission reductions in a highly
     convenient and acceptable manner to the public. The California I/M Review Committee
     estimates that implementing an "enhanced" decentralized, test-and-repair program would
     cost $40 or more per vehicle for the test ($80 with IM240).  Enhanced, test-only I/M
     contracts have now been signed in five states with per vehicle costs of $16-$21 per car
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 GAO testimony states (page 19):

      "this unresolved issue [the 50% discount] and others have the potential to undermine
      public confidence,  reduce motorists' acceptance of enhanced I&M programs,  and
      potentially impact envisioned emissions reductions."

 EPA response:

      GAO provided no basis to support the suggestion that this is an unresolved issue or that
      there is a problem with public acceptance. In fact, of the 23 states that are required by the
      Act to implement enhanced I/M, only two (Massachusetts and California) have not passed
      legislation addressing the question of network type, and as of this writing, test-only
      legislation passed both houses of the Massachusetts legislature and minor differences
      were being worked out in conference.  (Two other states that are already test-only also
      need  legislation but the issue is  not network type).  Indeed,  a recent Gallup poll
      conducted for the American Lung Association found that 79% of vehicle owners believe
      the separation of testing and repair is a good idea.  Further, 72% feel separation of testing
      centers from repair facilities insures that the repairs that are made  are necessary and done
      correctly.  Most states required to implement enhanced I/M programs are well on their
      way to doing so.  About half the I/M states currently operate test-only programs  and
      experience very high levels of motorist satisfaction.

 GAO testimony states (page 39):

      GAO sites two studies EPA used  to establish "that decentralized programs were less
      effective than centralized programs" (the 1982 tampering survey and the 1985 California
      I/M Review Committee report).

 EPA response:

      This statement is incorrect. EPA did not use the 1982 tampering  survey data in the way
      GAO  claims.  EPA  used the 1982 tampering survey data to  establish visual anti-
      tampering credits for all I/M programs - i.e., equal credits were issued at that time for
      both types of programs.  EPA used subsequent tampering surveys conducted mainly in
      the late 1980s, the California report cited by GAO along with the California I/M Review
      Committee's  1,100 vehicle study, and EPA and state audit data to adjust the visual anti-
      tampering program credits.

GAO testimony states (pages 39-40):

      GAO claims that EPA told it about  the Portland, Oregon study "just prior to today's
      hearing" and that EPA used this study to conclude "that centralized programs were the
      most effective network for identifying vehicles" that need repair.

EPA response:

      This statement is also incorrect in two respects. First, EPA discussed the Portland study
      with GAO auditors in the beginning of the audit process, but GAO auditors did  not
      investigate it further.  Second, contrary to the second part of the statement, EPA did not
      draw any conclusions from  the Portland study about the effectiveness of  different
      network types. This  would have been impossible since, at the  time, there were only
      centralized emission test programs in operation in the United States.
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GAO testimony states (page 40):

     GAO states that "the data from the 1980 Portland study was the original basis for the
     100-percent tailpipe emissions credits given for test-only I&M programs. Although we
     have not had an opportunity to review this study in detail, our limited review indicated
     that the Portland centralized program only identified 55% of the vehicles that exceeded the
     tailpipe emission standards."

EPA response:

     This statement reflects some apparent confusion between the question of test objectivity
     (i.e., proper versus improper testing) and test effectiveness. It is a well known fact that
     the idle test only identifies about 55% of the vehicles that exceeded the tailpipe emissions.
     This is the primary reason EPA developed the IM240. But this has nothing to do with
     whether or not the inspector does the test correctly or honestly.  EPA has not found a
     problem with inspectors in test-only programs conducting emission tests objectively.
     EPA and other investigations have repeatedly found serious  problems with improper
     testing in test-and-repair programs.
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      EPA RESPONSE TO THE  GAO  REPORT ON PROPOSED VEHICLE I/M
                                      PROGRAMS

 On October 20, 1992, GAO released a report titled: Unresolved Issues May Hamper Success of
 EPA's Proposed Emissions Program. This report, conducted at the request of Congressman
 Dingell, reviewed EPA's proposal to improve the effectiveness of vehicle Inspection and
 Maintenance (I/M) programs. Although EPA provided substantial written comments to GAO to
 correct inaccurate and misleading statements in the draft, GAO, in most cases, chose to ignore them.

 GAO Conclusion

    The IM240 test is not repeatable, therefore emission failures are not properly identified.

 EPA Response

    »   GAO correctly concluded that current I/M tests (idle or two-speed) are not effective.

    »   GAO does not understand the nature of testing in assuming that zero variability is attainable.
       All emission test results are variable because vehicles are variable.

    »   The challenge in developing I/M tests is to maximize the identification of vehicles that need
       repair while passing those that do not need repair.

    »   GAO focused its review on 18 vehicles that failed the IM240 in one test but passed in
       another.

       •    GAO neglected to point out in its report that all 18 of these vehicles failed the FTP and
           were in need of repair.

       •    These particular vehicles were marginal failures and vehicles in this category tend to be
           highly variable in performance but they nevertheless need repair

       •    GAO chose not to consider information presented by EPA regarding test algorithms that
           would reduce failures among marginal vehicles

       •    Finally, GAO was told that there was a problem with the NOx instrumentation (since
           corrected) during the testing of the 18 vehicles but GAO apparently chose not to consider
           this factor in its analysis. Eight of the  18 vehicles included in GAO's review were NOx
           failures.

    »   GAO also failed to understand the advancements represented by the IM240. The IM240 is
       better at identifying vehicles that need repair than any other I/M test and at the same time
       eliminates false failures. This is a major achievement over existing I/M tests.

GAO Conclusion

     The  repair industry may not be able to properly fix emission failures, thus causing
     motorists inconvenience  and frustration.  GAO cites 20 1986 and newer vehicles on
     which EPA contractor mechanics attempted repairs.  Seven (35%) could not be fixed on
     the first try.

EPA Response

    »   GAO incorrectly assumed that EPA was attempting to fully repair vehicles in the test
       program. During the early phase of the test program, which is the source of this data, EPA


Section Five                                                                        Page 5

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        was attempting to recruit and test as many vehicles as possible to characterize the
        effectiveness of the test. Full restorative maintenance was not being pursued but rather
        quick  one-shot repairs were performed to get a general sense for emission reductions
        available and the kinds of problems evident.

        Once EPA realized the superior effectiveness of the IM240 at identifying vehicles that need
        repair, the test program was refocused to assess the effectiveness of repairs.  In this phase of
        the program, normal diagnosis and repair of failing vehicles was pursued and technicians
        were able to fix failing vehicles to pass the M240 standards. This effort is continuing at this
        lime*

        GAO implies that a better test should not be employed because they believe mechanics may
        have trouble fixing vehicles that fail:

        •   Inexplicably, GAO fails to mention EPA's major initiative, announced in July 1992, to
           improve the quality of maintenance that vehicles receive.

        •   EPA has formed a task force with the automotive service industry, auto makers
           consumer groups, vocational and technical educators, and federal, state, and local
           government agencies to provide the tools, training, and certification to vehicle repair
           technicians.

        •   Further, GAO fails to point out that EPA recommends that states set looser outpoints
           during the first cycle of testing under new procedures. This phase-in approach will
           reduce failure rates in the first cycle and give states and technicians plenty of time to adapt
           to the new system.                                                           ^^

        •   Enhancing I/M programs is meaningless if it doesn't include enhancing technician
           capabilities and performance.
GAO Conclusion
     EPA has not  adequately  evaluated alternative I/M test procedures.  This is causing
     confusion with states, some of which believe they must decide upon  a specific test
     procedure by November 1992.

EPA Response

    »   EPA staff has been in continual contact with state and local officials responsible for I/M
       programs, has attended and held numerous meetings and conferences on this subject and has
       never heard from any official that such confusion exists.                         '

    »   Nevertheless, EPA has revised the I/M rule language to make clear that states have until
       November 1993 to choose a test procedure.

    »   EPA has evaluated alternatives to the IM240 test procedure and is continuing to do so
       EPA's proposed rule established an overall performance standard that was based on the most
       cost-effective test procedure EPA knows of: the IM240.

    »   States do have the flexibility, however, to choose alternative tests so long as the Droeram
       achieves the performance standard. EPA is currently evaluating an alternative test procedure
       suggested by ARCO and the State of California. This evaluation is scheduled £SLPrOCedUre
       completed by the end of the year at which time EPA will inform states of the results  This
       provides ample time for states to select test procedures prior to November 1993.   '
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                                                                                    Page 6

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           EPA  COMMENTS ON TESTIMONY OF RAND CORPORATION
               Before the California Senate Transportation Committee"
                              "Restructuring Smog  Check"

 General Comments

 RAND's program design recommendations are largely based on two "findings:"

       •      A small fraction of the vehicles are responsible for the majority of emissions.

       •      There is no evidence to support the separation of testing and repair.

 EPA response to the first:

 This assertion appears to be based on remote sensing data (no sources are cited).  Remote sensing
 can currently only effectively measure carbon monoxide (CO),  it cannot characterize vehicle
 emissions of volatile organic compounds (VOC), oxides of nitrogen (NOx), or evaporative
 emissions. This is an important distinction since the kinds of engine problems that produce excess
 CO emissions do not usually produce excess VOC or NOx  emissions. When considering all types
 of emissions the statement that a small fraction of the vehicles (15 percent in the Irvine report) are
 responsible for the majority of emissions is not true. Vehicles that have high CO emissions are not
 necessarily the highest VOC or NOx emitters because different types of problems cause emissions to
 increase in each case. The ten percent worst CO emitters account for 52 percent of CO emissions,
 and the ten percent worst VOC emitters account for 46 percent of VOC emissions, while the ten
 percent worst NOx emitters account for only 29 percent of  NOx emissions. However, these
 emissions do not come from the same ten percent of the fleet. It would be necessary to fail close to
 40 percent of the fleet in order to capture more than 50 percent of the tailpipe emissions of all three
 components. In addition, evaporative VOC emissions comprise 38 percent of all VOC emissions.
 Nineteen percent of vehicles account for 63 percent of evaporative emissions. Not all of these
 vehicles are included in the 38 percent of the fleet discussed earlier. Remote sensing devices cannot
 identify all of the vehicles that need to be failed and fixed in an I/M program.

 EPA response to the second:

 In fact, EPA has a considerable amount of data demonstrating that combined test-and-repair
 programs suffer serious emission reduction losses, from EPA audits, and from auditing work done
 by many states, including California. This data was made available to RAND. Indeed, RAND's
 principle conclusion was, "the California smog check system must be restructured." RAND
 proposes a list of additional safeguards which, it is claimed, will enable a test-and-repair program to
 meet EPA's performance standard. RAND presents no analysis showing how, and to what extent
 these features can improve the performance of the California program. EPA spent two years
 establishing the I/M regulation required by the Clean Air Act and consulted extensively with all
 effected parties. The Clean Air Act specifically required I/M programs to be "operated on a
 centralized basis unless the State demonstrates to  the satisfaction of the Administrator that a
 decentralized program will be equally effective."  In proposing its rule, EPA specifically asked for
 comment on what safeguards would enable a test-and-repair program to get comparable emission
 reductions to a test-only program.  Commenters experienced in overseeing I/M programs
 overwhelmingly stated that all past attempts to improve test-and-repair programs by adding additional
 safeguards had failed (as RAND admits they have failed in California) and that no combination of
 safeguards was likely to solve the fundamental problems of test-and-repair programs.

 Comments on the Testimony

The testimony expresses "surprise" at the extent to which mathematical models "often based on
 limited data and subject to little formal verification procedures, govern the terms of the I/M debate"
Section Five                                                                         Page 7

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 and adds that sufficient data do not exist "to assure that models are sufficiently accurate and unbiased
 to define policy."

 EPA's MOBILE model is simply a mathematical expression of an extensive database. It does not
 create emission factors for in-use vehicles; it reflects the data from testing thousands of such
 vehicles. EPA's latest model, MOBILES was developed based on data from EPA's Emission Factor
 program and other sources. EPA's Emission Factor program alone reflects test data on well over ten
 thousand consumer vehicles. As with all versions of the MOBILE model, MOBILES was released
 only after extensive consultations with affected industries and state government officials including
 five public workshops.

 Comments on RAND's Responses to the Four Questions

 Question:  "Evaluate the data and methods used to assess the benefits of the current program, 'assess
 Doug Lawson 's evaluation and answer the following question:  Which data and/or evaluation is more
 accurate, and what are the benefits of the current program?"

 RAND expresses some reservation about the 1 100 California vehicle study but does not draw any
 conclusions about it. The testimony seems to indicate agreement with Lawson's findings, that the
 California program does little to change the emissions profile of the fleet, although their hypothesis
 as to why this might be the case, that owners repair all tampering on their vehicles just before the test
 and re-tamper them immediately after the test, is supported by no research. EPA's tampering
 surveys over the years have consistently found intentional tampering to be on the decrease. EPA's
 investigations of I/M effectiveness indicate that emissions reduction losses, similar to those
 documented in Lawson's studies to be due to improper testing in  test-and-repair programs, and the
 poor ability of steady-state tests to detect emissions problems on  new technology vehicles.' Finally,
 RAND offers no estimate of the benefits of the current program, or of their proposed program
 design.

 Question:  "The I/M Review Committee 's recommendation for a hybrid program assigns costs and
 benefits to that program. Are those rules based on scientific data and analysis?"

 The Committee's estimates erred on the high side. The State of Maryland recently awarded a
 contract for a test-only IM240 program for about $16 per vehicle including oversight costs.

 Question:  "Given the conditions in California relative to building a facility such as a high-volume
 smog check station,  are the I/M Review Committee's recommendations practical, can the program,
 as proposed by the I/M Review Committee, be implemented on time ?"

 RAND characterizes the likelihood that program implementation will be delayed as "highly uncertain
 but probably large." Other states have zoning laws and environmental review laws as well and no   '
 test-only program has ever suffered a delay in implementation due to protracted permitting
 procedures.                                                                    6

 Question:  "EPA rules reduce the benefits of California-type smog check by 50 percent  Are those
 rules based on scientific data and analysis? Can a smog check program similar to the existing one in
 California be augmented with additional enforcement, random roadside tests, remote sensing or other
 methods to produce air quality benefits that meet the EPA requirements? "
 RAND's response to this question has been discussed previously.  EPA has extensive data incHf™
 the credit discount but RAND suggests that another round of adflng more "sS^to the ^
 existing program "can be highly effective." EPA investigated the second question and found alone
 with those commenters experienced m overseeing I/M programs, including the fonml comment If
 the State of California, that no such measures were likely to be effective enough. However  RAND
 does not quantify the benefits of the current program, they do not quantify the emission reduction


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                                                                                   Page 8

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 goals of the Clean Air Act, and they do not quantify the benefits of their proposal. Hence, there is
 nothing in either the testimony or the attached report to support their claim that additional safeguards
 will be effective. The Clean Air Act clearly requires that test-and-repair programs can be considered
 only with a demonstration of equal effectiveness.

 RAND proposes that the current smog check program "be structured to evolve into a well
 safeguarded decentralized program with rigorous state supervision."

 The current California smog check program is the one of best safeguarded, most rigorously state
 supervised test-and-repair I/M program in the world and yet it still cannot meet the Clean Air Act
 requirements. RAND suggests such measures as "remote sensing, random roadside inspection,
 continuous monitoring and evaluation, real time computer links and software for verifying
 enforcement." These are not new ideas; they are among the measures EPA asked for comment on
 during the rulemaking process.  Furthermore, all these features are required for enhanced I/M
 programs in EPA's rule. Hence, they cannot be used to make up for shortfalls in program design.

 RAND claims that their program design will be more cost-effective than a test-only IM240 program.

 No analyses are presented to support this claim.  California's oversight program is already the most
 expensive in the world, costing $7 per vehicle on top of an average inspection fee of $25. RAND's
 recommendations will only raise the cost of the program. A test-only enhanced IM240 program is
 being implemented in Maryland for only $16 per vehicle. These figures include costs to educate the
 public, upgrade  mechanic skills, and enforce the program.

 Other Comments on the Opening Testimony

 EPA agrees with RAND that there is a great deal more to an I/M program than just test type and test
 network.  EPA's rule contains requirements to ensure that program effectiveness is verified
 independently of modeled estimates, that on-road testing is used to verify vehicle compliance
 between inspections, and that resources are available locally to train and assist repair providers.
 Provisions are also made in the rule to ensure that inspections are convenient for motorists, that
 motorists' avoidance behaviors are anticipated and addressed  and that public information and
 consumer protection are important elements of I/M. EPA has also worked with states to evaluate
 options to assist  low income drivers. EPA  also notes RAND's statement that their conclusions "do
 not imply that a centralized system utilizing IM240 technology would be ineffective."

 Given that I/M programs have been in operation for many years it is possible to consider RAND's
 idea that joining  testing and repair "promotes the development of a corps of mechanics who will
 better understand how to repair vehicles and how to reduce emissions at any point between
 scheduled tests"  in light of experience.  States with test-only programs have been able to develop a
 much more cooperative relationship with the local repair industry, focusing their resources on
 training and information sharing. On the other hand, states with test-and-repair programs have had
 to focus increasing resources on enforcement, resulting in an adversarial relationship between the
 state and the repair industry.

 Comments on Recommendations for Restructuring Smog Check

A Safeguarded State Supervised Decentralized Program

 As mentioned above EPA asked for comment during the rulemaking process on the effectiveness of
 additional safeguards and tighter supervision. No evidence was presented that this approach would
 work and many commenters observed that repeated attempts have been made to improve the
effectiveness  of test-and-repair programs by adding new features without success. California's
current program  is the product of three iterations of strengthening safeguards and tightening
supervision and yet it still does not meet the requirements of the Clean Air Act. It is also important to


Section Five                                                                          Page 9

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 note the time frame implied in the statement of these recommendations.  The State is advised to
  initiate planning and preliminary design" of its program, and in listing the safeguards RAND
 allows that, some will need further development;" and indeed, the "continuous monitoring"
 strategies proposed are extremely premature. Remote sensing can only measure CO at this time  and
 not enough is known about what a remote sensing reading indicates about a vehicle's overall   '
 operating state to use it as an evaluation tool as RAND envisions. The Clean Air Act requires states
 to submit their enhanced I/M SIPs by November 15, 1992. In the I/M regulation, EPA required
 comrmtta  SIPs by the statutory date and full SIPs by November  15, 1993. There is no legal room to
  initiate planning and preliminary design" of a program relying on features that "will need further
 development.

 Technology/Testing/Demonstrations

 EPA agrees that VOC,  CO, NOx, and CO2 must be measured.  Given the current state of testine
 technology this means the State must use some sort of loaded mode test.  EPA agrees that the State
 must determine which loaded mode test is most suitable. This determination must take into account
 the effectiveness of the  different tests and the emission reduction requirements of the Clean Air Act
 It seems clear that performing evaporative emission tests in test-and-repair programs would be
 difficult and costly. Estimates of evaporative emissions are not "in a state of flux" as RAND states
 A number of studies of evaporative emissions have been done and they generally agree on the
 relative contribution of  evaporative emissions. Recently published low estimates of evaporative
 D^x^?11? are based °n  studies with remote sensing, which cannot measure evaporative emissions
 RAND also proposes a  number of demonstration projects and studies. EPA does not object to these
 ideas and would be interested in any data generated, provided such studies do not come at the
 expense of implementing a program that meets the requirements of the Clean Air Act.

 Comments on Recommendations for USEPA and the Federal Government

 RAND's first recommendation is that "rather than focusing on just one element in the I/M system -
 the nature of the facility and technology," EPA should adopt a "broader systems view which
 involves a restructuring of virtually every element in the I/M system including inspection
 maintenance, repair, and the roles of the public and the test/repair industry."

 It can be clearly seen by a review of EPA's I/M rule, the preamble to it, and the support materials
 bPA published that EPA has indeed taken a broader systems view of a restructured enhanced I/M
 program. In developing its requirements for I/M programs, EPA  drew on information from as many
 different sources as possible, including such things as economic analyses, surveys of motorists'
 attitudes and experiences on I/M, and the experience of states in overseeing and enforcing the
 programs and dealing with motorists' complaints. EPA's rule contains requirements to ensure that
 program effectiveness is verified independently of modeled estimates, that on-road testing is used to
 verify vehicle compliance between inspections, and that resources are available locally to train and
 assist repair providers.  Provisions are also made in the rule to ensure that inspections are convenient
 for motorists, that motorists' avoidance behaviors are anticipated and addressed and that public
 information and consumer protection are important elements of I/M.

Response to Specific Recommendations

 1)     As indicated above, EPA consults extensively with states and industry before releasing new
 versions of the MOBILE model. These consultations do cover the underlying data, basic loeic and
any assumptions or uncertainties.                                                    5  '

2)     This recommendation has been discussed above.. It is a product of RAND's
with EPA's I/M policy and the history of its development.
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 3)     EPA does investigate, and assist in the dissemination of information on advances in the areas
 of information technology and diagnostic technology as it becomes aware of them. EPA is
 continuing to evaluate the capabilities of remote sensing and its potential role in I/M programs.

 4)     EPA has placed a great emphasis on mechanic training. EPA's Vehicle Maintenance Initiative
 is working with private organizations and state governments to improve the quality and availability of
 mechanic training on emission controls, and to improve state outreach efforts.  The I/M rule requires
 that programs to provide technical assistance to mechanics and to track repair effectiveness and
 provide feedback to mechanics be part of I/M programs. Similarly public information and consumer
 protection programs are required in I/M programs. EPA is also working with states on strategies for
 assisting low income drivers.

 5)     EPA is continuing its efforts to gather field data on vehicle emissions and repair effectiveness
 through its studies in Hammond, Indiana, and Phoenix, Arizona. EPA is also investigating a-variety
 of new diagnostic strategies for use in the repair industry.

 Summary

 Given that the debate in California has focused heavily on network type and test type, RAND's
 report is useful in that it reminds us that there are many more elements to a successful I/M program
 than that.  In that broader perspective, EPA and California are in agreement on many things.
 However, one cannot ignore the differences among different tests in detecting problems with
 vehicles, particularly, newer ones.  These differences have been extensively studied and amply
 documented. One simply cannot ignore the conflict of interest created in a test-and-repair network
 between performing repairs and judging their effectiveness;  and between keeping a good customer
 happy and enforcing a state requirement against that customer.  The loss of program effectiveness
 due to this conflict of interest has been extensively documented, as has the effectiveness of the test-
 only approach.
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                                EPA'S  RESPONSE TO
   I/M EFFECTIVENESS  AS DIRECTLY MEASURED BY AMBIENT CO DATA
                            by Huel Scherrer and David Kittelson
                                  University of Minnesota
Conclusion
For the reasons cited below, EPA does not believe that the study conducted by the University of
Minnesota is an accurate analysis of the effectiveness of the inspection and maintenance (I/M)
program in the Minneapolis-St. Paul area.

The Study  is Built on a False Premise

  •      The study establishes the baseline emission reductions it attributes to new car technology
        by linearly extrapolating pre-I/M CO reductions indefinitely into the future.

        This extrapolation suggests that even without I/M, CO emissions will eventually be reduced
        to zero, due to new car technology and fleet turnover.

        In reality, the reduction in CO due to new car technology will level off as vehicle standards
        stabilize and fleet turnover to these standards is completed.

        The authors' claim that their conclusions are based on "real-world data" as compared to
        EPA s computer projections is disingenuous. A "trend"  is just another type of projection
        based upon founded or unfounded assumptions, and data are only "real" to the extent that
        the formula used is valid and addresses all relevant variables.

The Current Minnesota I/M Program is Mischaracterized

        The Minneapolis-St. Paul area has a basic I/M program, but the authors suggest it is an
        enhanced program by describing it as a "comprehensive I/M program" that "maximized
        I/M program effectiveness."

        The authors claim that the program was predicted to "lead to a 25 to 30 percent reduction in
        carbon monoxide levels," erroneously suggesting that this reduction should be observed at
        individual monitoring sites.

        Neither EPA nor the Minnesota Pollution Control Agency has ever predicted I/M emission
        reductions for specific monitoring sites, nor have they predicted that the Minnesota
        program would achieve a 25% to 30% reduction in overall CO inventory.

        EPA's I/M benefits model (MOBILESa) estimates a 9.2% reduction in motor vehicle CO
        emissions and a 6.8% reduction in the overall CO inventory of Minneapolis-St. Paul during
        the study s time frame. This reduction is consistent with what would be expected from
        other basic I/M programs.

  The Study Is Based  On Mixed  and Incomplete Data

        Air quality data from five monitoring sites were ignored and no rationale is given for
        limiting the study to only the 3 sites selected.
                  ? ±T 'J% ^am!)ient CS levels estimated from me 3 monitoring sites (i.e.,
         1.5%, 5.8%, and -3.4%) shows wide variation and suggests that using date from a limited
         number of discreet sites for the purpose of program evaluation may be unreliable.

Section Five
                                                                                Page 12

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  •      Site 3 - which shows a 3.4% increase in the ambient CO level and brings down the overall
         average - has historically shown markedly different results than the other two sites,
         although the study treats data from all three sites as if they were equal. The authors do not
         attempt to explain why CO levels increased at this site.

The  Study Used Flawed Methodology

  •      Important variables were ignored, including the impacts of vehicle speed, mixing height,
         and operating mode.

  •      Winter data from 1992-93 were ignored, even though CO is primarily a cold weather
         problem and the program's impact would be best assessed then.

  •      The study attempts to justify the exclusion of important variables such as vehicle population
         and vehicle miles traveled (VMT) by averaging daily vehicle count data for sites 1 and 2.

  •      The traffic data used for sites 1 and 2 only looks at east-west traffic and ignores north-
         south traffic.

  •      Upon analyzing these incomplete traffic data  for sites 1 and 2, the authors found that daily
         average traffic counts were flat for a period of 12 years.

  •      Based upon the above conclusion, the authors ignored the fact that both vehicle population
         and VMT for the entire urban area went up during the study's time frame, significantly
         offsetting reductions from control strategies such as new vehicle standards and I/M.

  •      Because  of its location, site 3 (the site which drove down the overall average) is likely to be
         more influenced by area-wide increases in VMT and vehicle population than are sites 1 and
         2. The lack of traffic data for site 3 comparable to that used for the other sites makes it
         difficult to assess the full impact of this influence.

  •      Potential increases in CO emissions from industrial and other stationary sources were
         ignored, even though these account for more than a quarter of the overall CO inventory in
         the Minneapolis-St. Paul urbanized area.

  •      The study only looks at operating data from the first year of program operation - a time
         period typically used for fine tuning the program.

  •      I/M programs generally do not reach full effectiveness until they have been in place for a
         few inspection cycles, by which time the repair industry has developed the skills necessary
         to fully repair cars identified by I/M testing.
Section Five                                                                          Page 13

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