EPA-460/3-78-013
MOTOR VEHICLE EMISSION
INSPECTION/MAINTENANCE
INFORMATION KIT
Office of Mobile Source Air
Pollution Control (AW-455)
401 M Street, S.W.
Washington, D.C. 20460
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MOTOR VEHICLE EMISSIONS INSPECTION/MAINTENANCE INFORMATION KIT
Section 1- Overview
.1 Summary
.2 USEPA Policy
Section 2- Benefits
Section 3- Costs
Section 4- Legislation
.1 Suggested Content
.2 Analysis of State Statutes
Section 5- Public Information
Section 6- Training
Section 7- Program Implementation
9/78 CONTENTS
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Summary
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Sect ion 1.1
Inspection/Maintenance - A Summary
Transportation - related air pollution continues to poison the
air we breathe. In the nation's urban areas almost all of the carbon
monoxide, about half of the hydrocarbons, and somewhat less than half
of the nitrogen oxides (the latter two helping to form photochemical
oxidants or smog) come from mobile sources.
I/M complements the national effort to control motor vehicle
emissions. In the 1970 Amendments to the Clean Air Act, Congress
•&•
mandated that new cars in 1975 had to cut emissions by 901 compared
to then current levels. Though the final compliance date has been
delayed to 1981, a significant tightening of the applicable standards
went into effect in 1975 and another is planned in 1980. These standards
are intended to cut.the adverse health impacts of transportation-related
pollution. The two main pollutants of concern are photochemical oxidants
and carbon monoxide.
Health Effects of Transportation-Related Pollutants
Photochemical oxidants are formed by a complex series of chemical
reactions initiated when hydrocarbons and nitrogen oxide emissions from
autos are exposed to sunlight (resulting in photochemical smog). They
cause irritation of the eyes and mucous membranes and aggravate existing
respiratory illness. The elderly and very young are particularly affected.
Ozone is the main constituent of photochemical smog.
* Other motor vehicles have since also had standards prescribed.
9/78 1-1-1
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Carbon monoxide (CO), a colorless, odorless, tasteless gas, is
formed as a result of incomplete combustion. Carbon monoxide, inhaled
into the lungs, enters the bloodstream and readily combines with
hemoglobin, the substance which carries oxygen to the cells. Oxygen is
thus inhibited from being distributed throughout the body, causing
dizziness and headaches. CO can weaken the functioning of the heart,
impair motor ability, and slow response times. It is of special concern
to those with heart disease.
State Implementation Plans; Structure and History
In the Clean Air Act, Congress required the O.S, Environmental
Protection Agency (USEPA) to review health-related data to provide
the basis for National Ambient Air Quality Standards (NAAQS). Each
State was required to have a State Implementation Plan (SIP) for the
control of each designated pollutant down to the NAAQS. Some States
submitted adequate SIPs for the control of oxidants and CO, but USEPA
had to promulgate SIPs in some areas where States either submitted
an inadequate SIP or no SIP for oxidants and/or CO.
The NAAQS however were not generally attained and maintained
as the original plans provided. Reasonable measures such as I/M
were not implemented, deterioration of new cars' emissions was greater
than originally projected, and the oxidant problem was more pervasive
than it was originally thought to be.
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The Requirements of the Clean Air Act Amendments of 1977
With the understanding that the problem of transportation-related
pollutants would have to be attacked more comprehensively than in the
past, Congress enacted the Clean Air Act Amendments in August 1977.
Congress mandated that all areas with violations of the NAAQS be designated
as non-attainment areas. 104 metropolitan areas were designated in
February 1978 including 103 areas for oxidants, 62 for CO, and 6 for
N0_. Congress further required States responsible for these areas
to produce revisions to their State Implementation Plans (SIPs) by January
1, 1979. These provisions must provide for attainment and maintenance
of the NAAQS as soon as possible but no later than December 31, 1982.
For oxidants and CO, if it is demonstrated by a State to EPA that attainment
cannot be achieved by 1982, even with the implementation of all reasonably
available measures, then a specific schedule for the implementation of
I/M is required to be submitted with the 1979 plan revisions and an
extension of the attainment date to no later than December 31, 1987, may
be granted.
I/M as Part of a Comprehensive Control Effort
The Federal Motor Vehicle Control Program (FMVCP) is designed to
ensure the production of vehicles which, with proper maintenance and
use, will meet applicable emission standards throughout their useful lives.
9/78 1.1-3
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The FMVCP consists of: 1. certification of prototypes to insure that new
vehicle standards are met; 2. random testing of production vehicles at
the assembly line; and 3. recall of vehicles when a model line is found
to have a significant emission-related defect in use. I/M complements this
effort by providing a means to assure that reasonable maintenance occurs on
all affected vehicles.
Where the air quality standards are exceeded, overall emissions
must be reduced so that the standards will be met. The FMVCP, stationary
source controls (for hydrocarbons), and I/M all provide help in reaching
the NAAQS. Transportation-related measures, such as exclusive
bus lanes, carpooling, and improved mass transit can also be included in
SIPs to reach necessary emission reductions.
The Benefits and Costs of an I/M Program
An automobile inspection and maintenance program is a practical,
effective and cost-effective strategy.
Practicality:
The implementability of I/M has been demonstrated in several different
areas already. New Jersey, for instance, started their program in 1972
and initiated mandatory I/M in 1974. There are now ten I/M programs in
existence, six of which are mandatory in some form. Other areas have
initiated introductory programs and several additional States have passed
legislation.
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Benefits:
USEPA estimates that a properly operated I/M program can produce
*
a 20 to 30% reduction or more after several years of program
implementation. New Jersey, Arizona, and Oregon have all reported
significant idle emission reductions. In combination with the FMVCP,
I/M helped to produce a reduction of 26% in 3 1/2 years in ambient
CO concentrations on a statewide basis in New Jersey.
Costs:
Costs to date have been reasonable. Inspection fees alone generally
support the program. Failure rates have ranged from 12-36% and average
repair costs have ranged from $16 to $32. The most current averages
in New Jersey, Oregon, and Arizona are $15.86, $18.86, and $23.02,
respectively. The median cost of repairs has ranged from $8 to $20.
Types of I/M
There are three basic structures for I/M programs: centralized
(state or municipally owned and operated), centralized (contractor owned
and operated), and decentralized, private garage-based inspection and
Compared to what emissions would have been without I/M.
9/78 1.1-5
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maintenance facilities. Depending upon an area's existing administrative
structure, the costs involved, the presence of existing safety inspection
facilities, the geographic location, and several other factors, one of
the above systems will generally be employed.
Additional considerations include the type of inspection made or
emission test to be employed; the nature and degree of service industry
involvement and training; the necessary surveillance and auditing; and
the realistic I/M emission standards or "cutpoints" used to determine
whether or not a vehicle passes the test. The "cutpoints" will determine
the stringency of the program which determines the achievable emission
reduction.
The Need for Enabling Legislation
To implement an I/M program, there is a need for adequate legal
authority; this can often mean that state (sometimes local) legislation
is required. If I/M is needed for an extension of the air quality
standard attainment date, USEPA requires a certification of adequate
legal authority by June 30, 1979. In unusual cases, this deadline may
be extended to July 1, 1980, but only if either a) the legislature has
had no opportunity to consider legislation between the enactment of
the 1977 Amendments to the Act and June 30, 1979, and/or b) there has
not been enough time to complete necessary technical studies.
9/78 1.1-6
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Section 1.2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN 43105
JUL 1 7 1978
OFFICE OF
AiR AND WATER PROGRAMS
SUBJECT: Inspection/Maintenance Policy
FROM: David G. Hawkins, Assistant Administrator
for Air and Waste Management
MEMO TO: Regional Administrators, Regions I - X
As you know, the Clean Air Act Amendments of 1977 set forth
specific requirements for the implementation of motor vehicle
inspection/maintenance (I/M) programs. Attached is a policy paper
indicating what EPA will consider a minimally acceptable program
wherever I/M is required by the Act. It should aid your efforts to
provide for adequate I/M submissions for the State Implementation
Plan (SIP) revisions of January 1, 1979. Please continue to contact
me if problems in I/M implementation develop.
cc: Air and Hazardous Materials Division
Directors, Regions I, III - X
• Environmental Programs Division Director,
Region II
Air Programs Branch Chiefs, Regions I - X
9/78(7/78)
1.2-1
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Policy for the Development and Implementation of
Inspection/Maintenance Programs
The Clean Air Act Amendments of 1977 provide new direction for the
development and implementation of motor vehicle inspection/maintenance
(I/M) programs. If states are not able to demonstrate attainment of the
standards for oxidant (Ox) or carbon monoxide (CO) by December 31, 1982,
a specific schedule for the implementation of I/M must be included in
the State Implementation Plan (SIP) revisions of January 1, 1979 for the
plan to meet the requirements, of Section 172. The general requirements
for the I/M programs are set out in a February 24, 1978 memorandum from
the EPA Administrator to the Regional Administrators (reprinted in the
Federal Register on May 19, 1978, 43 F.R. 21673). The requirements, for
these programs, are explained in acre detail below.
A. I/M SIP Revision Development and the January 1, 1979, Submittal
In producing an I/M SI? revision, the states should provide for:
1. an analysis of the benefits and costs of the program;
2. a public information effort;
3. a legislative proposal; and
4. a schedule for I/M implementation.
A copy of suggested steps for development of the SIP revision is attached
(Attachment 1). Before the January 1, 1979 submictal, the SI? revision
must be adopted by the state air pollution control board or agency head as
appropriate. As a part of the SI? revision submittal itself, there must
be a commitment by the Governor to implement the I/M program according to
the schedule submitted.*
*Sections 172(b)(7) and (10) provide that the plan revisions required
for nonattainment areas shall —
(7) identify and commit the financial and manpower resources
necessary to carry out the plan provisions required by this subsection;
[Emphasis added]
and shall —
(10) include written evidence that the state, the general purpose
local government or governments, or a regional agency designated by general
purpose local governments for such purpose, have adopted by statute, regu-
lation, ordinance, or other legally enforceable document, the necessary
requirements and schedule and timetables for compliance, and ara committec
to implement and enforce the appropriate elements of the plan; [Emphasis
added]
9/78(7/78': 1.2-2
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These plan elements should be prepared in accordance with the guidance
on pages 186-188 of the Compilation of Presentations prepared by EPA's
Office of Air Quality Planning and Standards (OAQPS) for the "Workshops
on Requirements for Nonattainment Area Plans" February -March 1978
(pages 218-220 in the April 1978 edition).
B. The I/M Implementation Schedule
The specific items listed below must be included as a part of the
States' I/M implementation schedules with specified dates for implementation
of each item. The stringency planned for the program and other factors
affecting the potential for emission reductions should also be indicated.
Additional items if necessary because of local factors may be required by
USEPA Regional Offices.
1. Initiation (or continuation) of public information
program including publicizing the I/M program in the
media, meeting and speaking with affected interest
groups, etc.
2. Preparation of a draft legislative package and
submittal of legislation package to legislature
if additional legislative authority is needed.
3. Certification of adequate legal authority by approp-
riate state official.
4. Initial notification of garages explaining program
and schedule of implementation.*
5. Development and issuance of RFPs.*
6. Award to contractor(s).*
7. Initiation of construction of facilities.*
8. Completion of construction of facilities.*
9. Adoption of procedures and guidelines for testing
and quality control including emission analyzer
requirements (and licensing requirements for private
garages, if applicable*).
10. Notification of and explanation to garages of actions
in step 9.*
9/78(7/78) 1.2-3
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11. Completion of aquipment purchase and delivery of
equipment.
12. Developnent and adoption of outpoints.
13. Initiation of hiring and training of inspectors or
licensing of garages.*
14. Initiation of introductory program (voluntary main-
tenance with either voluntary or mandatory inspection)
if not previously initiated.
15. Initiation of mechanics training and/or information
program.
16. Initiation of taaudatory inspection.
17. Initiation of mandatory repair for failed vehicles.
If certification of adequate legal authority occurs after January 1979,
the States may modify previous commitments to implement and enforce the elements
of the schedule to conform to the legal authority.** These modifications will be
approved by the EPA Regional Offices and must be consistent with the Administra-
tor's February 24, 1978, policy memorandum. The documents should be submitted
to the EPA Regional Offices for inclusion in the SIP revisions already submitted
by January 1, 1979. Any necessary adjustments to the schedule may be made at
this tine but must be approved by the EPA Regional Offices.
C. Authority to Implement I/M
Normally, adequate legal authority to implement a SIP revision must exist
for a revision to be approved. Where a legislature has had adequate
opportunity to adopt enabling legislation before January 1, 1979, the
Regional Administrator should require certification that adequate legal
authority exists for I/M implementation by January 1, 1979. However,
for aany states there will be insufficient opportunity to obtain adequate
legal authority before their legislatures meet in early 1979. Therefore,
a certification of legal authority for the implementation of I/M in
these states nust be made no later than June 30, 1979. An extension to
July 1, 1980, is possible, but only when the state can demonstrate that
(a) there was insufficient opportunity to conduct necessary technical
analyses and/or (b) the legislature has had no opportunity to consider
any necessary enabling legislation for inspection/ maintenance between
enactment of the 1977 Amendments to the Act and June 30, 1979. Certifi-
cation of adequate legal authority, or other evidence that legal authority
has been adopted, must be submitted to the EPA Regional Offices to be
included in the SI? revision already submitted. Failure to submit evidence
of legal authority by the appropriate deadline will constitute a failure
to submit an essential element of the SIP, under Sections 110(a)(2)(I)
and 176 (a) of the Act.
* Dependent otT type of system "chosen (state-run centralized, contractor
centralized, or decentralized) .
e footnote on oaee 1.
" 1 2-4
9/78(7/78)
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Prior to the respective deadlines for initiating mandatory inspection
and mandatory repair of failed vehicles, the state, local government, or
regional agency should adopt whatever legally enforceable requirements
are necessary to ensure that vehicles are not used unless they comply
with the inspection/maintenance requirements. Written evidence of
adoption of these requirements should be submitted to the EPA Regional
Offices, to be included in the SIP revision already submitted by January
1, 1979.*
D. I/M Implementation Deadlines
Implementation of I/M "as expeditiously as practicable" shall be
defined as implementation of mandatory repair for failed vehicles no
later than two and-a half years after passage of needed legislation or
certification of adequate legal authority for new centralized systems
and one and a half years after legislation or certification for decen-
tralized systems or for centralized systems which are adding emission
inspections to safety inspections. For the normal legislation deadline
of June 30, 1979, new centralized programs must start by December 31,
1981, and all others must start by December 31, 1980. For the case of
the latest possible legislation date, July 1, 1980, this means that a
new centralized program must start by December 31, 1982, while all other
programs must start by December 31, 1981. Where I/M can be implemented
more expeditiously, it must be. Each state implementation schedule must
be looked at individually to determine if it is as expeditious as practi-
cable. Implementation dates ordered by courts, if earlier than these
dates, take precedence.
E. Geographic Coverage
I/M should focus on metropolitan areas and should include the entire
urbanized area and adjacent fringe areas of development. Boundaries of the
area affected may be adjusted if an equivalent emission reduction is achieved.
For urbanized areas of 200,000 population or greater which need I/M to obtain
raar-extension of the 1982 attainment date, full mandatory I/M must be implenentad
by t'fie deadlines indicated above. Statewide programs are encouraged, especially
for those states which are small and highly urbanized.
It should be emphasized that all nonattainment areas must have SI?s
which are adequate to attain and maintain the National Ambient Air
Quality Standards (NAAQS) by 1982 or by no later than 1987 should an
acceptable nonattainment demonstration be made. For areas under 200,000,
EPA will not at this time automatically require I/M schedules in 1979 as a
condition for SIP approval or an extension. However, areas under 200,000
still have to attain and maintain NAAQS as expeditiously as practicable,
and I/M is encouraged as a means of helping to provide for an adequate
SIP. EPA will review the need for I/M in areas under 200,000 after the
1979 SIP revisions are submitted, and will consider additional require-
ments at that time.
*See footnote on page 1. 1.2-5
9/78(7/78)
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F. Emission Reductions Required for I/M
I/M programs must produce at least a 25 percent reduction in light
duty vehicle (LDV) exhaust emissions of hydrocarbons and a 25 percent
reduction in LDV emissions of carbon monoxide by December 31, 1987,
compared to what emissions would be without I/M on the basis of the most
recent motor vehicle emission factors. However, the choices of stringency
factor to be used and other actions affecting the potential for emission
reduction should be made by the states. States should of course be
encouraged to develop programs which produce more emission reduction
when possible. The final revision to Appendix N (40 C.F.R., Part 51)
when promulgated (along with its minimum program requirements) should be
used to determine if the program described in the implementation schedule
will meet the minimum 25 percent CO/25 percent HC criterion. Should a
program not need to be this stringent to attain and maintain the NAAQS
by 1982, the I/M program need be only as stringent as needed to assure
conformity with NAAQS. Should a state want to emphasize control of one
particular pollutant at the expense of the other, the plan for such an
I/M program must be submitted to the appropriate EPA Regional Office for
approval.
G. Minimum Program Requirements
In addition to the emission reduction requirement above, all I/M
programs must:
1. provide for regular periodic inspections of all vehicles
for which emission reductions are claimed;*
2. provide for maintenance and retesting of failed vehicles
to provide for compliance with applicable emission
standards;
3. prohibit registration or provide some equally effective
mechanism to prevent vehicles which do not comply with
the applicable exhaust emission requirements from operating
on public roads;
4. provide for quality control regulations and procedures
for the inspection system including:
*Random roadside checks, while a useful addition to an I/M program,
are not an acceptable substitute for regular periodic inspections.
, „ 1.2-6
9/78(7/78)
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-6-
a. minimum specifications for emission analyzers
b. required calibrations of all types on analyzers and
c. minimum record keeping;
5. provide for either a mechanics training program or a program
to inform the public of service establishments with approved
emission analyzers; and
6. inform the public of the reason for the I/M program plus
the locations and hours of inspection stations.
Decentralized systems must also comply with the following require-
ments.
1. All official inspection facilities must be licensed.
Provisions for the licensing of inspection facilities
must insure that the facility has obtained, prior to
licensing, analytical instrumentation which has been
approved for use by the appropriate state, local, or
regional government agency. A representative of the
facility must have received instructions in the proper
use of the instruments and in vehicle testing methods
and must have demonstrated proficiency in these methods.
The facility must agree to maintain records and to submit
to inspection of the facility. The appropriate government
agency must have provisions for penalties for facilities
which fail to follow prescribed procedures and for mis-
conduct.
2. Records required to be maintained should include the
description (make, year, license number, etc.) of each
vehicle inspected, and its emissions test results.
Records must also be maintained on the calibration of
testing equipment.
3. Summaries of these inspection records should be submitted
on a periodic basis to the governing agency for auditing.
4. The governing agency should inspect each facility
periodically to check the facilities' records, check
the calibration of the testing equipment and observe
that proper test procedures are followed.
5. The governing agency should have an effective program
of unannounced/unscheduled inspections both as a routine
measure and as a complaint investigation measure. It is
also recommended that such inspections be used to check
the correlation of instrument readings among inspection
facilities.
9/78(7/78)
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-7-
6. The governing agency should operate a "referee" station
where vehicle owners may obtain a valid test to compare
to a test from a licensed station. At least one 'referee"
station must be present in each I/H metropolitan area.
9/78(7/78) ! 2_8
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Attachment 1
Suggested I/M Milestones
1. Complete plan for preparing and implementing I/M SIP revision
including:
a. technical analysis
b. public information program
c. development of necessary legislation
d. development of I/M implementation schedule.
2. Complete technical analysis including:
a. emission reduction benefits
b. fuel economy benefits
c. costs.
3. Complete elements of a continuing public information program
including:
a. further publicity concerning oxidant (and/or carbon
monoxide) episodes
b. meeting with and speaking to affected interest groups
(including the public and public officials)
c. news releases.
4. Complete development of legislative proposals.
5. Complete development of I/M implementation schedule.
6. Receive approval of I/M, including implementation schedule, from
air pollution control board or agency head as applicable and
introduce into state legislature.
7. Submit SI? revision for I/M, including implementation schedule, to
EPA (due no later than January 1, 1979).
3. Obtain legal authority needed to implement I/M (required by July 1,
1979, with some exceptions allowed until July 1, 1980).
1.2-9
9/78(7/78)
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Benefits
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Section 2.1
Summary of
Emission Reduction Benefits of
Inspection/Maintenance
Fleetwide emission reductions can be estimated for motor vehicle ins-
spection/maintenancefl/M) by applying credits that are specific to the type of
emission control technology associated with a particular model year, the
years a vehicle has been in an inspection/maintenance program, and the
stringency of the program involved. USEPA has developed credits for an
annual I/M program which are percentage reductions from what emissions would
have been without I/M. These credits are listed in Tables la through 4d
in Attachment 1. Attachment 2 illustrates the application of these credits
through several sample calculations.
Assuming nationwide average model year mix and average distribution of
vehicle miles traveled by model year, USEPA has also estimated basic emission
reductions in 1987 for various types of annual I/M programs. These are tabu-
lated in the Summary Table on the next page. As is indicated in the table,
additional credits can be granted for mechanics training activities. The
"with mechanics training" credits are the maximum emission reduction credits
allowable for I/M programs, but any credits beyond the basic credits must
be specifically approved by USEPA.
The credits presented should be used with the emission factors published
in March 1978 by USEPA in Mobile Source Emission Factors, Final Document
(EPA-400/9-78-005). The credits themselves are also a part of MOBILEl
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Summary Table
Light Duty Vehicle Exhaust Emission
Reductions from Inspection/Maintenance
Programs as of December 31, 1987
Stringency
Factor
Starting
Date +
Basic
Program
CO HC
With Mechanics
Training**
CO
HC
10 7/1/80
7/1/81
7/1/82
12/31/82
20 7/1/80
7/1/81
7/1/82
12/31/82
30 7/1/80
7/1/81
7/1/82
12/31/82
40 7/1/80
7/1/81
7/1/82
12/31/82
50 7/1/80
7/1/81
7/1/82
12/31/82
+Mandatory repair for failed vehicles
22.7
21.5
19.6
18.3
29.3
27.9
25.9
24.5
34.0
32.3
30.4
28.6
38.2
36.6
34.3
32.8
41.4
40.0
37.9
35.5
26.0
24.7
22.6
20.8
30.4
28.7
25.7
23.9
33.6
32.6
30.0
27.5
35.7
34.2
31.8
30.0
36.8
35.5
32.9
31.0
46.8
46.0
43.2
41.6
54.2
52.0
50.2
48.8
57,
56,
54,
53.2
61.1
59.8
57.9
56.5
62.5
61.1
59.3
57.9
42.5
42.3
39.0
37.3
49.0
47.2
45.3
43.6
52,
50,
49,
47.6
57.7
54.3
53.1
5112
57.2
56.1
54.3
52.8
NOTE-Policy guidance regarding the
the utilization of I/M cre-
dits is due in November 1978.
is initiated on this date.
* Assumptions:
1. All model years are included in the program.
2. Nationwide averages of vehicle mix by model year
plus distribution of vehicle miles traveled by
model year afffe assumed.
** Utilication of all of or part of this credit or part of it can onlj
be made with USEPA approval.
9/78
2.1-2
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mobile source emissions model computer program so that emissions with I/M
implemented can be calculated as a part of an overall emission inventory
preparation. (See User's Guide to MOBILE1 - Mobile Source Emissions Model.
EPA-400/9-78-007, August, 1978.) AP-42 Supplement 5 emission factors should
not be utilized with the credits included here.
With respect to emission control technology, the credits have been
separated into four main groups: Technologies I, II, III, and IV. Tech-
nology I consists of all pre-catalytic vehicles, or those of model year
1974 and before.* Technology II consists of all "first generation" cata-
lytic vehicles, while 'Improved catalytic" vehicles are denoted by Tech-
nology III. All "future technology" vehicles (those designated to meet
the 1981 and later statutory standards and those vehicles which are
comparable) are denoted by Technology IV. Calculations utilizing these
credits should be consistent with the list below.
Non-California
Model Year Technology
pre-1975 I
1975-1979 II
1980 III
1981 and later IV
*While some 1975 and later model year vehicles are not catalyst-equipped,
all vehicles should be considered as a part of their applicable model year.
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California
Model Year Technology
pre-1975 I
1975-1979 III
1980 and later IV
The-year s a vehicle has been in an inspection program also has an
important effect on the emission reductions achievable. I/M programs
have the potential to reduce emission deterioration rates of vehicle
fleets over time. Therefore, the benefits from inspection/maintenance
programs are estimated to increase with added years of program operation.
This is reflected in the I/M credits included in both Attachment 1 and
the Summary Table.
Finally, the stringency of the program involved has ah effect on the
total possible emission reduction. The stringency factor is related to
the proportion of vehicles that would have failed a given set of I/M
testing standards, or cutpoints, prior to implementation of an I/M
program. Because some vehicle owners may maintain their vehicles in
anticipation of an emissions inspection, the failure rate may tend to
be somewhat lower than the stringency factor. In estimating the benefits
attributable to programs with various stringency factors, USEFA has
assumed that it is as important to fail a high Federal Test Procedure (FTP)
carbon monoxide (CO) emitter as a high FTP hydrocarbon (HC) emitter.
9/78 2.1-4
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Attachment 1
Emission Reductions
Attributable to Inspection/
Maintenance Programs
9/78
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Table l.a
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
BASIC PROGRAM CREDITS
10%
Technology 1
20%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
3%
6
11
15
19
24
27
31
35
39
41
42
44
46
47
48
49
51
52%
4%
8
13
18
22
28
34
36
40
42
45
46
49
50
51
52
54
56
57%
Stringency Factor
30%
7%
14
20
28
34
39
43
46
49
52
54
55
57
58
59
60
61
62
63%
40%
50%
15
22
30
36
41
46
49
52
54
56
58
59
61
62
63
64
65
65%
16
23
31
37
42
46
50
53
55
57
59
60
61
62
63
64
65
66%
9/78
2.1-6
-------
Table l.b
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
BASIC PROGRAM CREDITS
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
10%
Technology 1
20%
Stringency Factor
30% 40%
50%
7%
13
17
22
26
30
32
35
37
40
41
42
44
45
46
47
48
50
50%
9%
17
22
27
31
35
37
40
42
44
46
48
49
51
52
53
54
55
56%
12%
21
27
32
36
40
44
47
49
52
53
55
56
58
59
60
61
62
62%
14%
23
29
35
39
43
47
50
52
55
56
58
59
60
61
62
63
64
65%
15%
25
31
36
41
45
49
52
54
56
58
59
61
62
63
64
65
65
66%
9/78
2.1-7
-------
Table l.c
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Technology 1
10% 20%
6% 9%
13 14
17 19
20 25
25 31
32 36
35 43
40 45
45 50
47 51
49 53
50 54
53 55
53 56
54 58
56 58
57 61
57 63
58% 63%
Stringency Factor
30% 40%
12%
19
27
35
41
44
51
53
55
57
59
61
61
63
65
65
66
66
67%
13%
24
33
40
46
50
54
57
59
61
63
65
65
66
68
68
69
70
71%
50%
14%
25
35
42
48
53
56
59
62
64
65
66
68
69
70
70
71
72
72%
9/78
2.1-8
-------
Table l.d
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
6
7
Year 1
Year 2
Year 3
Year 4
Year 5
Year
Year
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
10%
11%
20
26
30
34
40
43
47
50
52
53
55
58
57
58
59
61
60
62%
Technology 1
20%
Stringency Factor
30% 40%
50%
16%
23
29
35
40
43
49
51
54
55
57
58
59
60
62
62
64
66
66%
20%
29
37
42
47
49
55
57
59
61
62
64
64
66
67
68
68
68
70%
22%
34
41
46
51
55
58
61
63
64
65
67
68
69
70
70
71
72
73%
23%
35
42
48
53
57
60
62
65
66
68
69
70
71
72
72
73
74
74%
9/78
2.1-9
-------
Table 2. a
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
BASIC PROGRAM CREDITS
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Technology 2
10% 20%
4% 6%
6 11
9 16
11 20
16 23
19 27
20 31
23 33
25 36
28 38
29 40
30 41
32 43
33 44
35 45
36 46
36 47
37 48
38% 49%
Stringency Factor
30%
40%
10%
18
24
28
33
36
40
42
45
47
48
50
51
53
55
55
55
57
58%
12%
20
26
32
37
40
43
46
49
51
52
54
55
56
57
59
59
60
61%
50%
13%
22
28
34
39
43
46
49
51
54
55
57
58
59
61
61
62
63
64%
9/78
2.1-10
-------
Table 2.b
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
BASIC PROGRAM CREDITS
Technology 2
10%
Stringency Factor
20% 30% 40%
50%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
10%
15
20
23
26
28
31
32
34
35
37
37
38
40
41
41
42
43
44%
17%
25
29
32
36
38
41
42
44
46
47
48
49
50
51
52
52
53
54%
21%
31
36
40
44
47
49
51
53
55
56
57
58
59
60
61
62
62
63%
23%
34
39
43
46
49
52
54
56
57
59
60
61
62
63
63
64
65
65%
25%
36
41
45
49
52
54
56
58
60
61
62
63
64
65
66
67
67
68%
9/78
-------
Table 2.c
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
10%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
9%
13
15
18
22
26
28
31
33
35
37
39
40
42
44
44
44
46
48%
Technology 2
20%
13%
16
20
26
31
34
38
41
43
44
45
47
48
50
52
52
53
54
55%
Stringency Factor
30% 40%
50%
14%
21
28
33
38
41
45
47
50
52
53
54
56
57
59
60
61
61
62%
15%
24
31
36
41
44
48
50
52
54
56
58
58
60
61
62
63
63
65%
16%
26
33
39
43
47
50
53
55
57
59
60
61
63
64
65
65
66
67%
9/78
2.1-12
-------
Table 2.d
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
10%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
17%
25
27
31
35
38
40
43
44
45
49
50
50
53
54
54
55
56
58%
Technology 2
20%
26%
33
36
41
46
48
51
54
56
57
58
59
60
61
63
63
64
65
66%
Stringency Factor
30% 40%
50%
30%
41
47
50
54
57
59
61
63
65
65
66
67
68
69
70
71
71
71%
32%
45
50
54
57
60
63
64
65
67
68
69
70
71
72
72
73
73
74%
33%
47
52
56
60
62
65
67
68
69
70
71
72
73
74
74
75
75
76%
9/78
2.1-13
-------
Table 3.a
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
BASIC PROGRAM CREDITS
Technology 3
10%
20%
Stringency Factor
30% 40%
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
4%
11
22
32
42
49
54
58
62
64
66
68
69
71
72
73
74
74
75%
4%
13
25
37
46
53
58
62
65
67
69
71
72
73
74
75
76
77
77%
4%
15
28
40
49
55
60
64
67
69
71
72
74
75
76
77
77
78
79%
5%
17
31
43
51
58
63
66
69
71
73
74
75
76
77
78
79
79
80%
50%
5%
18
32
44
53
59
63
67
70
72
73
75
76
77
78
79
79
80
81%
9/78
2.1-14
-------
Table 3.b
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
BASIC PROGRAM CREDITS
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Technology 3
10% 20%
0% 0%
4 5
8 10
14 18
20 23
26 28
30 32
33 37
35 40
39 43
42 45
44 47
45 49
48 51
49 52
50 53
50 54
53 56
55% 57%
Stringency Factor
30% 40%
1%
6
13
21
27
33
38
42
45
48
50
52
54
56
57
59
60
61
62%
1%
6
14
22
28
34
39
43
47
49
52
54
55
57
58
60
61
62
63%
50%
2%
7
14
22
29
35
40
44
47
50
52
54
56
58
59
60
61
62
63%
V78
2.1-15
-------
Table 3.c
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
10%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
10%
33
51
59
67
70
74
76
78
80
80
81
82
83
84
84
85
85
86%
Technology 3
20%
13%
36
53
62
69
73
76
78
80
81
82
83
83
84
85
85
86
86
87%
Stringency Factor
30% 40%
15%
38
54
64
70
74
77
79
81
82
83
84
85
85
86
86
87
87
87%
50%
16%
39
54
64
70
74
77
80
81
83
84
85
85
86
87
87
87
88
88%
16%
39
54
64
70
74
77
80
81
83
84
85
86
86
87
87
88
88
88%
9/78
2.1-16
-------
Table 3.d
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
10%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
5%
24
40
48
56
60
65
67
69
72
72
74
75
76
77
78
78
79
79%
Technology 3
20%
8%
27
42
51
58
63
66
69
71
73
74
76
76
77
78
79
79
80
80%
Stringency Factor
30% 40%
50%
11%
29
43
52
59
64
67
70
72
74
75
76
77
78
79
80
80
81
81%
13%
30
43
52
59
64
68
71
73
75
76
77
78
79
80
80
81
82
82%
14%
30
43
52
59
64
68
71
73
75
76
77
78
79
80
81
81
82
82%
9/78
2.1-17
-------
Table 4.a
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
BASIC PROGRAM CREDITS
10%
Technology 4
20%
Benefit Year 1
Benefit Year 2
Benefit Year 3
Benefit Year 4
Benefit Year 5
Benefit Year 6
Benefit Year 7
Benefit Year 8
Benefit Year 9
Benefit Year 10
Benefit Year 11
Benefit Year 12
Benefit Year 13
Benefit Year 14
Benefit Year 15
Benefit Year 16
Benefit Year 17
Benefit Year 18
Benefit Year 19
3%
7
14
23
31
38
44
49
53
56
58
60
62
63
65
66
67
68
69%
3%
7
15
24
33
40
46
51
54
57
60
62
63
65
66
67
68
69
70%
Stringency Factor
30% 40%
3%
7
16
25
34
41
47
51
55
58
60
62
64
65
67
68
69
70
71%
3%
8
17
26
35
42
48
52
56
59
61
63
65
66
68
69
70
71
71%
50%
3%
8
17
27
36
43
49
54
57
60
62
64
66
67
68
69
70
71
72%
9/78
2.1-18
-------
Table 4.b
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
BASIC PROGRAM CREDITS
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year
Year
Year
Year
Year
Year
Year
Year
Year
Year
Year
Year
Year 13
Year 14
Year
Year
Year
Year
Year
1
2
3
4
5
6
7
8
9
10
11
12
15
16
17
18
19
Technology 4
10% 20%
0% 0%
2 4
7 11
13 19
19 26
24 32
29 37
33 42
37 45
40 48
43 51
45 53
47 55
49 56
50 58
52 59
53 60
54 62
55% 62%
Stringency Factor
30% 40%
50%
1%
5
13
21
28
34
40
44
48
51
53
55
57
58
60
61
62
63
64%
2%
8
18
28
36
42
47
52
55
58
60
62
63
65
66
67
68
69
70%
3%
12
23
33
42
48
53
57
60
63
65
66
68
69
70
71
72
73
74%
9/78
2.1-19
-------
Table 4.c
ESTIMATED PERCENT REDUCTION IN HYDROCARBON EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Technology 4
10% 20%
7% 11%
24 29
36 45
52 56
54 63
65 68
66 70
69 74
72 76
75 76
75 78
75 80
77 80
79 81
79 82
80 82
80 83
81 84
81% 84%
Stringency Factor
30% 40%
12%
32
46
58
65
69
72
75
76
77
80
81
81
82
83
83
84
85
85%
14%
36
52
62
68
73
76
78
80
81
82
83
84
85
85
86
86
87
87%
50%
15%
38
54
64
70
74
77
79
81
83
84
85
85
86
87
87
88
88
88%
9/78
2.1-20
-------
Table 4.d
ESTIMATED PERCENT REDUCTION IN CARBON MONOXIDE EMISSION
MAXIMUM PROGRAM CREDITS (WITH MECHANIC TRAINING)
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Benefit
Year 1
Year 2
Year 3
Year 4
Year 5
Year 6
Year 7
Year 8
Year 9
Year 10
Year 11
Year 12
Year 13
Year 14
Year 15
Year 16
Year 17
Year 18
Year 19
Technology 4
10% 20%
9% 15%
30 37
41 51
56 60
58 66
68 70
68 72
71 76
74 77
77 78
77 80
76 82
79 82
81 82
81 83
81 84
81 84
82 85
83% 85%
Stringency Factor
30% 40%
18%
39
52
62
68
71
74
77
78
79
82
82
82
84
84
84
85
86
86%
21%
43
57
66
71
75
78
80
81
83
84
85
85
bo
&6
87
87
88
88%
50%
23%
44
58
66
72
76
79
81
83
84
85
86
86
87
88
88
88
89
89%
9/78
2.1-21
-------
Attachment 2
Methodology for Applying
Attachment 1 Credits
9/78 2.1-22
-------
The following estimates of fleetwide HC and CO benefit assume that an
inspection/maintenance program is implemented on July 1 of calendar
year y, and calculated on July 1 of calendar year i. Interpolation
may be applied to obtain benefit estimates for programs which begin
or are evaluated at times other than July 1. The following infor-
mation in addition to the Attachment 1 tables of credits is required
for the calculations:
1. The calendar year, y, in which an I/M program was (or will
be) operational.
2. The fraction of vehicles of model year i-19 through i
contributing to the vehicle population on July 1. Vehicles
of model years earlier than i-19 should be considered as
model year i-19.
3. Average vehicle miles traveled in calendar year i by each
model year group of vehicles.
4. July 1 of calendar year i FTP HC and CO emission factors
(gm/mi) for each model year group of vehicles, assuming
I/M has never been in effect.
The calculation of benefit for a given pollutant (HC or CO) on July
1 of calendar year i is performed as follows:
*._Jjt 6it mit ^t I 6it t=.mi5 "if
where
b f Attachment 1 credit for vehicles of model year t on July 1 of
""calendar year i,
e ' emission factor (gm/mi) for vehicles of model year t on
it:July 1 of calendar year i, assuming I/M has never been
in effect,
m.= average vehicle miles traveled per year by vehicles of model
1 year t in calendar year i,
p.= fraction of the July 1, calendar year i, vehicle population which
lt:is of model year t.
9/78
-------
The b. entries can be found in Attachment 1 by identifying the
maximum number of inspections that model year t vehicles could have
undergone by July 1 of calendar year i. The maximum number of annual
inspections which a model year t vehicle could possibly incur defines
the benefit year which is applicable to vehicles of that model year.
The b. entry in the above expression for B. is the credit which
corresponds to this benefit year. Model year vehicles which could
have undergone more than 19 annual inspections should be counted as
having undergone 19.
The calculation of the fleetwide July 1 emission factor ef. with
I/M is performed as follows:
ef.
100-Bi
100
-fc
t=i-19
e.
it
m.
it
mit
'it
If scenario-specific estimates of e. , m. , and p. are unavailable,
nationwide estimates can obtained by referring to the Mobile Source Emission
Factors, Final Document (EPA 400/9-78-005, March, 1978). The credits
given in Attachment 1 are not applicable to emission factors as estimated
in AP-42, Supplement 5. Nationwide estimates of m. and p. are
provided in Tables 1 and 2 respectively.
9/78
2.1-24
-------
Examples of the Calculation of Benefits
Example 1: The July 1 nationwide mix of vehicles by model year and
nationwide estimates of average vehicle miles traveled apply. An I/M
program with a 40% stringency factor was implemented in 1973. Determine
the percent reduction in emissions for HC and CO on July 1 of CY 1977,
assuming that inspections are annual, and that no mechanic training
program is in effect.
Solution: The percent reduction, B7?, can be calculated from the
following formula:
77 77
B77=100 I: b?7 e »77ftp77ft / I e77)tm77)tp77>t.
t—JO C—DO
The following tables detail the calculation of the numerator and de-
nominator of B?? for both HC and CO.
9/78 2-1-25
-------
Numerator Denominator
Product Product
1.6
2.6
HC 1975 20 1.9 14.0 .107 0.6 2.9
6.9
7.0
6.6
6.0
5.4
4.4
3.3
3.0
2.1
1.4
1.0
0.6
0.4
0.3
0.3
0.3
0.3
15.1 56.4
HC: B77 = - 27%
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
1959
1958
0%
12
20
22
30
30
30
30
30
30
30
30
30
30
30
30
30
30
30
30%
1.3
1.6
1.9
5.0
5.7
6.3
6.9
7.4
7.9
8.3
11.3
11.7
12.1
12.5
12.8
13.1
13.4
13.7
14.0
14.2
15.9
15.0
14.0
13.1
12.2
11.3
10.3
9.4
8.5
7.6
6.7
6.6
6.2
5.9
5.5
5.1
5.0
4.7
4.4
4.4
.075
.107
.107
.106
.100
.092
.085
.077
.066
.052
.039
.027
.018
.014
.009
.006
.005
.005
.005
.004
0.0
0.3
0.6
1.5
2.1
2.0
1.8
1.6
1.3
1.0
0.9
0.6
0.4
0.3
0.2
0.1
0.1
0.1
0.1
0.1
9/78 2.1-26
-------
'77,t
m
77,t
'77,t
Numerator
Product
Denominator
Product
1977
1976
CO 1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
1959
1958
0%
23
34
29
35
35
35
35
35
35
35
35
35
35
35
35
35
35
35
35%
20.3
24.1
28.2
60.8
68.7
76.0
82.8
89.0
94.7
99.8
104.7
.7
.7
106
108
110.6
112.4
114.0
115.6
117.1
118.5
119.9
15.9
15.0
14.0
13.1
12.2
11.3
10.3
9.4
8.5
7.6
6.7
6.6
6.2
5.9
5.5
5.1
5.0
4.7
4.4
4.4
.075
.107
.107
.106
.100
.092
.085
.077
.066
.052
.039
.027
.018
.014
.009
.006
.005
.005
.005
.004
0.0
8.9
14.4
.5
3
,7
24.
29.
27.
25.4
22.6
18.6
13.8
9.6
6.7
4.3
3.2
2.0
1.2
1.
1.
0.9
CL7
215.8
24.
38.
42.
84.4
83.8
79.0
72.5
64.4
53.1
39.4
27.4
19.0
12.
9.
5.6
3.5
2.9
2.8
2.6
2.1
668.8
.1
,1
CO: B
77
215.8
668.8
= 32%
Example 2: Determine the percent reduction in emissions, B^, for 1IC
and CO under the assumptions of example 1, except assume that a mechanic
training program is in effect.
Solution: The method used for example 1 applies. Only the entries of
b will change to reflect the additional benefit credited for an
adequate mechanic training program. The following tables give the
details of the calculations:
9/78
2.1-27
-------
Numerator
Product
Denominator
Product
1977
1976
HC 1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
1959
1958
0%
15
24
33
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40%
1.3
1.6
1.9
5.0
5.7
6.3
6.9
7.4
7.9
8.3
11.4
11.7
12.1
12.5
12.8
13.1
13.4
13.7
14.0
14.2
15.9
15.0
14.0
13.1
12.2
11.3
10.3
9.4
8.5
7.6
6.7
6.6
6.2
5.9
5.5
5.1
5.0
4.7
4.4
4.4
.075
.107
.107
.106
.100
.092
.085
.077
.066
.052
.039
.027
.018
.014
.009
.006
.005
.005
.005
.004
0.0
0.4
0.7
2.3
2.8
2.6
2.4
2.1
1.8
1.3
1.2
0.8
0.5
0.4
0.3
0.2
0.1
0.1
0.1
0.1
HC: B
77
b
20.2
56.4
= 36%
77,t
20.2
Numerator
Product
1.6
2.6
2.9
6.9
7.0
6.6
6.0
5.4
4.4
3.3
3.0
2.1
1.4
1.0
0.6
0.4
0.3
0.3
0.3
0.3
56.4
Denominator^
Product
1977
1976
1975
CO 1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
1959
1958
0%
32
45
41
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46
46%
20.3
24.1
28.2
60.8
68.7
76.0
82.8
89.0
94.7
99.8
104.7
106.8
108.7
110.6
112.4
114.0
115.6
117.1
118.5
119.9
15.9
15.0
14.0
13.1
12.2
11.3
10.3
9.4
8.5
7.6
6.7
6.6
6.2
5.9
5.5
5.1
5.0
4.7
4.4
4.4
.075
.107
.107
.106
.100
.092
.085
.077
.066
.052
.039
.027
.018
.014
.009
.006
.005
.005
.005
.004
0.0
12.4
19.0
34.6
38.6
36.3
33.4
29.6
24.4
18.1
12.6
8.8
5.6
4.2
2.6
1.6
1.3
1.3
1.2
1.0
,2
.7
,2
.4
286.6
24.
38.
42.
84.
83.8
79.0
72.
64.
53.
39.4
27.4
19.0
12.
9.
5.6
3.5
2.9
2.8
2.6
2.1
668.8
.5
.4
.1
,1
,1
CO: B
77
43%
9/78
2.1-28
-------
Example 3: The July 1 nationwide mix of vehicles by model year and
nationwide estimates of average VMTs apply. An I/M program with a 30%
stringency factor is to be implemented in CY 1980. Vehicles will be
tested annually, and no mechanic training program will be in effect.
«.._. c --, 90, for IIC and CO on July
1 of CY 1990, and the resulting reduced emission factors for HC and CO
Determine the percent reduction in emissions, B
390, and the
on July 1 of CY 1990.
Solution: The calculations of
outlined in examples 1 and 2.
culations:
for HC and CO are performed as
:e following tables detail these cal-
390,t
"90, t
Numerator
Product
Denominator
Product
1990
1989
1988
1987
1986
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
1972
1971
0%
3
7
16
25
34
4.1
47
51
55
69
47
47
47
47
47
52
52
52
52%
0.3
0.6
0.9
1.2
1.5
1.8
2.1
2.3
2.5
2.7
2.9
4.0
4.2
4.3
4.4
4.6
10.6
10.9
11.1
11.4
15.9
15.0
14.0
13.1
12.2
11.3
10.3
9.4
8.5
7.6
6.7
6.6
6.2
5.9
5.5
5.1
5.0
4.7
4.4
4.4
.075
.107
.107
.106
.100
.092
.085
.077
.066
.052
.039
.027
.018
.014
.009
.006
.005
.005
.005
.004
0.0
0.0
0.1
0.3
0.5
0.6
0.8
0.8
0.7
0.6
0.5
0.3
0.2
0.2
0.1
0.1
0.1
0.1
0.1
0.1
HC:
6.2
17.9
= 35%
6.2
0.4
1.0
1.4
1.7
.8
.9
1.
1.
1.8
1.7
1.4
1.1
0.8
0.7
0.5
0.4
0.2
0.1
0.
0.
0.2
0.2
17.9
9/78
2.1-29
-------
C0: B90 - = 33%
Numerator Denominator
Product Product
1990 0% 2.6 15.9 .075 0.0 3.1
1989 1 5.3 15.0 .107 0.1 8.5
1988 5 8.3 14.0 .107 0.6 12.4
1987 13 11.0 13.1 .106 2.0 15.3
1986 21 13.6 12.2 .100 3.5 16.6
1985 28 16.0 11.3 .092 4.7 16.6
1984 34 18.2 10.3 .085 5.4 15.9
1983 40 20.2 9.4 .077 5.9 14.6
1982 44 22.1 8.5 .066 5.5 12.4
1981 48 23.7 7.6 .052 4.5 9.4
1980 48 30.4 6.7 .039 3.8 7.9
1979 55 53.8 6.6 .027 5.3 9.6
1978 55 55.6 6.2 .018 3.4 6.2
1977 55 57.3 5.9 .014 2.6 4.7
1976 55 58.9 5.5 .009 1.6 2.9
1975 55 60.4 5.1 .006 1.0 1.9
1974 52 126.2 5.0 .005 1.6 3.2
1973 52 129.2 4.7 .005 1.6 3.0
1972 52 132.1 4.4 .005 1.5 2.9
1971 52% 134.8 4.4 .004 1.2 2.4
55.8 169.5
The reduced emission factors for HC and CO are calculated using the
following formula:
100-Bg() 90 90
ef90 * TOO X 690,t m90,t P90,t ' ra90,t P90,f
Substituting the appropriate numbers,
HC: ef,0 . , - 1.0 sW.nl
__ e JLUU-Jj J.D9.3 ._ . / .
CO: cf9Q - lftft x ,, o - 10.1 gm/mi.
9/78 2.1-30
-------
Table 1
Miles Travelled Per Year of Vehicle Life*
Year Miles (in thousands)
1 15.9
2 15.0
3 14.0
4 13.1
5 ^.2
6 11.3
7 10.3
8 9.4
9 8.5
10 7.6
11 6.7
12 6.6
13 6.2
14 5.9
15 5.5
16 5.1
17 5.0
18 4.7
19 4.4
20 4.4
Statistics for years 1-11: Strate, H.E. Nationwide Personal
Transporation Study-Annual Miles of Automotive Travel. Report
Number 2, U.S. Department of Transportation, Federal Highway
Administration, Washington, D.C. April, 1972. Statistics for
years 12-20: 1972 Census of Transporation Truck Inventory
and Use Survey, U.S. Department of Commerce, October, 1973;
as summarized by Michigan Technological University in the
report EPA-R803782010: The Development of_ an Emission and
Fuel Economy Computer Model for Heavy-Duty Trucks and
Buses, August, 1977.
9/78 2.1-31
-------
Table 2
Fraction of Vehicles on the Road on July 1 of Calendar Year CY*
Model Year Fraction
CY .075
CY-1 .107
CY-2 .107
CY-3 -106
CY-4 .100
CY-5 .092
CY-6 .085
CY-7 .077
CY-8 .066
CY-9 .052
CY-10 .039
CY-11 .027
CY-12 .018
CY-13 .014
CY-14 .009
CY-15 .006
CY-16 .005
CY-17 .005
CY-18 .005
CY-19 .004
MVHA Motor Vehicle Facts & Figures '77, p. 34. Data averaged
over the years 1968-1970, 1972-1976.
9/78
2.1-32
-------
Costs
-------
Section 3.1
The Costs of
Inspection/Maintenance
The Clean Air Act Amendments of 1977 underscored the importance of motor
vehicle inspection/maintenance (I/M) programs as a key measure in reducing
vehicle emissions and helping to achieve the national ambient air quality
standards. The Amendments direct that, should a state not be able to
demonstrate attainment of the standards for photochemical oxidants (Ox)
or carbon monoxide (CO) by December 31, 1982, even with the implementation
of all reasonably available measures, a specific schedule for the imple-
mentation of I/M must be included in the SIP revisions of January 1, 1979.
This commitment is necessary to enable an extension of the attainment date
up to December 31, 1987.
I. PURPOSE
Experience to date with vehicle inspection and maintenance programs has
shown them to be an effective, practical and cost-effective approach to
achieving significant emission reductions from in-use vehicles. But while
cost-effective, overall I/M program costs have varied substantially from
program to program (See Table 1).
For states which will need I/M, a very important question is what is it
going to cost to implement, administer and operate an I/M program in
their jurisdiction? The following pages are intended to provide information
9/78
3.1-1
-------
to enable states to answer this question. As such their focus is towards
costs associated with the administration and operation of the inspection
phase though a summary of vehicle repair costs is included later in this
section. The major cost categories examined are capital and annual (recurring)
costs.
The report (l) discusses what program objectives and variables States
should consider in assessing I/M costs; (2) outlines simplified cost
analysis methodologies; (3) notes references where more detailed and
extensive information can be found and; (4) lists representative cost
figures from ongoing I/M programs and recent area-specific I/M feasibility
studies. Emphasis was not placed on recounting a host of cost estimates
found in previous documentation since the relative accuracy of these figures
could not be determined nor could they necessarily provide directly applicable
data for areas now considering I/M. Summary tables of these costs are
included as appendices to the report.
9/78 3'1"2
-------
fable 1
Characteristics of Selected Existing I/M Programs
Capital and Operating Costs
Last Data Year
Location/
Fee
Test Mode & Type/
Average Repair Cost
# of vehicles/
Capital Cost ($)
% of vehicles failing/
Annual operating cost ($)
1977
Arizona
$5
Contractor; Idle with
loaded mode capabilities
permanent & mobile faci-
lities; 30 permanent
lanes, 1 mobile lane
$23.02
1.1 million
$9.134 million
.134 million to
Arizona DHS for
program develop-
ment
9.0 million to
HTS comprised of
(3.6 buildings)
(1.4 land)
(3.0 equipment)
(1.0 personnel)
16.2%
.5 million Ariz
4.0 million HTS
-------
Last Data Year
•si
oo
Location/
Fee
Test Mode & Type/
Average Repair Cost
// of vehicles/
Capital Cost ($)
% of vehicles failing/
Annual operating cost ($)
1978
Oregon:
Portland-Metro-
politan Service
District
State-run;
Idle mode with
permanent and
mobile facilities;
10 permanent lanes,
5 mobile lanes
.58 million
36% (biannual)
$5
$18.86
$1.2 million for
2 years
(181,750 land &
building)
(203,000 equipment
(815,750 administra-
tion)
2.25 million total
(biannual)
(1.34 million
personnel)
(.416 service &
supplies
(,163 equipmt.)
(.295 admin.)
-------
Tabltr 1 (contd.)
Last Data Year
Location/
Fee
Test Mode & Type/
Average Repair Cost
# of vehicles/
Capital Cost ($)
% of vehicles failing/
Annual operating cost ($)
1978
New Jersey;
Statewide
$2.50
State-run;
Idle mode with
permanent facilities;
Includes safety and
emissions; expanded
to include garage
recertification:
68 permanent lanes
15.83
4.5 million
18%
$0.25 million for
equipment; add-on
to existing safety
facilities with $1.0
million personnel
($32.95 million in
original safety &
emission facility
capital investment)
$10,588,544
total annual
operating
costs (both safety and
emissions)
$200,000 rental and
$2.0 million
personnel associated
with emissions
Sources: "Information Document on Automobile Emissions Inspection and Maintenance
Programs, Fe. 78, USEPA, GCA Corporation, and conversations with John
Elston, Fred lacobelli and Ron Householder. See also Reference 3.
-------
II. FACTORS INFLUENCING I/M COSTS
Reasons for the relative variability in the costs of an I/M program can
generally be attributed to three major areas:
(1) its organizational structure - it is state-owned and operated
at centralized facilities; contractor (franchise) operated
under State administration at centralized facilities; or
private garage operated (decentralized facilities) under
State administration;
(2) the type and mode of test employed - emissions test only or
emissions piggy-backed with safety inspection; use of idle
versus loaded mode exhaust emissions test or other inspection
formats and;
(3) the geographic location of the program - noting its population
& vehicle density; degree of urbanization; the prevailing labor
rates, land and material costs of a reflection of regional market
conditions; etc.
The following discussion briefly reviews these considerations and other
issues inherently associated with them.
9/78 3.1-6
-------
Organizational Structure
A State will wish to choose a particular administrative arrangement for I/M
in light of several considerations: the aggregate costs to government and
its administrative capability to support an I/M program; the time required
for program initiation and implementation; and the degree of public accept-
ability including measures for consumer protection and convenience. Table
(2) outlines the advantages and disadvantages associated with various I/M
structures.
A State should assess what level of effort and program functions it would
be willing and able to support under the various I/M approaches. For
example, a State-owned and operated centralized system would involve more
capital outlay to the State for equipment and initial start-up expenses
but would entail less administrative, auditing and surveillance costs
over time than would a franchise or private garage-based system. The
ability to support escalating staff salaries and fringe benefits (labor
costs) over time is an important consideration to be weighed versus the
*
beneficial aspects of direct State control of the program.(1) States
which already have experience with some pilot forms of I/M or with
safety inspection systems in place may or may not find it desirable to
integrate emissions testing into the existing State operations depending
upon their test requirements and administrative structure.(2)
9/78 3"1'7
*Footnotes refer to technical notes, not bibliographical references.
-------
Table 2
00
COMPARISON OF ALTERNATIVE I/M ORGANIZATIONAL
STRUCTURES: ADVANTAGES AND DISADVANTAGES
Public Centralized
Advantages
Consumer Protection:
Disadvantages
Consumer Convenience:
1. Inspection separate
from repair; no conflict
of interest.
2. Independent basis for
judging the performance
of the service industry.
3. Monitoring of instruments'
and inspectors' performance
facilitated, thereby reducing
testing variability.
4. Designed specifically for
high capacity emission testing
1. Fewer inspection facilities
than with decentralized
systems, thus an increased
probability of longer
travel and wait.
Cost
1. Start-up requires large
public capital outlay
if land and equipment acqui-
sition and building construc-
tion is necessary.
2. All program costs born
by public sector.
3. Risk of increasing long-
term fixed costs to
government due to increase
in number of potential
retirement/pension
beneficiaries.
4. Long lead time for land
acquisition and construc-
tion.
t
oo
-------
Table 2 (cont.)
Advantages
Disadvantages
00
Public Centralized
(continued)
Cost:
State Convenience
Potentially lower 1.
(inspection) labor
costs compared to decen-
tralized systems can mean 2.
lower recurring costs.
More efficient use of
equipment than in decentra-
lized systems, economy of
scale of multi-lane stations.
Will sometimes require
that state must obtain
land.
Relatively greater
number of state employees
to hire than other options,
Information:
1. Data collection facilitated; benefits from computer
applications
2. Loaded mode testing possible.
i
vo
-------
Advantages
Disadvantages
oo
Table 2 (cont. )
Centralized
(Contractor-Operated)
Consumer Protection;
Information:
same as
public
centralized
Consumer Convenience:
Consumer Protection
same as
public
centralized
i
f*
o
Cost: Same as public centralized,
plus
1. All program costs born by
private sector except those
associated with adminis-
trative oversight.
2. No risks of increasing long-
term fixed governmental
costs.
3. Permits use of corporate tax
structure to reduce burden of
start-up capital expenditures.
State Convenience
1. Private sector may be
able to obtain land and
hire new employees more
readily than a state
agency.
Information
1. Data collection and handling
can be part of contractor's
duties.
Possible adverse public
reaction to corporation
earning profits from
"captive market."
Potential for
extensive and costly
State administrative
functions to monitor
contract.
Start-up time less
than State but more than
decentralized approach.
-------
Table 2 (cont.)
-J
00
Private (Service
Industry) Decentralized
Advantages
Consumer Convenience:
Disadvantages
Consumer Protection:
Greater number of 1«
facilities increases
probability of mini-
mizing travel and
wait times.
Possibility for one-
stop inspection/ 2.
maintenance; with most
safety inspection programs
being decentralized, offers
easy combination of tests. 3.
Training of inspectors
involves direct contact
between state and service
industry; can promote
communication necessary
for proper implementation
of program.
Inspection not
separate from repair:
presents potential
for conflict of
interest which requires
active state oversight.
No independent basis
for judging perfor-
mance of service
industry.
Effective monitoring
of inspectors and
instruments is substantially
more difficult.
Cost:
Lower start-up costs for
state than in public centra-
lized system; reduces financial
burden of state-captial invest-
ments.
All operating program costs born by
private sector except
administration and monitoring.
OJ
i—i
i
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00
Table 2 (cent.)
Private (Service Industry)
Decentralized (continued)
Cost:
Generally high labor
costs for monitoring of
licensed stations can
mean high recurring costs.
Less efficient use of
equipment than in centra-
lized systems
Inspector training
involves greater
numbers than in centra-
lized systems and is
therefore more costly.
Information:
Sources: See references 3, 8, and 14.
Uniform and detailed
data collection is
more difficult.
Loaded mode testing
is difficult if not
impossible.
10
i-"
i
i-»
to
-------
Scheduling for I/M initiation and implementation varies according to
system type. State or publicly-operated centralized systems generally
require more start-up time than decentralized, private systems. Centralized
I/M programs are capital intensive requiring the purchase of land, buildings
and test hardware.(3) States usually require competitive bidding procedures
to be followed for each of these cost categories and the time required
between legislation and actual operation is comparatively longer than other
systems. While a franchise system involves many of these same contracting
procedures the necessary start-up period is usually less since only one
contract agreement is necessary for operation of the many aspects of the
system.(4) A private decentralized approach is expected to take the least
time to initiate because of the immediate presence of inspection sites and
the purchase of equipment is by the garage owners.(5)
Public acceptability is probably the most important consideration
influencing organizational structure, I/M costs, and the success of I/M
overall. The public's acceptability of I/M is determined not only by the
amount of out-of-pocket expenses incurred and the perceived benefits but
by the guarantee of consumer protection and the relative convenience of
the program. Consumer protection and consumer convenience are functions
of both the I/M system (centralized, decentralized) and its ownership
(public, private). Centralized systems due to their potentially higher
lane capacity, require fewer inspection sites.
*Deadlines for I/M implementation^^ included in USEPA's policy paper
9/78
on I/M issued on July 17, 1978 . See reference 15.
3.1-13
-------
The reduced number of sites allows more effective monitoring of
inspectors and equipment, thereby reducing test variability due to
variations in inspector and instrumentation performance. This results
in a decreased possibility of error in measuring vehicle emissions.
The smaller number of sites also means that a smaller total number of
personnel are involved in providing inspections; hence, lower inspector
training costs are incurred.(6) The private garage system, while
offering the convenience of combining both inspection and maintenance
functions, presents a potential conflict of interest since the mechanic
who determines whether or not a car must be repaired also stands to
gain business from this determination. A State-run centralized
system offers a distinct inspection phase versus a repair phase thereby
removing the possible conflict of interest, thus removing one source
of possible public dissatisfaction.
A franchise scheme would be equally as acceptable to the public as a
State-run system if it was assured that the contractor was not involved
in the parts or repair industry and that the State is effectively and
objectively monitoring the contract.
To assure the integrity of such a system, the State must maintain
an effective monitoring and unannounced audit program of licensed
stations.
9/78 3'1"1
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Type and Mode of Test Employed
The type of inspection may be an emissions-only inspection or an
emissions and safety inspection (costs associated with incremental
programs, emissions add-on to safety, are discussed in another section).
The test mode employed may be idle or loaded. Both test type and mode
affect I/M program characteritics, particularly the vehicle processing
or through-put rate and hence the number & size of stations and the
attendant staff required.(7).
If either an idle or loaded mode exhaust emissions test is adopted the
State should consider the trade-offs between equipment cost and extensiveness
of emission information.(8) The loaded mode test employs the use of a
chasis dynamometer and usually more expensive computer processing
equipment in order to obtain vehicle emission readings more reflective
of actual urban driving conditions.(9) While the information gained
is more complete, equipment costs are greater than with the idle mode.
These costs may be offset over time because the degree of automation
employed reduces the total number of inspection personnel that might
be required for the manual inspection procedure. The idle test mode,
at the minimum, requires minimal hardware (probe, analyzer, etc.)
and personnel necessary to take readings and process vehicles.
The idle mode does not preclude the use of more sophisticated data
handling equipment, however. The loaded mode necessitates permanent
facility construction or modification (except where used with a mobile
van and trailer) and would virtually eliminate the possibility of use in
a private, decentralized system.
9/78 3-1'15
-------
The State may also wish to consider employing test alternatives
other than idle or loaded mode exhaust emission testing, such as
parameter inspection and mandatory maintenance. Completed studies
have suggested, however, that such alternatives are not as cost-effective
as exhaust emission tests. For example, Olson Laboratories in 1976(10)
produced a study which indicated that while parameter inspection and
mandatory maintenance have the potential to provide for substantial
emission reductions, they generally cost significantly more than an
idle test. With the exception of the type and cost of equipment
utilized, the State can expect to incur approximately the same types of
expenditures as with exhaust emission inspection alternatives. Generally
inspection times are significantly greater, thereby affecting vehicle
capacity and system configuration. Surveillance, certification, and
training requirements may also be more costly depending on the number
and type of adjustments involved.
The Effect of Geographic Location
Evidence from existing I/M programs generally confirms that program
location affects both I/M capital and annual costs. For instance, costs
for labor, land, building and construction, and equipment all can be greater
in the northeastern United States than in the western and southern
portions. Salaries, fringe benefits & inspection site land values are all
subject to regional price variation. Table (3), for example, notes the variation
in land and inspector cost requirements for various existing and proposed I/M
programs.
9/78 3.1-16
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Table 3
oo
Location
Denver
Portland
Cincinnati
St. Louis
Chicago
New Jersey
California
PRICE VARIATION IN LAND
ACQUISITION COSTS AND INSPECTOR
SALARIES FOR SELECTED I/M
PROGRAMS AND STUDIES
Year Cost per sq. ft.
1974-75 $2-3
1975 $2.75
1976 $.92
1976 $1-30.00
1974 $4
1975 $1-9.00
1977 N/A
Annual Inspector Wage Rates ($)
9500
10,944(a)
9,893
i;ooo
NA
H233
13488(b)
(a) 1978
(b) See reference
Source: See references 3, 4, 10, 20 & 22
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II L. CATEGORIES OF I/M COSTS
As noted earlier there two major areas of costs associated with initiation
of implementation of an I/M program - capital and annual (recurring)
expenditures. Capital investments can include the purchase of land,
buildings and test hardware. Also possibly included are construction and
installation costs & initial program start-up costs including the admini-
strative expenses of detailed program design and evaluation, inspector and
supervisor training, public relations and education, laboratory testing
for standard documentation and where applicable, mechanics training.
Annual costs generally include: building and site rentals or leases;
personnel salaries and fringe benefits; daily operating expenses, overhead,
equipment amortization and replacement; and the on-going aspects of public
education, staff training, enforcement and program monitoring and evaluation.
However the primary component of annual or recurring costs is the cost of
labor. (11) Table (4) summarizes the various effects on annual and capital
costs by the variables of organizational structure, test type and mode and
program location noted earlier. Table (5) provides a more detailed delineation
of responsibility of program components costs accordingto organizational structure,
IV. SAMPLE COST DETERMINATION PROCEDURES AND CONSIDERATIONS
In this section, simplified cost analysis procedures are provided so that
the prospective program manager, given area-specific data, can preliminarily
assess costs of alternative I/M systems. Several important points to
9/78
-------
consider throughout the analysis of costs are the unique characteristics of
the area, its existing resources, and the necessity of public acceptance.
Included in Section 3.2 is a sample worksheet illustrating application of
the cost process.
9/78
-------
Table (4) - FACTORS INFLUENCING I/M COSTS
CO
ORGANIZATIONAL
TEST TYPE
AND MODE
CAPITAL
COSTS
- Org. Structure determines
how distributed and to who
- Building costs generally
greatest though land costs
can vary
- In centralized system there
are heavy site, facility &
equipment costs; contractor
bears this expense in franchise
system; private garage needs
equipment only but greater #
of analyzers evens aggregate
costs out
Failure & thruput rates are
affected; combined safety &
emissions test takes longer and
consequently a greater lane
capacity is needed
Centralized systems have
larger facilities; decen-
tralized systems have more
inspection sites w/greater
equipment needs
ANNUAL
COSTS
In public centralized
system, State pays for both
inspection personnel and
administration; in
contractor system, adminis-
stration expands to include
monitoring of contract,and
inspection personnel costs
are greatly reduced if not
eliminated; decentralized
systems necessitate a
significant state monitor-
ing and enforcement effort
along with basic program
administration
Public, centralized system may have to
pay long terra fixed obli-
gations to employees
whereas contractor does
not
Because failure & thruput
rates are affected, number
of required inspectors
is greater w/ combined
safety/emissions program
where inspection time &
failure rate are greater
-------
Table 4 (continued)
\o
"».
00
PROGRAM
LOCATION
Loaded mode requires more
equipment, costs more and takes
longer; building costs greater;
private garage generally precludes
use of loaded mode
Considerable variation in
land & construction costs
Interregional & intertnetro-
politan price variation
Station location costs depend
upon density, transportation
system and demographic charac-
teristics of the area
- Gross salary & fringe
benefits affected
- Higher wage rates in
denser northeast &
north central regions
Source: From Reference 3.
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State-Operated, Centralized System Costs
The first procedure listed pertains to initial capital investment costs for
a state owned and operated I/M program. Some of the steps will be duplicated
for the cost analysis of other systems. The procedure is as follows:
(1) estimate applicable affected vehicle population accounting for
the geographic area covered and according to vehicle types
tested (weight range, model year, etc.) - obtain data from
motor vehicle department records, census data, survey information
and transportation planning data;
(2) locate existing and projected vehicle population according to
planning zone, etc. determining the relative population and
vehicle densities or concentrations;
(3) determine the number of vehicle inspections per year to be
performed by taking figure derived in Step 1 plus the failure
rate (10, 20 or 30% etc) times that figure (i.e. initial
tests plus necessary retests);
(4) determine the vehicle throughput or processing rate - account
for inspection test mode time, hours of facility operation,
actual days of operation, operating efficiency (installed
vehicles, inclement weather, inspector fatigue, unforeseen
delays, etc.);(12)
(5) determine the total number of lanes required by dividing the
total number of inspections by the lane throughput capacity;
9/78 3.1-21
-------
(6) accounting for vehicle density, vehicle growth, locational
criteria (environmental compatiblity, travel time, proximity,
land availability) allocate lanes (and stations) to appropriate
sub-areas;
(7) determine site location requirements and acquisition costs-account
for land values; account for necessary acreage (capacity) needs
according to number of lanes and station design (as influenced by
test mode); account for expected facility expansion over time (if
applicable) from growth found in Step 1; illustrates costs per
square foot and per acre; research real estate values; compare cost
rental or lease agreements to cost of ownership over time;(13)
(8) determine site preparation costs-account for landscaping, soil
conditions, necessary street imporvements, sewer and water costs,
electricity costs, other improvements including paving sidewalks,
curbs, parking, signs etc; determine basic single lane costs and
then modify for multiple lanes needed and hence station costs
(account for economies scale or size);
(9) determine facility construction costs-account for station design
and capacity (architectural & engineering fees); account for
projected expansion due to change in test mode if necessary; account
for support function costs (lab, office, storage); account for
structural costs (including construction labor) on a per lane
basis;(14)
(10) determine total equipment costs including test equipment, station
support equipment and general office equipment (include analyzers
and where applicable dynamometer, air compression equipment, fans,
tools, contingencies, computer record and read-out hardware, etc.);
account for replacement and maintenance;(15)
9/78 3.1-22
-------
(11) sum site acquisition, preparation, facility construction and
overall equipment costs;
(12) determine initial program design, testing and evaluation
costs-account for program planning, engineering and design
fees, research and development;
(13) determine the level of effort and associated costs required for
public information and education (including media spots,
printing, free program tests, seminars, etc);
(14) determine administrative start-up costs including initial
employee training for management, inspection and enforcement
functions;
(15) total 11 through 14 for total initial capital investment;
captial costs may be amortized generally over a 5 or 10
year time span give the life of the program and interest
rate.
9/78
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-J
00
Table (5) Summary of Cost Categories and Components Associated with I/M
Implementation Costs to the State Under Various Systems
Cost Category
Capital Costs
Public
Centralized
System Type
Private
Contractor
Decentralized
Private Garage
Site Acquisition
Site Preparation
Facility Construction
Equipment Costs
Administrative Start-Up
-Program Design, Testing &
Evaluation
-Public Information & Advert
ising
-Programming & Computerization
Training, Supervision & Enforce-
ment
Mechanics
x
x
X
;x
+ ,x
N/A
N/A
0 facility
modification
(All*)
station
Inspector training
Lane inspectors
training
Rest is state super-
vision & enforcement
i
N»
•e*
-------
VP
00
Annual Costs
Amortized (Capital Costs
General Station Operating
Expenses
Salaries & Fringe Benefits
Replacement Costs & Contingencies
Recurring Costs
-Program Evaluation
-Inspector Training
-Public Education
-Mechanics Training
Responsibility
State
Contractor x
+
+
+
+
+
*
+adm., x oper.
x
+adm., x oper.
(see above)
+ ,x
*
+adm., 0 oper.
0
+adm., x
+0
Private Garage 0
$OTE - N/A = Not applicable
- Mechanics training programs can be developed by the State through
community college courses or special programs or may be taken by
mechanics through the service industry.
-------
Analysis of annual costs for State-operated centralized facilities
should:
(1) determine general station operating costs-account for
utilities, office equipment and supplies, cleaning and
refuse service, phone service, etc.;
(2) determine administrative field and inspection station
personnel salary, fringe benefit and pension require-
ments - account for operating personnel per station and
needed overtime; include base wage plus cost of living
& merit increases and fringe benefits; account for
administrative, surveillance and repair facility
contact personnel; account for data processing
personnel, etc.; account for on-going program evaluation
costs;
(3) account for equipment depreciation, replacement and
amortization of capital costs over time.
9/78 3-1-26
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Thus in figuring a total outlay for a State-run centralized sysytem
for a single jurisdiction:
(1) amortized costs - capital costs x financed period x interest
rate;
(2) yearly program costs - amortized costs + operating expenses;
and
(3) cost per vehicle (owner) per year (i.e. inspection fee) *
yearly program costs divided by total number of applicable
affected vehicles (assuming retests are free).
All of the above computations must account for the effects of
inflation and other cost escalation considerations. Rates
will vary among cost sectors and geographic location (land
values, equipment costs and personnel salaries are particularly
affected). While each State should determine what adjustments
are necessary for its particular situation, several (states have
been employing annual inflation factors from 5 to 102.(16)
Contractor-Operated, State Administered, Centralized System Costs
With a private centralized system the cost analysis procedure is
«uch the same as with the public, centralized system. While the
ultimate fee to the consumer can be calculated by the relatively
same process, the costs to the States would be distributed differently
i/78
3.1-27
-------
among program components. The contractor would absorb the bulk of
capital expenditures and recurring labor costs. The State's
expense would rest primarily in administrative areas — auditing,
surveillance, program evaluation and consumer protection. Under a
private, centralized system the State would invite competitive bids
from various contractors. Based upon program conditions (stringency
of the standards, affected vehicles, test mode) outlined by the State,
the most qualified proposal would be selected. The State could determine,
on the basis of the contractor proposal:
(1) the level of management (administrative and clerical)
and program evaluation staff required, including the
personnel needed to ensure proper implementation of the
contract;
(2) the number of State inspectors required to monitor the
stations called for by the contractor (and the station
equipment);
(3) the number of State inspectors required to handle
complaints; and
(4) the need for any additional quality control or consumer
protection measures.
The same cost analysis procedure used for determining state, centralized
system expenses can be employed to check the cost proposals of various
contractor submissions.
9/78 3.1-28
-------
The contractor and State would negotiate a detailed agreement
outlining the specific responsibilities and expectations of each
party and detailing, according to vehicle population and changes
in various cost components over time, the scale of fees to be
charged and the respective portions due to the State and contractor.
The number of oversight State personnel to ensure proper implemen-
tation of the contract is probably the most important administra-
tive consideration for the State.
In some instances involving large vehicle populations the private
contractor approach has shown that the I/M program can be mobilized
•ore quickly at a per vehicle cost equal to or less than that of the
public, centralized approach and much less than that of the private
Decentralized approach.(17) This is because the contractor can move
•ore rapidly in site acquisition and facility construction and has more
flexibility in the use of its employees. The contractor is bound by
the negotiated agreement to certain dollar levels and time periods.
This assures the State a relatively stable I/M program. Unfortunately
should the State renign on a negotiated agreement with the contractor,
the State may be liable to reimburse the contractor for all his
expenditures to date.(18)
9/78 3.1-29
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Private Garage, Decentralized Facilities
Many of the considerations in the costing analysis for public, centralized
systems are inherent to the analysis of decentralized systems, as well.
The State must determine the total number of affected vehicles and inspections
expected. The initial difficulty with garage-based I/M programs is the
uncertainty concerning the number and location of participating garages
relative to the vehicle population. The number of private service stations
and garages licensed to perform vehicle inspection affects the amount of
time each station must spend on inspection. This in turn affects vehicle
processing rates and inspection fee levels. In any regard more than a
sufficient number of garages can be expected to participate.(19)
Once the number of participating stations is gauged (most likely through
survey or polling) the State would be able to determine:
(1) the administrative costs of certification, surveillance and
enforcement;
(2) the State inspector requirements - in consideration of total
inspection time and workload, travel time, number of certified
facilities and frequency of inspection;
(3) the State inspector costs - number of inspectors required,
salaries and fringe benefits over time, training costs;
(4) the costs associated with program evaluation, processing of
data, and public relations and education; and
(5) the cost of instituting a State challenge lane facility for
consumer protection.
9/78 3.1-30
-------
With a private, garage-based decentralized system large capital
expenditures for land and buildings are not required. The participating
service stations need only purchase emissions testing equipment and
have their mechanics undergo the appropriate training to be certified for
emissions testing and repair. The State, while relieved of the costs
of site acquisition, construction and maintenance, except possibly for
state challenge land facilities) may experience greater overall adminis-
tration costs under this system primarily due to the increase in
surveillance and auditing requirements. The cost of the inspection to
the consumer may be greater than in a centralized system due to the
significantly higher hourly wage rates of garage mechanics and the longer
amount of time required to perform the inspection.(20) However, the
relative inspection fees for decentralized versus centralized systems
depend on many factors, and local comparison of various program options
is advisable.
9/78
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V. COSTS AND CONSIDERATIONS OF INSPECTOR AND MECHANICS TRAINING
A key component in the degree of public acceptability of an I/M
program is the quality & reliability of work provided by the automobile
repair industry. In order for the program to be successful it is
imperative that any inspectors of the administering jurisdiction as
well as mechanics conducting testing or vehicle repair work be properly
knowledgeable.
The emissions inspector must have first hand knowledge of the test
procedures, operation and care of inspection instrumentation, and engine
components which contribute to excess HC, CO and NO emissions. Mechanics
need to understand the function and maintenance of emission control devices,
which engine parameters affect emissions, and how to properly tune vehicles
to minimize emissions while optimizing performance and fuel economy.
EPA-sponsored training programs conducted by Colorado State University
(CSU) are intended to address these training needs. Vocational-educational
schools and community colleges across the United States have adopted the EPA-CSU
courses. By placing these courses within the framework of the local
eductional system, this knowledge becomes readily available at a reasonable
cost. The State is not the only source for mechanics training programs,
9/78 3.1-32
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of course. Various sectors of industry - motor vehicle manufacturers,
petroleum companies and emission analyzer firms - also offer courses
to train mechanics for competency in dealing with emission control
and instrumentation.
Estimates of the costs of training mechanics and emissions inspectors
vary.(21) Table (6) lists the most recent and reliable cost approximations
for the various training categories as provided by CSU. Mechanics training
refers to training of mechanics for necessary diagnosis and repair. Referee
lane training is the most comprehensive approach involving the understanding
of all aspects of program operations, test procedures, diagnosis and repair.
Investigator training refers to training of the inspectors of inspection
stations. It also is more comprehensive than general inspector training
jihich is essentially geared towards operation of the idle test process-vehicle
preparation, probe insert, instrument reading, vehicle processing, etc.
9/78 3'1-33
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Table 6
00
Training
Type
Mechanics
Training
Referee
Lane
Training
Investigator
Training
Inspector
Training
(Idle Mode)
Costs
Direction of
Instruction
16-20 hrs.
50 hrs.
40 hrs.
approx.
8 hrs.
of Inspector and Mechanics
Class Number of
Size Instructors
16-18 2
25 2
N/A 2
30 1-2
Training
Salaries
Overhead
Direct Cost
$
125,000
15,600
N/A
N/A
Numbe r
of Persons
Trained
1050
25
N/A
N/A
Cost per
Person
Trained ($)
120
675
570
70-95
Source: Information supplied by Marion Maness, Colorado State University, August 1978.
-------
VI. INSPECTION AND MAINTENANCE ENFORCEMENT AND SURVEILLANCE COSTS
Enforcement of an I/M program will necessarily involve the ensuring
vehicle owner compliance with inspection requirements. In a number of
previous I/M studies, cost analyses failed to account for enforcement
costs.(22) There are generally two mechanisms employed to enforce the
program: (a) Withhold registration based upon test records and follow-
up by law enforcement officials and; (b) withhold an inspection sticker
which must be displayed for vehicle operation on public roads. Citations
could then be issued to those without licensed plates or a valid inspection
sticker. Citations may also be issued during random roadside checks
by law enforcement or program officials. Estimates of enforcement
costs have generally found them to be no more than 1% of the total
annual program costs for a State operated program.(23) Enforcement
costs can be expected to be higher for programs that involve vehicles
from neighboring jurisdictions. Where I/M authority rests with a
city or county alone, enforcement of vehicles registered outside its
boundaries can be effective only with close interjurisdictional
cooperation.
Surveillance costs for the monitoring and certification of
private garages, generally translate into personnel (investigator)
and administrative (record-keeping) costs. Inspectors must
ensure that emission analyzers are in proper calibration and that
the licensed stations are following all rules and proper procedures.
When assessing surveillance costs the State should consider:
(1) costs of investigator or inspector training;
(2) their salaries and fringe benefits;
9/78 .
-------
(3) their daily expenses, travel, mileage, etc.;
(4) their inspection rate (in stations-per-lnspector-per-month)
and the number of private garages to inspect (thus the
total need for inspectors can be determined); and
(5) the salaries and benefits of personnel needed to process
private garage data and maintain records plus any
associated software, hardware and-equipment costs.
(key punch, computer, survey forms, etc.)
One example of the number of personnel needed to monitor a program is
the State of Rhode Island which maintains a force of 30 inspectors
for about 700 licensed stations and 500,000 vehicles for both safety
and emissions.(24)
Surveillance costs can be recouped of course by charging the private
garages a certification fee. The private garages generally pass this cost
along to the vehicle owner. Thus by requiring more extensive administrative
demands on the State, the costs of private garage certification may tend to
raise the inspection fee.(25)
9/78 3.1-36
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VII. PUBLIC AWARENESS AND EDUCATION
The important consideration in this area is not the total number
of dollars expended but the quality of public relations effort produced.
Generally a prerequisite condition to the initiation of a full-scale
public relations effort is the choice of the I/M system and test mode.
Indications of the public acceptability and the practicality of various
I/M alternatives can be gained from a demonstration effort. The timing
of public information efforts is important as well. While there should
be an initial push for I/M, public relations expenditures should be
continuous throughout the life of the program.
The following materials and strategies have been utilized for I/M
outreach:
(1) information pamphlets, press releases, and newspaper ads and
articles;
(2) radio and TV spots including public service announcements;
(3) bumper stickers, educational posters and displays;
(4) audiovisual presentations including slide shows;
(5) free auto-care clinics with mobile testing facilities and;
(6) soliciting media involvement, obtaining speakers, organizing
information efforts and subcontracting to public interest
groups to conduct programs to inform various organizations.
9/78 3'1-37
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VIII. INCREMENTAL EMISSIONS TESTING PROGRAM (SAFETY INSPECTION ADD-ON)
Many States have existing forms of vehicle safety inspection programs
already in place. Twenty-four states use service stations o garages
licensed by the State for inspection while three states and the District
of Columbia have centralized public programs. Because of the widespread
existence of safety inspection programs, the combination of safety and
and emissions testing frequently must be considered.
The type and mode of emissions test must interface compatibly with
the existing safety inspection program. For example if a loaded-mode
emission test is desired for a private garage-based safety program then
those stations would be faced with having to tie up their service bays
and install dynamometers at a significant cost outlay to them should
they decide to participate. For this reason it is generally impractical
to initiate a private garage system with loaded testing. It is much
more likely that some form of a centralized system could reasonably
achieve this.
9/78
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Idle emission tests are therefore easier to add to existing safety
programs. State of New Jersey has successfully instituted an idle
emissions test at its centralized safety inspection facilities while
avoiding possible disruptive effects on the program. The New Jersey
inspection program began in 1938 with safety inspections and now includes
emissions testing, registration and license check and insurance certi-
fication. (26) The City of Cincinnati has also demonstrated the viability
of adding an idle test to a safety system.
A second consideration is that a test for emissions and safety
typically fails a higher percentage of all vehicles inspected and takes
more time on average than does an emissions only test. As a result a
combined emissions and safety inspection program requires greater lane
capacity than an emissions only test, given the same vehicle population.
For centralized systems this may either mean a greater number of facilities
are required or a more intensive use of existing facilities. For example,
New Jersey found it necessary to expand its program to include emission
retests at certified garages. The State estimates that initially,
$1.25 million in costs were added to its safety program.(27)
However, in terms of convenience to the state adding emissions testing
to an existing safety program generally is rather straightforward. An
administrative and surveillance network has already been established.
States investigating incremental approaches should most importantly consider
consumer convenience, consumer acceptability and administrative & operational
|ef ficiency.
9/78 3'1-39
-------
IX. INTRODUCTORY OR DEMONSTRATION I/M PROGRAMS - COST AND CONSIDERATIONS
Instituting an introductory or pilot form of I/M provides a logical
transition to the implementation of a full-scale program. Operating
an introductory I/M program can enable a jurisdiction to:
(1) promote public awareness and acceptance - by explaining the
rationale and benefits of I/M and assuring the provision of
adequate consumer protection;
(2) gain useful information on the vehicle population - emission
levels, recommended stringency factor, repair rates and
ceilings, etc.;
(3) become more adept at program management, technical training
and the handling of technical issues; and
(4) develop the appropriate cutpoints or standards for the
program.(28)
Costs for an introductory program are actually dependent upon how
sophisticated or extensive a State wishes it to be or what a State
can reasonably afford. The format can be based on what program aspects
a State would like to investigate or document (e.g., - relative
advantages of idle versus loaded mode; model line - specific cutpoints
etc.) or the State may wish to institute a dry-run of a scaled-down
version of its eventual full-scale I/M program.
9/78 3.1-40
-------
Introductory approaches can include but are certainly not limited
to the use of mobile vans or a centralized test facility for voluntary
vehicle testing. They may also involve for example: voluntary testing,
the inspection of vehicles at time of a change of ownership; or mandatory
inspection with voluntary maintenance for all light duty vehicles.(29)
Below are several brief summaries of approaches to introductory I/M programs.
(1) Well-publicized demonstration lanes can acquaint many
people, either in person or by mass media, to I/M. Free
tests can be provided with explanations of the need and
benefits of vehicle I/M.
(2) Mobile vans can be employed in a continuing introductory
program to avoid the higher costs of permanent facilities.
Several sources have placed the cost of single unit,
fully-equipped with loaded mode test capability, at $30,000
to $50,000 (manpower not included).(30) Mobile vans were
employed by the State of Oregon as part of their initial I/M
efforts.
(3) The State of California will begin operation of mandatory
I/M for vehicles requiring registration changes in March
1979 within the South Coast Air Basin. The program will
be operated by a private contractor. Over 1.7 million idle
mode inspections are anticipated to be performed at
centralized facilities. This program supersedes California's
earlier use of its permanent Riverside test facility which
tested 120,000 light duty vehicles under a mandatory inspection
and voluntary maintenance format. Original capital costs for
the Riverside facility totaled $250,000.(31)
9/78
3.1-41
-------
X. FINANCING THE SYSTEM; COSTS TO THE CONSUMER
The three major cost categories of inspection/maintenance programs-capital,
annual,and repair costs - each have different means of financing. The
financing methods for the first two categories vary according to a program's
organizational structure.
Costs associated with capital investment have been financed, in centralized
public systems, through the current budget of the affected jurisdiction.
The funds needed to establish the I/M program have either been appropriated
directly to the vehicle inspection program or the program has borrowed
money from another state agency.(32) These funds may possibly be recouped
by inspection fees. Limited experience with centralized contractor systems
seems to indicate that such arrangements have a capacity to use the
corporate tax structure to cover capital expenditures over time. Such
an arrangement effectively shifts the burden of financing the capital
investment for I/M from the State to the Federal government. There is insuffi-
cient data available on capital financing mechanisms for private decentralized
systems. However, assuming that the capacity to write-off capital expendi-
tures is a function of the type of ownership, private decentralized systems
would share the same financing advantages as centralized, contractor systems.
Like capital costs, annual costs in both public and private centralized
systems can also be financed from the current State budget.(33) I/M is
generally a self-supporting program, however, since the revenues generated
usually cover operating expenses and generalized capital costs.
9/78
3.1-42
-------
Ultimately, virtually all costs are born by the consumer, whichever I/M
program option is chosen. I/M costs to the consumer are comprised of
of the inspection fee and the I/M - related maintenance and repair costs
(when necessary). Some states have minimized consumer costs with vehicle
repair cost ceilings and exemptions. (34) r^e Inspection fee is generally
designed to cover the program's capital and annual costs.
Several states with existing I/M programs have found that an inspection
fee of $5.00 is adequate to cover program costs (See Table 1).
Studies for other States have projected comparable inspection fees.(36)
Fees have ranged from $2.50 in New Jersey (with both safety and emissions)
to $14.00 in California*(for the change-of-ownership program).
The overall fee should generally not be significantly more than that
needed to sustain a self-supporting operation. The exception is in the
case of a contractor-operated I/M program where a reasonable profit is
included for the incentive of the contractor.
Recent information from existing I/M programs on repair costs indicates
a range of average costs for failed vehicles of $16 to 32. Table (7)
provides a more detailed percentage distribution of costs according
to general cost categories.
* This fee covers ongoing reimbursements >:o the Motor Vehicle Account
of the California Transportation Tax Fund. A substantial loan from
the Account supported the Riverside pilot program.
9/78
-------
Table 7
vO
-J
00
I/M Repair Costs
New Jersey
Less than $10
$10 - $25
$25 - $50
$50 - $100
Over $100
29.1%
26.4%
22.11
16.1%
5.6%
N - 16,000 „
Average repair costs * $32.40
Median - 50% of repair cost
less than $20
65% of repairs cost less than
the average
No Cost
$0 - $10
$10 - $30
$30 - $50
$50 - $75
Over $100
27%
37%
18%
8%
5%
2%
N - 1400 (primarily newer cars)
Average repair costs * $16.00
Median - 50% of repairs
cost less than $8
71% of repairs cost less than
the average
to
Arizona
Less than $5 27%
$5 - $10 17%
$10 - $25 24%
$25 - $50 20%
$50 - $100 10%
Over $100 2%
N - 2000
Average repair cost * $23.40
Median - 50% of repairs cost less
than $15
64% of repairs cost less than average
-------
00
Table 7 (continued)
Failure Rates - New Jersey
Arizona
Oregon
-12% (annual)
- 16% (annual)
- 36% (annual)
Source: See Reference 24
New Jersey's average costs dropped to $15.86 in 1977.(36)
i
*•
Ul
-------
XI. SUMMARY
This section has reviewed various cost components that affect
the overall costs of an I/M program. The main focus was on the
costs to the state or other administering jurisdiction. It must be
emphasized however that local factors individual to each area have a
very strong influence on how much an I/M program will cost. While
the figures presented here should give some sense of the magnitudes
of the costs involved, a cost analysis should be performed for any
new I/M program.
9/78 3.1-46
-------
APPENDIX
Tables of Selected I/M
Program Cost Estimates
(Reference 3)
9/78 3'1-47
-------
CHART A
CAPITAL COBTO FOH EX10T1HO
00
location
New Jcrooy
Cincinnati
ami
Ho r wood,
Ohio
Chicago
Por tl nnd,
Orogon
Rlvorolilo,
California
Moticopn
an') Plma
Count loo,
Arizona
Otgonlialional
Structure
etnle Ownod
and
Ojjorotcd
City Owned
and
Operated
City Ownod
and
Operated
Gtato Owned
and
Operated
Gtnte Ownod
and
Operated
Frnnchlao
Tont TV1>«
Snfoty ond
tnilaalono
Safety ond
Dnloolono
Dnlofllona
nnloolono
Onloolona
Qnlsalone
Toot Modo
Idlo
Idla
Idlo
Idla
lx>adoJ
I^iadad
ini jrtiiant
250,000
600, (
!,»»<. "0°
203,000
500,000
3,000,000
hul Idlncji)
25,500,000°
100"
160, ooo r
107, 7D01'
l.itml
4,noo,oo
200,000-
400,000
400,000
74,000r
t,o,l nod
3,600,000
,400,000
Tulnl
5l2,9'iO,00()
405,00d/
la no
000,000-
l,-0«)0,0()()
200, OOO/
) nnil
J, 11-10, 1)00
2 13,. )()(>/
lunf.
1,200, 500
U0(oofi/
1 ano
i , i'jo,nc>n
220,0007
la no
9,132,000
24 7, OOO/
1 ano
a. EntImated noplncemcnt Vnluo
b. 1 (icnnant building and alx rriohlla vano
c. Eo11mated Valuo - Actually loaacd for $l/yr. from OtnLo Highway D9j>artmont
d. Includua 10 montho oporatlon coat* for pilot program
o. To data
f. Include* coat of 12 vans
g. Rough estimate of value - land provlotioly ownod by city no ocutal oxpondllure ~ $0.
4>
00
-------
B
nccunnina cosTsron EXIBTIIM
Organizational
location Structure Teat Tvt»e Toot Mode fl l.nnee Admlnlotrntlon Inupoctjon Ollior Total
How Joraoy
Cincinnati,
Ohio
Chicago
Portland
Motropol Itan
Service
District,
Oregon
nlverolde,
California
Maricopa
and ('jma
Counties,
Arizona
Statn Owned
and Operated
City Ownud
and Operated
City Owned
and Operated
State Owned
and Operated
State Owned
and Operated
Franchise
Dnlaaiono
and Safety
Dnlaalona
and Safety
bnlaalona
nnlanloria
Bniaaiona
Dniooiono
Idle
Idle
Idle
Idle
Loaded
I/eailod
60
4
10
15
6
37
Oroflfl flalaryi
$426,000
Fr Ingot
106, 500
OrooB Oalaryi
491^76
Frlngoi '
1,072,941 .
PfOi 300)000
305,000*
Ud,224ft
Oronn fiolnryi
126,000
Frlnyoi
21,042
Orooo Galaryi
169,344
Frlngoi
27,942
350,oooirrsn
J30,OOtMrl7..
•»""'
Oioon flnlaryi
703,500
Fr Ingci
117,405
Qrooo Oalaryi
336,000
Kringoi
50,073
3,700,000*
I.O.1 no i
200,000
Overhead,
Onppl Inn i
050,000
Non-
re riionnoli
50 4 000
Tif-ccIflTT "
100,000
"Oaoda fttiJ
Bet vlcon"
600,000
01,600
I.cnnci
255,j160___
K'jul |xncnt
jOlLllllS.
Puhllc
260,000
11,236,617
lC5,240/lano
535,000
133,7'JO/lono
1,579,40(1
07,750/lono
1,049,600
70,000/lnno
16 1! 390/1 one
4,630,000
125,.'.35/l«'>ne
Ul
-*J
SJ
a. Including frlngo , . .
b. Incliidca oon.o umioual expcnoeo, e.g., pliotograplilc c L>o
inoi.ected, lliero are 27 inopcctlon staff i Oroaw aalary $272,404/ycar; frlmjoi $45,505/yc«r
«1. Pro » Premium Portion of Ovortimoi like frlngo bonoflto, thlo la not accounted to cither tho DEP or DMV l>udgct, hut in pnld
directly out of the Mow Jerooy State Troaaury.
-------
vO
00
CHART C
CAriTAI, COST r.3Tl>1ATE8 FOR rUBUCLT.
------ ---.--r- -, -,---,-r- - „- , -.,,-,- - f ! Tl" " lOlAT
DATA SOURCE 0 1.
F.rA. OTMIf
USED
El' A, Otl.lll'
IIS Ell
ItATIKLLE, TCP
5/75
DA1TEI.I.E, TCP
'CONTROL STRATEGICS
FOR III 1ISF.
VEHICLES." '74
'(X)UTH(II. STRATEGIES
FOR IN USE
VEHICLES." '7/l
OLSON, SCAB,
VEI STUDY 5/75
{JEW tlfR.lt, | 7 3
NKM'fiinRf '^H*1
DENVER TRWL*7«
UF.NVr.n. TRW,'7<
MtS TF.5T IKWl
2 IDLE
2 im.n
2 LOADED
2 IDLE
2 LOADED
2 LoAllED
T LOADED
2 LOADED
2 IDLE
2 LOADED
MltUNIRinATION
$5,000
J.Obii
3,000
3,000
7.039
7.000
9,400
~177flfio
16,070
2 ',,2 70
2ft, 720
99, 51)0" •"
4|,i23
17,194
33.529
nil I LH 1 IH,7 COMB 1 RUC II Ujt
f 0,000
' " " 60, 000
35,000 '
35,000
iJini'
14,000-140,000
147Dno-i'in,n(io
14,000-140,000
07,500
90, $66
MEHl lUtflOO_
fiEUAJil^ i 2 tOOO
SHU
9^.500
f 11. 000
130.592
125.996
30. 323
29,971
4,900-7,000
«,r.on-'io;noo
All 1 (MAT 1 01! 1
14,050
4,090-7,000
AllfOMATIOIIt
_|4,n50
4j 500- JO. BOO
$93, 300-221, '• 00
07,010-21 fi, 770
270, lOO
129.J70
132.M
118.794
«/ IHCI.IIHF.S HO, ANALYZERS
I,"/ AOTOHATED
c/ nin.iiMF.s rERRoimei. TRAINING
J/ 8AFF.TT AND EMISSIONS INSPECTION
-------
O CHART D
CAPlTAt COST ESTIMATES fOR riUYATB nAKACK BTSTniS
CO
s~\
v/l
DATA .SOURCE
1 or i.Dv's
AlitUNISTRATlON
nun.oiHcs Aim i.Aim
«/ AvrRAcr I i.i)Vs inr.PEcrri»/STATjoN/m - 1,000 (ESTIMATE immvro mon HAHIAM AMD ncnvER STUDIES)
I STATIONS Nr.F.DF.I) FOR 1 HIU.10H 1.0V'8 " 1,000
r.l)Ull'MF.NT COST/STATION - 91,200
TOTE
EPA - OTI.UP 1/76
DATTF.U.E, TCP
TEXAS, P. ADI AH
6/75
r>ENVC!>., 1BW. 1974
1,000,000
2,000
(2 I.AHFr,)
3,*00,000
0,302 STATIONS )
696.000
( t.00 STATIONS )
$25,000
J.OOO
J91.0UO
$22,000
2,700,000
17,870
6,761,000
7,0*0,000
$2,225,000
20,870
7,155,000
2,662,000
NOTt. ALL STUDIES ASSUME AH IDLE HOUR TEST
-------
CHART E
MfURRIHC COST ESTIMATES fOH fUBLlCLY OWNED MID DERATED 8TSTEJIS
3
DATA SOMCE
WA, OTUlf
M»F.D
BArtEI.I.E, TCf
J/7J
"CONTROL STRATEGIES
FOR IN-Ur.B
vMiin.r.s," 5/75
OLSON, SCAI vet
MUWT 5//S
NEW TORK 74
tir.W TORK Md
PEHVER, TRW
'7*
HP.NVKR. TRW
74
1 LAliEJ
2
I
2
2
2
2
<2
60
TEST HOOE
IDLI AND
LOADED
IDLE AND
IX)ADEO
IDLE AND
LOAMD
LOADKO
LOADED
LOADED
IDLE
LOADED
AmiiriitTRATibii
1 33,060
11,060
1 IristECTloM
14,000
64,000
*
102.600
b
78,650
726,000
600,000
776,000
1.178,000
1,428,000
liirRtes
1,940
1,9*0
c
26,900
e
50,000
c
120,000
OTHER
"01 MM TIlAH
PERSONNEL"
19,312
"OTIir.R THAN
PERSONNEL"
34,024
tN^uftdttlKHfi '
5'iB.OOO
DATA COLLECT ION I
1»,000_
EHronCKHENTl
600.000
DATA COLLECTION t
224.000
TOTAL
(100,000
J 00, 000
100,000
129.500
94,162
2fi 1,624
2.600,000
0),«00/2 LANES
1,14ft, 000
92,600/2 LAKES
Of HH.'l.tlllKS 20 *
b/ UICI.IIDES 30 y. MINOS
C/ INCLUDES GOUirMCMT MAINTENANCE
d/ EHIGS10H9 ANn SAFETT
I
01
-------
CHART F
BECURRiHO COST ESTIHATEB KM PRIVATE CARACE StSTEHfl
"*J —.--.....—,— • •••••-.- ' •' -r: .::..! ---.-.-;. ' l'u,i,rr,*i,ta ' "" riirom-ftirur nATA fdl I.Ki:TI(lN OtIIRR TOTAl
00 l)ATA SUURU
^ EfA - OTI.IIP
•vl HSfU
BATTKUE, 1CP
5/75
KAOIAH, TliXAS
6/75
DENVF.R, TRU
74
F STATIOMS
1.000
2 LANES
J.3B2
600
flDHiniSIHAIIUM
50.000
33,Of.O
179,700s
1 BO ,000
2,000,000
H.M
1,708,000
2. BOO, OHO
n
150.000
660,000
.190,100
224.000
surn.ifcsi
2,940
1.818,900
(IVF.RIIF.AUl
550.000
2,200,000
100,000
4,164,700
4,422,000
~ COSTS BDRN BY BTATBj Al.t OTIIKK COSTS BORH Bl rWATB CAMGES TART1C1PAT1HO IN TUB INSPECTION.
I
Ul
-------
Technical Notes
1) A large state such as California would require a substantial staff
effort. A comparison of contractor versus State annual labor costs
for California's change of ownership I/M program indicated figures of
$3,243,000 (1979) versus $8,836,665 (1978) respectively (references
9 and 10).
2) New Jersey has determined that nearly $20 million in revenue would
be lost if its safety and emissions program were discontinued.
By combining safety and emissions testing programs, New Jersey has
been able to certify vehicle owner insurance, licensing and auto
registration as well (reference 13).
3) See reference 3.
4) See references: 3, pg. 40; and 10.
5) See reference 15, pgs. 3-4.
6) In an alternative I/M systems analysis for Denver, centralized options
required a range of only 44-68 lanes involving 41 stations while a
private, decentralized option estimated 600 participating inspection
sites (reference 6).
7) The information below is included from reference 4, pg. 72:
9/78 3.1-54
-------
aa
(continued)
ESTIMATED DURATION AND THROUGHPUT OF INSPECTION PROGRAMS
Locale
New Jersey
Arizona
Arizona
Oregon
California
Cincinnati
Nevada
Massachusetts
Missouri
Duration,
minutes
Program
Combined safety and idle
mode emission inspection
'Loaded mode emission
inspection
Motor vehicle safety emis-
sion diagnostic inspection
demonstration project
Idle mode emission inspection
Riverside pilot program -
loaded mode emission
inspection
Combined safety and idle mode
emission inspection
Private garage idle mode emis- 20-25
sion inspection v/adjustments
Private garage safety inspec- 8-10
tion program
Private garage safety inspec- 20
tion program
Throughput,
vehicle/minute
6
6
25-30
4-5
6-8
1/1.5
1/3
1/8
1/3
1/3
.Time for inspection only, does not include waiting time.
Potential throughout for inspection test lanes, does not consider
influence of downtime and assumes vehicle always waiting for inspection.
1/2
NA
NA
NA
NA - Not applicable.
-------
»» 8) Costs for a dynamometer and supportive hardware have been quoted
5} as ranging from $6400 to $10,000. The costs of HC and CO analyzers
have generally been shown to range from $2000 to $2500. A NOx
analyzer has been estimated at $2800. Costs for supportive automation,
instrumentation and data handling range from $2500-$30,000 (references
1; 5; pgs. 206, 215; 4, pg. 94; 20; pg. 51; 6, pg. 3-10).
9) Illustrative Emissions Test Equipment Costs Per Lane
COSTS OF
GCA(77) OTLUP(76) DENVER(74) ARIZONA(77) CALIFORNIA(72) CLEAN AIR
(76)
A Emission Analyzers 2200 69001 - 17502
(HC, CO, NOx)
B Dynamometers 10000 7000 8000 6500 6950 6400
(loaded mode)
C Instrumentation/ 25,000 - 30,000 - 26720
Data Handling
1. A and C for idle mode only
2. For HC and CO only
9) For a more detailed discussion of the various I/M test modes see reference 5,
pgs. 30-76; reference 21, pgs. 21-23 and See reference (17) A Review of
Control Strategies for In-Use Vehicles; Aerospace Corp., ECTD, USEPA;
Dec. 1974.
10) For a discussion of the merits and drawbacks of various approaches to I/M
testing see reference 5, pgs. 12-29. See also reference (18) Inspection
and Maintenance of Light Duty Gasoline-Powered Motor Vehicles; A Guide
for Implementation, EPA, Aug. 1974 , pgs. 2-8-2-11; A Review of Control
Strategies for In-Use Vehicles, etc.; Degradation Effects on Motor Vehicle
Exhaust Emission, Olson Laboratories, 1976 and An Evaluation of Restorative
Maintenance on Exhaust Emission of 1975-1976 Model Year In-Use Automobiles,
EPA, 1977.
11) See reference 3, pg. 45.
12) While a generalized approach places the throughput rate for loaded mode
testing a 29,000 vehicles per lane year and idle mode at 32,000 vehicles
•^ per lane per year, the following specific approach can be utilized:
i
Ul
-------
12) continued
Figuring Throughput and Lane Requirements
Throughput:
1. duration of inspection in minutes divided by operating efficiency
of lane (probably between 50% and 80%).
2. Adjusted time per test vehicle (from #1 in vehicles/minute)
multiplied by 60 minutes/hour, number of hours of facility
operations per day.
3. Multiply vehicle tests per day times days of operation to
arrive at vehicle tests per year per lane.
Lane Requirements
1. Assess total number of applicable vehicles.
2. Multiply #1 by failure rate.
3. Add #1 to #2 to obtain total inspections.
4. Divide total inspections (#3) by total inspections
possible per lane per year to obtain number of lanes
required.
9/78 3'1-57
-------
^> 13) For a more detailed discussion of station design criteria and
>j requirements see references 4, pgs. 69-85; and 5, pgs. 77-111
and 197-200.
14) See references 4, pgs. 87-101 and; 5, pgs. 197-207.
15) See technical note #8.
16) See references 10, 4, 5. Conversations also with Ron Householder, State
of Oregon DEQ and John Elston, State of New Jersey.
17) See reference 9.
18) Ibid.
19) See references 6 and 4.
20) Increased costs to the consumer under a private garage system were pointed
out in both the Denver and St. Louis studies. Nevada's present pilot
system involving idle mode testing by licensed service stations,
garages and auto dealers can vary the motorist's fee from $8.50 to
$16 .00. Rhode Island, with a private garage-based system, charges
only $4.00, however. Total private garage, decentralized labor costs
to be factored into the overall determination of the ultimate inspection
fee can be calculated as follows:
number of
affected labor cost
Mechanics hourly wage x emission test time per vehicle x vehicles = component of
total program
$9-12.50 per hour 10-25 minutes n(e.g. 1,000,000) costs to be
incurred by
vehicle
owners
21) In reference 5, Arizona noted $550 per inspector for idle and
c*50 for loaded mode (1976); EPA-OTLUP noted $60,000 per million
(reference l) vehicles (1977); Pennsylvania (reference 19) noted
approximately $150 for mechanic and $770 for instruction for
initial training (1977) and GCA (St. Louis (reference 4) indicated
$350 for both idle and loaded mode mechanic training (1977).
22) See reference 3, pgs 46-47.
i 23) See reference 3, pgs 49-51 and reference 10.
oo
-------
•£&') Thomas Getz, Rhode Island Department of Health, telephone conversation
June 1978.
25) See reference 6, pg. 3-2 and 4, Table 3.
26) See reference 13.
27) See reference 13.
28) See reference 14.
29) I/M demonstration programs have been or are being conducted in Riverside,
California; Tampa, Florida; Chicago, Illinois; and Louisville, Kentucky.
In Riverside, vehicles were required to undergo inspection but
maintenance of failed vehicles was voluntary. In Tampa, Chicago, and
Louisville, nil partlcipa'ulo. *z val'-'^tary.
30) See references 12, 5 and 22. Conversations with Ron Householder of the
Oregon DEQ, determined the cost of a fully-equipped mobile van
with trailer, test equipment including analyzers to cost approximately
$40,000.
31) See references 21, 10 and 9.
32) See references 3 and reference 4, pg. 43. $5.0 million in Clean Air
Act Section 105 funds will likely become available in FY 79 to
assist in the development of introductory I/M programs.
33) See reference 3, pg. 49.
34) Waivers or repair ceilings are noted in the legislative analysis.
35) References 10 and 4.
36) Reference 13 and 17.
i
Ul
vO
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Bibliography
1) "Fixed and Operating Costs of A Two-Lane Inspection Station,"
OTLUP-EPA, April 1976.
2) "Evaluation of Mandatory Vehicle Inspection and Maintenance
Programs," California Air Resources Board, (Preliminary Draft),
August, 1976.
3) "Inspection/Maintenance Cost Effectiveness and Feasibility of
Implementation;" Bentz, Edward, et^ ail_., Long Range Planning Group,
OPE: USEPA; May 1977.
4) Viable Alternative Types of Inspection/Maintenance Programs for
St. Louis, Final Report, Kincannon,Benjamin, et^ a_K, June, 1977.
5) Motor Vehicle Emissions Inspection Program-Technical Report,
Volume 5; Arizona Department of Health, Division of Air Pollution
Control, Environmental Health Services; Jan. 1974.
6) "Inspection/Maintenance of Light Duty Vehicles in the Denver Air
Quality Control Region," TRfo, Inc; (Technical Report; Nov. 1974.)
7) "Tune Up for Less Emissions - It's Working," Arizona Vehicular
Emissions Inspection Program Operations - 1977, Arizona Dept.
of Health Services, Bureau of Vehicular Emissions Inspection,
April, 1978.
8) "Evaluation of the Nevada Inspection/Maintenance Programs,"
(Final Report), GCA Corp./GCA Technology Division, Aug. 1976.
9/78 3.1-60
-------
9) "Comparison of Contractor Versus State Operated Vehicle Emissions
Inspection Program on Change of Ownership Only" - memorandum from
California Bureau of Automotive Repair to California Air Resources
Board; May 23, 1977.
10) "California Vehicle Inspection Program - Volume II - Cost Proposal,"
Hamilton Test Systems, March 1977.
11) "Inspection and Maintenance - Program Elements and Approaches;"
USEPA - Region I; updated (1977).
12) "Vehicle Inspection Program; Overview," State of Oregon Department
of Environmental Quality, 1978.
13) "Motor Vehicle Inspection System Study Commission; Final Report
1978," State of New Jersey Motor Vehicle Inspection Study Commission,
May, 1978.
4) "Inspection and Maintenance in the Nevada Context," F. H. Castaline,
GCA Corp., GCA Technology Division, paper presented to Fifth Annual
NorthAmerican MVEC Conference; Oct. 26, 1976.
15) "Inspection/Maintenance Policy Paper," U.S. Environmental Protection
Agency, July 17, 1978.
16) Memorandum from R. D. Gafford (Olson Laboratories) to F. B. Cronin
(EPA-OAWM); dated June 18, 1974.
17) A Review of Control Strategies for In-Use Vehicles, Regospace Corp.
and EPA-ECTD; Dec. 1974.
18) Inspection and Maintenance of Light-Duty. Gasoline-Powered Motor
Vehicles: A Guide for Implementation, U.S. EPA-SASD; Aug. 1974,
19) Memorandum from G. L. Triplett, (Pa. BAQNC) to G. R. Bonina, EPA
Region III; Nov. 5, 1976.
}0) Draft of "Costs of the Clean Air Act," 1976, p. 72.
9/78 3.1-61
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21) Information Document on Automobile Emissions Inspection and Maintenance
Programs. EPA 400/2-78-001, 1978.
22) "Vehicle Emissions Testing Systems - Cost Analysis for City of Chicago"
Olson Laboratories, Feb. 1973.
23) "Periodic Motor Vehicle Inspection," Highway Safety Program Manual
No. 1, Jan. 1974, U.S. DOT, NHTSA.
24 "Motor Vehicle Inspection/Maintenance in the U.S. An Update;" -
Bruce Carhart, USEPA, paper delivered to the 6th Annual Meeting
MVECC; April 5, 1976.
9/78 3.1-62
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Legislation
-------
Section 4.1
Suggested Content for Inspection/Maintenance Legislation
USEPA's policy for what constitutes an acceptable I/M program is outlined
in Section 1.2. However, enabling legislation for I/M can be in many
different forms. This paper provides a brief overview of general subjects
which can be contained in I/M legislation. No attempt is made here in
this section to specify what is desirable for state legislation in general.
Many parts of this section indicate that certain elements may be included
in legislation. In most cases such elements can just as easily be
addressed by the administering agency in the form of technical and procedural
rules and regulations. These subjects are indicated by * in the sentence
or phrase where they appear. A tabular representation detailing the content
of eight state inspection/maintenance (l/M) statutes plus the I/M ordinance
of the City of Chicago is provided in Section 4.2. While this table
should provide some assistance in determining appropriate legislation, local
factors should of course be considered and Section 1.2 should be consulted.
Guidelines for Model Legislation Components
1. Definitions
May include procedural and organizational terms used in a specific or
unusual sense, as well as all technical terms.
2. Purpose
Indicates the intent and general context of the program, and defines the
agency responsible for its execution. (May identify two agencies for
responsibilities such as state air agency and state department of motor
vehicles).
3. Type of Program
Establishes the form in which inspection will take place. May specify
requirements for state facilities and provide for their acquisition,
construction or modification. May alternatively provide for contracting
to private firms for administering centralized inspections. May provide
for facilities (e.g., repair garages). May outline bidding processes,
terms of contracts, qualification of contractors, etc.
4/78
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4. Procedures
4c
May define mode of testing (o be employed. May associate emissions tes£
with safety test procedures, specify vehicle components to be examined, ^
emissions of concern, equipment to be used and procedures to be followed.
5. Staff
Provides for staff and their training to operate state-run facilities, or to
inspect and maintain terms and standards of contracted or certified inspection
stations.
6. Implementation Schedule
Establishes major milestones of program. Hay provide for voluntary phase-in
period, public information campaign, scheduling of inspections themselves
(e.g., monthly staggering, and dates upon which various levels of enforcement
will take effect). May also make special provisions for fleet inspections.*
7. Standards for Emissions
*
May define pass/fail criteria and/or stringency factors to be observed,
including the allowable levels of various gaseous emissions (may be stratified
according to model types and/or years). May also require the presence
and proper operation of vehicle emission control systems.
*
Can also be done by regulations promulgated by administering state agency.
9/78 4.1-2
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8. Requirements for Vehicle Registration
Provides for the distribution of certificates, stickers, etc. as validation
of compliance with inspection standards. May require such certificates
as prerequisite to annual vehicle registration or transfer of ownership.
May require such certification within a specified time period before sale
by used vehicle dealerships.* May set guidelines for retesting of failed
vehicle^ after repair, or of passed vehicles after accidents requiring
repair. May disallow falsification or improper granting of such certi-
ficate.
9. Enforcement
Prescribes penalties for non-compliance with other provisions of legislation.
May prohibit operation of uncertified or non-compliant vehicles. May
define function of state inspectors to maintain standards of contracted
private inspection operations. May allow for spot-check retesting of
certified vehicles by enforcement authorities. May set time limits for
compliance with repair or certification requirements.
May provide for:
(1) suspension of registration (in which case vehicles are prohibited
from using the highway) for vehicle ovners who cannot demonstrate
their vehicles passed the applicable test standards.
(2) revocation of station inspection permit
for licensed private garages in decentralized systems for failure
to follow applicable rules and regulations.
(3) fines and/or imprisonment for noncompliance with applicable
rules and regulations.
Can also be done by regulations promulgated by administering agency.
9/78 4.1-3
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10. Applicability and Exemptions
Indicates classes of vehicles to which program requirements apply and
do not apply, e.g., light-duty vehicles, light-duty trucks, etc.
May specify weight limitations.* May exempt heavy duty, non road-use,
and historic or rare vehicles, motorcycles, motor-driven bicycles,
golf carts, etc.*
11. Public Information
Provides for the compilation and distribution of consumer information
such as standards and regulations, inspection procedures and scheduling,
likely repair problems and costs, the seriousness of the air pollution
situation, etc.
12. Repairs^
Specifies guidelines, for repair and adjustment procedures pursuant to
failed inspections. May regulate charges for specific repairs.*
May provide for special training and certification of repair personnel,
and specify uniform instrumentation and its use for repair stations.
May set terms of authorization of repair stations* agd regulate the re-testing
and certification of failed vehicles after repairs.
*
Can also be done by regulations promulgated by administering agency.
9/78 4.1-4
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13. Records and Review
Provides for the collection and storage of. records on vehicles inspected,
inspection results and repairs performed. Provides for the ongoing
analysis of the effectiveness of the inspection, certification and
repair procedures, and the assembly of such records and analyses into
regular reports. May also provide for the review and updating of the
program on the basis of such reports.
14. Financing
Provides for the funding of the program on the basis of a specified
combination of intergovernmental grants, revenues, and inspection fees.
May establish maximum fees, and proportions of operating or capital
costs to be covered by each source. May allocate specific dollar
amounts for initial funding. May create an "Emission Inspection Fund"
for the fees which will subsequently be used to support the program.
15. Severance Clause
Allows for the severance of any part of the statute due to its
unconstitutionality or invalidity.
Can also be done by regulations promulgated by administering agency.
9/78
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Section 4.2
ANALYST'S OF STATE STATUTES
Attached is a table which reviews the content of I/M legis-
lation from the States of Arizona, California, Colorado, Connecticut,
Nevada, New Jersey, Oregon, and Rhode Island, and the I/M ordinance
from the City of Chicago. A *•+" in the table indicates inclusion in
the bills that established the individual I/M programs. However, such
inclusions are not all-encompassing. For instance, "technical rules
and regulations" frequently means only that the law authorizes the
administering agencies to adopt necessary rules and regulations to
implement the program. For details of a particular State's I/M author-
ity, the reader should refer to the full text of the appropriate I/M law.
J/78
4.2-1
-------
ANALYSIS OF STATE STATUTES
REGARDING MOTOR VEHICLE
EMISSION REGULATIONS AND
PROVISIONS
ARIZONA
CALIFORNIA
CONNECTICUT CHICAGO COLORADO NEVADA NEW JERSEY OREGON RHODE-ISLAND
I. Department Authorized to
Administer The Emission
Control Program
Dept. of Dept. of
Health Services Consumer
Affairs
Department of Dept. of Dept. of
Environmental Environ- Health
Protection mental (air pollu- Contn*'
Control tlon con-
trol dlvl-
State En- Dept. of Environ- Registry of
vlronmental Environ- mental Motor Vehicles
mental Commission
Protection (Department of
State Air
Resources
Board
Cal. Highway
Patrol
Department
of Motor
Vehicles
slon) Dept. of
Dept. of Motor Vehicles
Dept. of Motor Vehicles
Revenue
Dept. of
Air Pollu- Human Resources
tlon Control
Commission
tlon)
II.Authority to Hire
Outside Contractors
for Program Opera-
tion
Independent Contractor
(bidding requirement and
prohibition against
having financial Interest
In repair facilities)
Dlr. of Health Dept. of Con-
Services authorized sumer Affairs
to enter Into an
agreement w/one or
more contractors
4-
Authorized to
Contract w/prlvate
or public
entitles +
* , , (Connecticut)
(California)
9..'"
4.2-Z
-------
ARIZONA
CALIFORNIA
CONNECTICUT CHICAGO COLORADO NEVADA NEW JERSEY RHODE ISLAND OREGON
III. Requirements for
Vehicle Inspectors
Examination or demon-
stration of skills,
competence, and capa-
bility
(by way of
contract)
IV. Technical Standards
and Regulations +
(rules pertaining to the operation
and maintenance of emission Inspection sta-
tions; licensing emission Inspectors and
standards of approval, operation, cali-
bration, and certification of exhaust
gas analyzers)
V. Requirements for
Vehicle Registration
(Inspection test and
evidence of compliance)
VI. Exemptions + +
, A. New Motor Vehicles + +
B. Transfer (prlvate-
pub!1c)sale vehicles +
C. Model and year of +
vehicle (cars 15 years
old)
+ 44
+ -f
+
+ +
(cars manufac- (cars manu-
tured prior to factured prior
1 968 ) -i
y°° ' 1977)
+ 4
(no Inspec-
tion until
vehicle 1s
2 years or
older)
4
4
4
(cars manu-
factured
pri or to
1942)
9/78
4 :>-•
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ARIZONA CALIFORNIA CONNECTICUT CHICAGO COLORADO NEVADA NEM JERSEY OREGON RHODE ISLAND
VII. Required Inspection
Frequency + + + +++++ +
Annual
Note: each state provides
for a maximum time period
for Inspection prior to
registration
Si
(change-of- +
ownership)
, •
+ (biannual
Inspection)
VIII. Public Information
A. Consumer Education
Provision +
B. Information Allocation +
+
+
IX. Fee Structure
A. Maximum allowable
charge per Inspection
(charge not to
exceed $5.00)
(charge not to
exceed $5.00)
(charge not to
exceed $5.20)
(charge based
on prevailing
shop labor rates)
9/78
4.2-4
-------
ARIZONA CALIFORNIA CONNECTICUT CHICAGO
COLORADO NEVADA NEW JERSEY OREGON RHODE ISLAND
Fee Structure (cont.)
B. Fee to be fixed and
adjusted by an author-
ized official to re-
flect both the con-
tractual charge (where
applicable) and any
escalation or decrease
of administration costs.
NOTE: All fees collected
at the time of registration
are deposited In the state's
Inspection Fund.
(fee charged
must be sufficient
to "match" any fed-
eral twts awarded)
(fee also must cover
reimbursements to
Motor Vehicle Account
1n the Transportation
Tax Fund)
X. Relnspectlon for Certification
without an Additional Charge
NOTE: All states which provided
for relnspectlon w/out additional
charge, also required that reln-
spectlon occur w/ln a specified
time limit.
XI. Referee or challenge lane
facility to Insure protection
of vehicle owners
9/78
(allows for
relnspectlon
w/ln 30 days)
(allowed, but not
specifically men-
(legislative authori-
ty to provide for
"referee" facility)
4.2-5
-------
ARIZONA CALIFORNIA
CONNECTICUT CHICAGO COLORADO NEVADA NEW JERSEY OREGON
RHODE ISLAND
XII. Maximum allowable charge
to vehicle owners to bring
vehicles Into compliance + + +
(not to exceed ($50.00 w/a (not to exceed
$25.00 for pre- provision to $/0.00)
1968 vehicles raise to $75.00
and $75.00 for necessary)
1968 and later
vehicles)
(escalation of
repair charge
reflects the
consumer price
Index)
XIII. Monitoring Provisions
to Insure compliance by
vehicle Inspectors
Provision for the sub-
mission of all emission
Inspection records and
documents pertaining
to the operation and
maintenance of the emission/
Inspection station
(by way of
contract)
(no fee specified;
however, the State
Environmental
Commission shall
set repair cost
limits In a manner
to avoid unnecessary
financial hardship)
XIV.
Remedies and Sanctions for
failure to comply with stan- +
dards, rules or any other provisions
(Fines, imprisonment,prohibition
against operating noncomplyln
vehicles on the highway, etc.
9/78
4.2-6
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ARIZONA CALIFORNIA CONNECTICUT CHICAGO COLORADO NEVADA NEW JERSEY OREGON RHODE ISLAND
Remedies and Sanctions
(cont.)
NOTE: Suspension of registration
Is 1n addition to a fine and/or
ImpMslonment 1n all cases.
XV. ..Emission Inspection Fund
XVI. Severance Clause
9/78
4.2-7
-------
Information
-------
Section 5.1
Public Information and the
Establishment of Inspection/Maintenance Programs
Who Should Get Involved?
Since almost everyone contributes to air pollution from motor
vehicles, almost everyone should get involved in a program to deal with
it. Through an I/M program every registered car owner with only minimal
inconvenience can make an individual contribution to improved air
quality.
The first step in getting such a program underway in your State
is enabling legislation. Such legislation will be enacted only if
citizens work actively for its passage. Citizens need to know and
understand the seriousness of the problems and its health effects, what
an I/M program can do, what benefits they can expect, how much it will
cost, and how a program works. Developing I/M public awareness will
take a continuing information program during the months ahead. To get
an I/M program in place, a State and/or organizations must develop and
plan activities to ensure a continuing flow of information. Groups who
have a role or interest in I/M legislation and should potentially be
involved, include (but are not limited to) tne following:
State, local government
air pollution control agencies
motor vehicle agencies
state legislators/staff
energy and transportation officials
elected officials/staffs
9/78 5.1-1
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Public Interest Groups
League of Women Voters
American Lung Association
consumer protection groups
Sierra Club
clean air coalitions/environmental groups
League of Cities
Conference of Mayors
National Association of Counties
Civic Groups
Chamber of Commerce
Jaycees
Kivanis
Urban League
NAACP
Health Groups
State, County Medical Societies
Public Health Association
Auto Related Services
automotive service organizations
dealers associations
garages and service stations associations
auto parts manufacturers and suppliers
emission analyzer manufacturers
gasoline retailers
Organized Auto Owners
auto clubs
sports, recreational groups
Media
newspaper
trade press
special press
radio stations
television stations
How to Enlist Help
A core group involved in I/M already exist. American Lung Association
9/78
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chapters across the country are supporting I/M to further reduce air
pollution and its related lung problems. The ALA and EPA joined forces
to develop a multi-media package of informational materials on I/M
(see pages) which can be useful in encouraging broader understanding
of the program.
Other programs such as the ones listed above can easily get involved,
too.
What can Groups do?
* Obtain information for members and niifn contact other potentially
interested groups.
* Arrange workshops, seminars, and public meetings to brief citizens
and other organizations on the air quality status in individual
areas and the requirements that must be met under the Clean Air
Act. Emphasize I/M. Invite appropriate media. Solicit help in
reaching other groups.
* Where meetings cannot be arranged or are infeasible, write to
various groups, include brief information and offer additional
help. Follow up by telephone to see what additional information
might be needed.
* Contact your district legislators and brief them on the need
program- 5.1-3
-------
* Encourage others to write or contact their legislators.
* Meet with appropriate legislative committees and present views.
* Attend public meetings where I/M or air quality is being discussed
and present views.
* With other community groups, sponsor a town meeting, invite
legislators, State and local officials to discuss air quality
problems and I/M as one possible solution.
* Develop a leaflet explaining I/M and encourage other groups, gas
stations and garages to distribute.
* Include an I/M article in your regular publication or newsletter.
* Borrow a copy of the ALA/EPA film, "On the Road to Clean Air"
and show it to various additional groups.
* Coordinate with a local emission analyzer manufacturer to set up
a demonstration testing station in a shopping mall or urban
center to give people an opportunity to have their car inspected
for emissions levels.
* Work with a health organization to develop an exhibit on the
health effects of air pollution for display at a county or State
fair or another *ell-attended event.
9/78 5-1'4
-------
* Sponsor a poster or bumper sticker contest for school children
on the need for I/M programs, have various groups offer prizes
and plan to exhibit in area accessible to the public.
How to Make Effective Use of Media
The media—newspapers, radio and television—can alert and inform
large number of citizens to the need for, the benefits of, the costs
and the kinds of I/M programs that can be considered.
How to Get Press Coverage
* Invite environmental reporters and news editors to an I/M
briefing, show them the film "On the Road to Clean Air", provide
them with additional information and contact people who can
answer questions.
* Invite press to a voluntary demonstration that is being held
in the vicinity.
* Provide information on the status of enabling legislation
for I/M programs.
* Help to arrange interviews with key state and/or local government
officials involved in I/M considerations.
* Provide information on successful programs in other cities and States.
9/78 5>1 5
-------
* Provide information and background on the local situation to
editorial writers.
* Invite reporters to public meetings and hearings.
* Develop press releases on significant activities your organization
has planned on I/M.
* Encourage local newspapers to feature a question box where
readers can write in questions and expect an answer.
How to Interest Radio and Television
The broadcast media provides many opportunities to reach
broad segments of the public and stimulate public discussion
and involvement in I/M programs. In addition to their news and
editorial coverage commercial and public radio and television stations
are required by the FCC to determine community needs and make their
programming responsible to these needs through public service spots
and programs.
To tap public service time, organizations might:
* Suggest a panel discussion of air quality problems and the role
of I/M in reducing the problem.
* Offer the EPA film "On the Road to Clean Air" for viewing.
9/78 5.1-6
-------
* Suggest a call-in show for viewers and listeners at home to ask
I/M and air quality questions of a knowledgeable person.
* Encourage a documentary or feature on the local air pollution
situation and on the role of I/M as one solution in minimizing
pollution.
* Suggest a panel discussion on the health effects of air pollution
and the status of air quality improvement in your city.
Other Opportunities
The trade and special press-professional and technical
journals or newspapers, environmental and other newsletters, and
church or civic publications offer many opportunities to get
I/M information to citizens. Contact the editor and provide him
or her with additional information.
Available Materials
I/M information materials which are available include:
Film
"On the Road to Clean Air"—a 17-minute color film covers purpose
and need for I/M programs, the benefits and costs and how a program
operates. Available from your local ALA chapter or from EPA
Regional Offices on a free-loan basis.
9/78
5.1-7
-------
Publications
"Information Document on Automobile Emissions Inspection and
Maintenance Programs" - EPA-400/2-78-001 (February 1978) a report
produced pursuant to Section 108 of the Clean Air Act which presents
substantial information on all aspects of inspection/maintenance
programs. Available from EPA.
"Turning Down Auto Air Pollution"—a 16-page booklet which discusses
the need for I/M programs, the benefits and costs and how a program
works. Available from EPA.
"Get a Check-up for your Car"—a leaflet on the need for keeping
cars well maintained to cut pollution along with pointers on what
can go wrong with your engine and what to do about it. Available
in English and Spanish from your local ALA chapter or EPA regional
office.
"Do You Own a Car"—a leaflet which explains pollution control
systems and gives the reasons why motorists should not tamper with
those devices. Available from EPA.
"The Health Effects of Air Pollution"—a 16-page pamphlet which
discussess the various air pollutants and the effects they have
on health. Available from EPA.
Materials for the Mass Media
American Lung Association (ALA) TV spot - a 60-second television
9/78 5-1'8
-------
presentation which emphasizes the need for regular car maintenance
to minimize auto-related air pollution. Produced in cooperation
with the ALA and Car Care Council. Available from ALA and EPA.
ALA radio spots - four 30-second presentations, including one
in Spanish, which stress the connection between air pollution and
the automobile. Available from ALA and EPA.
5.1-9
9/78
-------
Training
-------
Materials Developed at the Section 6.1
Center for Motor Vehicle Emissions Control and Safety
Available Through the Department of Industrial Sciences,
Colorado State University, Fort Collins, Colorado 80523
Reference
Number Cost
Motor Vehicle Emissions Control Instructional Materials 1122-0 $145.00
Packet
Designed as a complete multimedia training course which
includes: Technical related narrative, 35mm slides and audio
cassette tapes, test questions with answers and laboratory
exercises with tool list. This instructional packet is de-
signed for vocational automotive teachers who wish to train
future mechanics, mechanics in the field and additional
teachers on the basic concepts of emissions and vehicle
emissions control systems.
Instructor's Guide for use with Vehicle Emissions Control 0331-3 6.50
Instructional Materials Packet
Designed to aid the instructor in class preparation,
demonstrations, "hands on" sessions and the presentation
of the "Colorado Emissions Control Packet" (0331-1) and/
or the "Motor Vehicle Emissions Control Packet" (1122-0).
It consists of key points for improving classroom pre-
sentation, suggestions for dramatic "table top" and
"live vehicle" demonstrations as well as class formation,
time budgeting and effective use of components for de-
monstration purposes.
Emissions Control Multi-Media Kit 1122-1 150.00
Designed as a complete multi-media auto mechanics
training course. This Kit includes 359 slides (35 mm);
8 audio cassettes; test questions with answer key and
laboratory exercises (including tool list) plus a complete
easy to follow instructor's guide. This kit has been de-
signed primarily to be used in the teacher training work-
shops but is available as an excellent instructional aid
for teachers with some background in emissions control
instruction. The kit includes 1122-0 and 0331-3.
Chemistry of the Internal Combustion Engine - Running 1122-2 50.00
Time (41 min.)
A 3/4 inch color video presentation on fuel composition
and'changes resulting from the combustion process.
6.1-1
9/78
(REV. 4/73>
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Reference
Number Cost
Motor Vehicle Emissions Control - Series of Seven Books 1159-1 $ 10.00
A series of seven illustrated self-instructional books
(391 total pages) designed to teach the concepts of emissions
control systems. The seven topics covered are: Positive
Crankcase Ventilation Systems; Thermostatic Air Cleaner
Systems; Air Injection Reaction Systems; Fuel Evaporation
Control Systems; Exhaust Gas Recirculation Systems; Spark
Control Systems; and Catalytic Converter Systems. Allow
one kit for each student since it is a consumable workbook.
Emissions Control Training Mechanics Handouts 1167-1 1.75
Designed to be used in conjunction with the "Motor
Vehicle Emissions Control Instructional Materials Packet"
(1122-0). The booklet contains handouts, laboratory ex-
ercise worksheets and other related information. It is
intended for mechanic use while attending an instructor
facilitated workshop.
It is not designed for use alone, or as a self-
instructionaTdevice or textbook.
A Primer On Auto Emissions Systems for Home Mechanics 1167-2 3.50
A book designed to acquaint the vehicle owner who likes
to maintain his automobile with the basic emissions control
systems and components installed on today's cars. It con-
tains animated, easy to understand, step by step procedures
for checking various components related to emissions control
systems. This book is not intended to be a substitute for,
or replace a good emissions control service manual.
Instructor's Guide for Vehicle Emissions Control Training 1167-3 4.50
A self-contained curriculum with narrative, illustra-
tions and overhead transparency masters. It is designed
for instructors with limited background and equipment, who
want to teach the basic concepts and key points of vehicle
emissions control systems.
This guide is part of a training package consisting
of "Instructor's Guide" (1167-3) "transparency Masters"
(1167-4) and "Student Workbook" (1167-5) designed to be
used together.
Transparency Masters for use with Instructor's Guide for 1167-4 3.00
Vehicle Emissions Control
This training aid provi'des all the transparency
masters which are identified in the Instructor's Guide.
6.1-2
9/78
REV. 4/78>
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Reference
Number Cost
Student's Workbook for Vehicle Emissions Control Training 1167-5 $ 3.00
A workbook designed to lead students through key points
of vehicle emissions control concepts. This workbook paral-
lels the presentation given in the "Instructor's Guide"
(1167-3) and requires the student's participation by re-
sponding to questions and key points and by performing
simplified "hands on" exercises.
Teacher Classroom Kit 1167-9 10.00
A self-contained curriculum complete with all materials
and instructions necessary for instructors with limited back-
ground and equipment to teach the basic concepts and key points
of vehicle emissions control systems. The1 kit includes 102
page instructor's guide, 116 transparency masters and 1 copy
of the student workbook (99 pages). All teaching aids employ
a low verbal-pictorial approach. The kit includes 1167-3,
1167-4 and 1167-5.
Electronic Ignition Systems 1167-6 35.00
An introductory level approach to electronic ignition
theory and operation with comparisons to conventional
systems. It is designed to be incorporated into the
"Motor Vehicle Emissions Control Instructional Materials
Packet" (1122-0).
The media used is an audio cassette tape, slides,
narrative, test questions and answers.
Colorado Vehicle Emissions Control Mechanic Workbook 0331-2 1.75
Designed to be used by the student in conjunction
with the "Colorado Emissions Control Packet" (0331-1) and/
or the "Motor Vehicle Emissions Control Instructional Ma-
terials Packet" (1122-0). Each segment of this student
workbook contains emissions concepts, laboratory exercises,
self-check questions and related information. It is not
designed for use alone, or as a self-instructional device
or textbook.
Introduction for Vehicle Emissions Control 0331-4 150.00
Two 3/4 inch color video cassettes of an animated
introduction to emissions control systems. There are
eight (8) presentations with an approximate running
time of 10 minutes each. The tapes were produced from
the booklet, A Primer On Auto Emissions Systems for
Home Mechanics.
6.1-3
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Reference
Number Cost
Colorado Vehicle Emissions Control Idle Test Book 0331-5 $ 1.00
A detailed presentation to be used in the Colorado
Idle Inspection/Maintenance program. It includes the use
of the infrared analyzer and inspection procedures. In
addition, a section covers probable causes of excessive
emissions that would result in a vehicle failing the
idle inspection.
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Implementation
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Section 7.1
I/M Program
Implementation
Milestone
Schedule
This planning schedule is presented in three large phases:
1. program planning, 2. preparation for the introductory phase, and 3.
implementation of the introductory phase and preparation for the fully
mandatory phase. The timing of the elements indicated may differ from
state to state. The options for implementation included within the
schedule are:
Option A - Decentralized stations (licensed private garages);
Option B - Centralized stations, state-owned and operated; and
Option C - Centralized stations, contractor-owned and operated.
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Program Planning Phase
From Month-12 to Month +2*
This phase should be begun before legislation is enacted.
From Month -12 to Month -6:
1. Prepare analysis of benefits and costs of program.
2. Initiate public information effort including
a. the public
b. affected interest groups
c. public officials
3. Prepare legislative proposal.
4. Develop schedule for I/M implementation.
From Month -6 to Month +2:
1. Continue public information program.
2. Finalize system format
a. Program type
1. decentralized
2. state-run centralized
3. contractor-run centralized
b. Type of inspection test
c. Type of enforcement
d. Recordkeeping and reporting
* Month 0 = legislation enacted.
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e. Consumer protection features e.g.
1. Upper limit on cost of repairs
2. "Challenge" or "referee" station
3. Mechanics training
4. System for processing consumer complaints
f. Enforcement system including provisions for:
1. Vehicle owner compliance
2. Licensed inspection station compliance (if applicable)
g. Fee collection system
3. Consideration of necessary standards and regulations.
7.1-3
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Preparation for Introductory Phase
The three main possibilities for an introductory I/M phase are:
1. mandatory inspection with voluntary maintenance;
2. change-of-ownership mandatory inspection and maintenance; and
3. voluntary inspection and maintenance.
Each of these possibilities can be in each of the three implementation
options.
A. Decentralized Option
(From Month 0 to Month 6)
1, Notify garages explaining program and schedule for implementation
2. Adopt standards and regulations including emission analyzer
requirements and licensing requirements for private garages
3. Notify and explain to garages actions in step 2.
4. Train inspectors and license garages
5. Prepare "referee" station(s).
B* State-Run Centralized Option
(From Month 0 to Month 18)
1. Design stations.
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2. Develop and issue any RFPs necessary.
3. Award any necessary contracts.
4. Acquire land.
5. Build inspection facilities.
6. Hire and train inspectors.
7. Adopt standards and regulations including emission
analyzer requirements.
8. Acquire equipment.
C. Contractor-Run Centralized Option
(From Month 0 to Month 18)
All of the steps in Option B are needed in this option as well,
except 1,4,5,6, and 8 are done by a private contractor.
Other Necessary Elements for Introductory Phase
All three options need the following addditional elements.
1. Continue public information program with new emphasis to public
on the reason for the I/M program and the coming I/M requirements.
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2. Hire administrative personnel.
3. Develop and adopt either preliminary or final outpoints.
(Introductory phase may be used to develop outpoints.)
A. Finalize record reporting system.
5. Finalize fee collection system.
6. Finalize enforcement system (if inspection is mandatory in
introductory phase or if change-of-ownership phase is planned)
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Implementation of Introductory
Phase and Preparation for Fully Mandatory Phase
Decentralized - From Month 6 to Month 18
Centralized (State-Run or Contractor-Run) - From Month 18 to Month 30
1. Initiate testing.
2. Continue public information program, stressing the reason for the
I/M program plus the locations and hours of the stations.
*
3. Institute calibration, monitoring, and enforcement procedures, including
auditing program if system has licensed private stations.
4. Institute record reporting system.
p. Institute plan for consumer protection.
6. Evaluate emission data in introductory phase and finalize outpoints
if not already finished.
7. Train mechanics (and inform do-it-yourselfers) or "institute a
program of public information of service establishment with
approved emission analyzers.
not for voluntary inspection and maintenance
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