INSPECTION  AND MAINTENANCE
      A GUIDE FOR IMPLEMENTATION
           ENVIRONMENTAL PROTECTION AGENCY
                ROUGH DRAFT

               Do not cite or quote.
         Strategies and A1r Standards Division
            Research Triangle Park, N. C.

               February 25, 1974

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INSPECTION  AND  MAINTENANCE
      A GUIDE FOR IMPLEMENTATION
            ENVIRONMENTAL PROTECTION AGENCY
         Strategies and Air Standards Division
            Research Triangle Park, N. C.

                February 25, 1974

                    TCP-1

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                             DOCUMENT STATUS

      This document is being circulated within  EPA for  critical
review and comment only and should not be  cited or quoted.   It
is a draft and therefore,  does not reflect official  EPA policy.
      Mention of companies or product names does not constitute
endorsement by EPA.

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                            TABLE OF CONTENTS

Chapter I  Introduction
     Legislative Review
     Air Quality Criteria, Standards, and Pollutants                1-3
     Extent of the Problem                                          1-7
     References                                                     1-9
Chapter II  Inspection and Maintenance Programs
     Description of Inspection and Maintenance Programs             II-l
     Instrumentation and Equipment                                  11-12
     Effectiveness of Inspection and Maintenance Programs           11-13
     Cost of Inspection and Maintenance Strategies                  11-22
     Factors in Choosing an Inspection and Maintenance Strategy     11-27
     References                                                     11-29
Chapter III  Legal Authority
     Enabling Legislation                                           III-3
     Rules and Regulations                                          III-4
     References                                                     111-8
Chapter IV  Implementation
     Agencies Involved                                              IV-1
     Implementation Schedule                                        IV-5
     Federal Assistance                                             IV-10
     Training                                                       IV-14
     Potential  Problems Associated with Inspection and              IV-19
       Maintenance Programs

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Chapter V  Monitoring and Reporting
     Monitoring                                                     V-l
     Reporting                                                      V-8
     Public Acceptance                                              V-ll
Chapter VI  Federal and State Programs Related to Inspection
              and Maintenance
     Programs Sponsored by the Federal Government                   VI-1
     Programs Sponsored by State and Municipal Governments          VI-5
     References                                                     VI-8
Appendix A  Environmental Protection Agency Regional Offices
Appendix B  Glossary
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Table 1
                 LIST OF TABLES

Summary of National  Air Quality Standards for Motor
Vehicle Related Pollutants
Table 2-1   Engine Parameter Inspection
Table 2-2   New Jersey Approved Manufacturers of Low Cost Infrared
            Analyzers Suitable for Use in Repair Garages
Table 2-3   Initial Reductions in Pollutants With Major Inspection
            Strategies
Table 2-4   Reductions in Polluting Emissions to the Atmosphere from
            a Vehicle Population Subjected to Emission Inspection
Table 2-5   New Jersey Idle Inspection Standards
Table 2-6   Costs of Equipment for Emission Inspection
Table 2-7   Inspection Station Cost Estimates
Table 2-8   State of California Total Program Costs
Table V-l   Inspection and Maintenance Emission Data
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                             LIST OF FIGURES

Figure 2-1    Derivation of Emission Standards from Cumulative Distri-
              bution of Emissions
Figure IV-1   Implementation of State Owned Inspection Lanes (Idle or
              Loaded Mode Tests)
Figure IV-2   Implementation of Idle Inspection at Licensed Garages
Figure V-l    Vehicle Emission Inspection - Idle Method
Figure V-2    Vehicle Emission Inspection - Loaded Method
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                            CHAPTER I
                          INTRODUCTION

   The purpose of this document is to  provide guidance  to applicable
Federal, State, and local  agencies on  how to implement.and monitor  an
inspection and maintenance program for motor vehicles.   Before  begin-
ning discussion of the various aspects of an inspection  and maintenance
program however, it would perhaps be helpful to review  briefly  the
evolution of the fight against air pollution, with emphasis on  motor
vehicle pollution abatement.
     A brief legislative review provides an insight into the impor-
tance which legislators have increasingly attached to motor vehicle
control over the past decade.  A discussion of air quality criteria
and standards gives an overview of the basic relationship between
criteria and standards.  A discussion  of pollutant characteristics  is
included to give the reader an understanding of the types of pollutants
emitted by motor vehicles.  Finally, a discussion of the extent of
motor vehicle pollution highlights the need for control  and how this
control can be accomplished.

                        Legislative Review
     The U.S. Congress first responded to growing public concern over
declining air quality in 1955 with legislation authorizing a Federal
program of air pollution research and  technical assistance to State and
local governments  (PL 84-159).  This legislation established a  policy,
retained in all subsequent legislation, that State and  local governments
have fundamental responsibility for local air pollution control with
the Federal Government providing leadership and support.
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     The first congressional  efforts to bring vehicle emissions  under
control were initiated in 1961  with public law 86-493.   This  legislation
authorized the'Public Health Service to conduct a study of pollution
caused by vehicles and to report the results to Congress.   An amendment
to this law (PL 87-761} authorized vehicle studies on a continuing basis.
As a result of this legislation, significant progress was  made toward
achieving an understanding of the air pollution problem and developing
methods for air pollution control.  By 1973, however, it became  apparent
that the progress in scientific understanding was not being translated
into improved air quality, primarily because State and local  governments
had neither the resources nor the authority to adequately  cope with the
problem.
     Results of early studies authorized by Congress indicated that
motor vehicles were contributing significantly to overall  air pollution
levels.  Consequently, Congress passed an amendment to the Clean Air
Act in 1965 authorizing the Department of Health, Education,  and Welfare
to set emission standards for motor vehicles.  Initial  standards  per-
taining to crankcase and tailpipe emissions from gasoline-powered
motor vehicles became effective in the 1968 model year. The  most recent
Federal legislation, the Clean Air Amendments of 1970, impact directly
on transprotation systems in addition to individual  motor  vehicles
through such provisions as:   requiring State implementation plans to
include land-use and transportation controls where necessary, and setting
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new motor vehicle emission standards to be effective in  model  year
1975* for carbon monoxide and hydrocarbons and in model  year 1976* for
oxides of nitrogen.   While these new motor vehicle emission standards
are a Federal responsibility, States have the responsibility to control,
regulate, or restrict the use, operation, or movement of registered or
licensed motor vehicles where necessary.

         Air Quality Criteria, Standards, And Pollutants
Air Quality Criteria
     The 1967 amendments to the Clean Air Act required the Department
of Health, Education, and Welfare to publish air quality criteria judged
to be requisite for the protection of public health and welfare.  Air
quality criteria are an expression of the scientific knowledge of the
relationship between various concentrations of pollutants in the air
and their effect on man and his environment.  Criteria are descriptive
in that they describe the effects that have been observed to occur when
the concentration of a pollutant in the air has reached or exceeded a
specific level for a specific period of time.  Such criteria provide the
most realistic basis that we presently have for determining to what point
pollution levels must be reduced if we are to protect public health and
welfare.
     As scientific knowledge grows, air quality criteria will have to
be reviewed and, in all probability, revised.  The Congress has made it
* Required compliance with these emission standards has been delayed
  until 1976 for carbon monoxide and hydrocarbons and. until 1977 for
  oxides of nitrogen.
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clear, however, that we are expected, without delay,  to make the most
effective use of the knowledge we now have.
Air Quality Standards
     The 1970 amendments to the Clean Air Act required the Environmental
Protection Agency (EPA) to promulgate national air quality standards for
each air pollutant for which air quality criteria have been issued.   Air
quality standards are prescriptive.   They prescribe pollutant exposures or
levels of effect that should not be exceeded in a specified geographic area.
     Air quality standards for motor vehicle related  pollutants are pro-
vided in Table I.
                                 Table I
               Summary of National Air Quality Standards
                 For Motor Vehicle Related Pollutants
                      Averaging                  Primary & Secondary
Pollutant	Time	Standards	
CO                    8 - Hour*                  10 mg/m3 (9ppm)
                      1 - Hour*                  40 mg/m3 (35ppm)
NO-                   Annual                     100  yg/m3 (O.OSppm)
                        (Arithmetic Mean)
Photochemical         1 - Hour*                  160  jig/m3 (O.OSppm)
Oxidants
Hydrocarbons          3 - Hour*                  160  yg/m3 (0.24ppm)
(Non-Methane)

*Not to be exceeded more than once per year.
NOTE:  The hydrocarbon standard is a guide to developing State imple-
       mentation plans to achieve the oxidant standard.  The hydrocarbon
       standard does not have to be met if the oxidant standard is met.
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     Air quality standards are set at two levels,  primary and secondary.
Primary standards establish how clean the air must be to safeguard
human health.  Secondary standards establish how clean the air must
be to prevent damage to clothes, buildings, metals, vegetation, animals,
etc.  As shown in Table I, primary and secondary standards for motor
vehicle related pollutants are the same, which means that the levels
set for each pollutant are sufficient to protect both health and welfare.
     The above standards are "national" in that they apply to all 50
States, the District of Columbia, and three U. S.  territories.  These
political jurisdictions have until mid-1975 (1977 in some cases) to meet
the standards.
Pollutant Characteristics
     The air pollutants discussed below are often called the motor
vehicle related pollutants.  This is because first, that they are emitted
by motor vehicles, and secondly, because the amounts of these pollutants
emitted by motor vehicles constitute a major portion of the total of
such pollutants emitted by all sources.
     1.  Carbon monoxide:  Carbon monoxide is the most widely distributed
and the most commonly occurring air pollutant.  '  Total emissions of
carbon monoxide to the atmosphere exceed those of all other pollutants
combined.  Most atmospheric carbon monoxide is produced by the incomplete
combustion of carbonaceous materials such as fuels for vehicles, space
heating, and industrial processing.  Man's activities are, therefore,
largely responsible for carbon monoxide contamination.
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     The introduction of the internal  combustion engine for transportation
and the development of a number of technological processes which produce
carbon monoxide have greatly increased atmospheric concentrations.   Tfcans-
portation activities represent the largest source category.  Concern has
now broadened from the acute and often lethal  effects  of high concentrations
of the gas to encompass as well those effects  that may occur as a result of
considerably longer exposures to much lower concentrations.
     2.  Nitrogen oxides:  Of the various oxides of nitrogen, the most
important as air pollutants are nitric oxide and nitrogen dioxide.   The
term nitrogen oxides usually refers to either  or both  of these two substances.
Nitric oxide and a comparatively small amount of nitrogen dioxide are
formed under high temperature conditions such  as those that accompany the
                        (2\
burning of fossil fuels.  '  They are emitted  to the atmosphere from
automobile exhaust, furnace stacks, incinerators, and vents from certain
chemical processes.  These substances are also important in air pollution
control becuase they are involved in .photochemical reactions in the atmosphere.
     Mobile sources are the largest single source category, contributing
over 40 percent of all man-made nitrogen dioxide in the United States.  '
The next largest source is electric power generation which is responsible
for nearly 20 percent of all man-made nitrogen dioxide.
     3.  Photochemical oxidants:  As initiated by sunlight, a series of
complex atmospheric reactions between hydrocarbons and oxides of nitrogen
                                                                            (4\
lead to the formation of new substances, among which are ozone and oxidants/  '
These substances are chemical entities detrimental to^ biological systems
and destructive to certain materials.  The complexity of the atmospheric
reaction has led to differences in interpretation of experimental results
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by researchers  These differences relate to the degree of reactivity  of
various hydrocarbons and the effects of reactivity over a period of time.
The Division of Chemistry and Physics of the National  Environmental  Research
Center is conducting research in these and other areas.
     4.  Hydrocarbons:  Hydrocarbons are important in  air pollution con-
trol, not because of their direct effects, but because of their role in
photochemical reactions.  Hydrocarbon emissions originate primarily from
the inefficient combustion of volatile fuels and from  their use as process
raw materials.  It was estimated that the transportation source category
contributed 52 percent of the nationwide hydrocarbon emissions in 1968.  '
Organic solvent was the second largest source category, contributing about
27 percent, and industrial processes was third, contributing 14 percent.
                           Extent of the Problem
     Taken individually, the automobile appears to be  a very minor air
pollution offender.  The amount of hydrocarbons, carbon monoxide, and
nitrogen oxides emitted by a single automobile are small compared to
industrial sources.   However, the sheer numbers of automobiles operating
daily cause serious air pollution problems in many metropolitan areas.  For
example, there were approximately four million vehicles, including trucks,
in Los Angeles County in 1970,  ' or one vehicle for every two people in
the County.   If the present growth trend continues,.there will be approxi-
mately six million vehicles in Los Angeles County by 1990.  One and on-
half million  vehicles were driven about 35 million miles in the Greater
Houston area  in 1971, and over one billion gallons of gasoline and diesel
fuel were consumed in the process.   '  These kinds of statistics make it
obvious that  vehicle  pollution must  be controlled.

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     Transportation control  measures are of two basic types.
Measures such as bus/carpool lanes and parking restrictions are
intended to encourage the use of more efficient modes of travel, i.e.,
buses and carpools, instead of the single passenger motor vehicle.
As a result of a shift to more efficient travel modes, vehicles miles of
travel (VMT) are reduced and the pollutants emitted are reduced.  Measures
such as retrofits and inspection and maintenance are intended to reduce
the quantity of pollutants emitted by motor vehicles.  The latter of these
measures, inspection and maintenance, is required either by the State or
EPA in most of the metropolitan areas which now require transportation
controls.
     An inspection and maintenance program by itself is a control measure
which can facilitate substantial reductions in automobile exhaust emis-
sions.  In addition, an inspection and maintenance program can mean much more
to a program to reduce automotive emissions, since it is a corner stone
for an effective mobile source control program.  For example, an inspection
and maintenance -program is  basic to any retrofit program which may be
implemented.  Furthermore,  it is vital to the implementation of the warranty,
recall, and anti-tampering  provisions of the Clean Air Act.  These programs
will assure that the emission reductions achievable by the Federal  Motor
Vehicle Control Program are actually attained by vehicles in use.
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                               References

1.   Air Quality Criteria for Carbon Monoxide (AP-62).  U.  S.  Department
    of Health, Education, and Welfare, National  Air Pollution Control
    Administration, Washington, D.  C., March 1970.
2.   Air Quality Criteria for Nitrogen Oxides (AP-84),  Environmental
    Protection Agency, Air Pollution Control Office, Washington, D.  C.,
    January 1971.
3.   Control Techniques for Nitrogen Oxide Emissions from Stationary Sources
    (AP-67), U. S. Department of Health, Education and Welfare, National
    Air Pollution Control Administration, Washington,  D. C., March 1970.
4.   Air Quality for Photochemical Oxidants (AP-63), U. S. Department
    of Health, Education, and Welfare National Air Pollution Control Admin-
    istration, Washington, D. C., March 1970.
5.  Air Quality Criteria for Hydrocarbons (AP-64), U.  S. Department of
    Health, Education, and Welfare, National Air Pollution Control
    Administration, Washington, D. C., March 1970.
6.  Transportation Control Strategy Development for the Metropolitan
    Los Angeles Region,  APTD-1372, EPA, December, 1972.
7.  Transportation Control Strategy Development for the Greater Houston
    Area.  APTD-1373,  EPA, December, 1972.
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                         CHAPTER II



             INSPECTION AND MAINTENANCE PROGRAMS





     Inspection and maintenance covers a variety of strategies for



reducing air polluting emissions fron light-duty motor vehicles



currently in use by establishing procedures that will assure their



continued proper maintenance by the motorist.  Most of the approaches



have two distinct phases:  an inspection phase, in which motorists



arc required to periodically present their vehicle for examination;



and a maintenance phase, in which vehicles failing to meet the passing



requirement of the examination must be taken to a garage for maintenance



to bring them back into compliance.



     Description of Inspection and Maintenance Programs



     There are three classifications which cover the major alternate



approaches to inspection and maintenance, emission inspection, engine



parameter inspection, and mandatory maintenance.  Emission inspection



involves sampling the exhaust gases from the vehicle being examined



and passing them through suitable analytical instrumentation to measure



the quantities of air polluting compounds they contain.  If the concen-



trations of these compounds all fall below the standards set by the



rppronriate agency, the vehicle passes the examination.  If the concen-



trations of any pollutant  are above the standard, the vehicle  fails.



Vehicles failing the  test  must then be adjusted or repaired to bring



the emissions  into  compliance.  Following the maintenance, it  would



normally be required  that  the vehicle be resubmitted for an emission



test  to determine that  it  is in compliance.



      Engine parameter inspection involves the examination of critical



engine components and adjustments  to  determine whether  thr engine  is




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functioning according to the manufacturer's  specifications.   If the

vehicle failer7 to fall within the tolerances set by  the  State agency

it would bo required to undergo needed  adjustments or repairs to

brinn it within the tolerances.  If  the required maintenance were

performed by a certified mechanic there would be no  necessity for

returning the vehicle for reinspeotion.

     Mandatorv maintenance avoids the inspection phase entirely.  Here

the vehicle must periodically undergo specified maintenance  procedures

bv ar authorized garage.  The maintenance  procedures are1 designed to

correct or avoid the most frequent types of emission-related malfunctions

of "vehicles of a  particular make, model,  and year of manufacture.

     Before discussing the various inspection and maintenance programs,

it is perhaps worthwhile to discuss  the alternate ways in which a

state, county, or municipal agency might structure an inspection and

maintenance system.

Operational Configuration

     The broad configurations of inspection and maintenance programs are:

     1.  Publicly operated lane system
     2.  Privately operated lane system
     3.  Licensed garage system

     In the publicly operated lane system, the inspection function is

performed directly by the appropriate government agency  in publicly

owned and operated facilities set up for inspection  of motor vehicles.

The facilities may be exclusively devoted  to emission testing or

include other types of required inspection such as vehicle safety.

     In a privately operated lane system,  the testing would  be performed

by a private organization under contract to  the appropriate  government

agency.  The facility might either be publicly owned or  the  property of

the licensee.

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     In the licensed garage system the testing is performed by existing



private service or repair agencies within the repair and maintenance



industry.  The facility is certified, licensed, and controlled by the



appropriate government agency.



     Generally, it is assumed that any needed repair, adjustment, or



maintenance would be done by private service garages and dealerships.



In the case of the licensed garage system described above, the garage



performing the inspection would be in a position to do the required



work to bring the vehicle into compliance.



Emission Inspection



     The two major considerations in performing an emission inspection



are the emission measurement itself and the vehicle operating condition



during the measurement.



     Analysis of Vehicle Exhaust Gases;  The air pollutants in auto-



motive exhaust of concern in inspection and maintenance are hydrocarbons,



carbon monoxide, and nitrogen oxides.



     Hydrocarbons may be measured by either of two methods:  infrared



absorption or flame ionization detection.  Infrared instruments work



by measuring the infrared energy absorbed by the hydrocarbons in the



sample gas.  Hydrocarbons absorb only at specific infrared frequencies.



F.y measuring just the energy absorbed at these frequencies, the instru-



ment will sense only the hydrocarbons in the sample gas.



     Flame ionization detection depends on the fact that hydrocarbons



introduced into a sample gas generate electrons in a hydrogen flame



which can be detected as an electric current by applying a voltage



across the flame.
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     Presence of carbon monoxide is determined by infrared absorption.

In this case the instrument is set to respond to the particular

frequencies of infrared radiation absorbed by carbon monoxide.  It is

therefore, not affected by the hydrocarbons present in the gas since

they absorb in a different region of the infrared spectrum.

     Nitrogen oxides are really two gases, nitric oxide (NO)  and nitrogen

dioxide (NO ).  The nitrogen oxides in exhaust gas freshly sampled
           2
from an engine are almost entirely nitric oxide.  However, if the sample

stands for more than a minute as is the case in some sampling methods,

oxygen present in the exhaust will oxidize a portion of the nitric oxide

converting it to nitrogen dioxide.  This tendency for the nitric oxide

to convert to nitrogen dioxide complicates the measurement of nitrogen

oxides.  Nitric oxide can be determined by infrared absorption.  However,

since water absorbs infrared radiation fairly strongly in the nitric

oxide absorption region, the gas must be first passed through a

dessicant to remove all water.

     Nitrogen dioxide can be measured by ultraviolet light absorption,

but the method lacks sensitivity.  When the infrared and ultraviolet

absorption instruments are used the individual concentrations are

summed to give the total concentration of nitrogen oxides.

     In recent years chemiluminescent instruments have become available

for nitrogen oxide measurement.  They depend upon the fact that when

nitric oxide is mixed with ozone, the nitric oxide rapidly converts

to nitrogen dioxide emitting light in proportion to the concentration

of nitric oxide present.  The emitted light is measured with a photo-

nultiplier tube.  To make the instrument measure total nitrogen oxides

the sample qa.s is first passed through a stainless steel or molybdenum

tube at high temperature to decompose any nitrogen dioxide present

back to nitric oxide.  By this procedure all the nitrogen oxides are

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present as nitric oxide as they pass  into  the  ozone  reaction  chamber.
     This method requires a means of  generating  ozone  and careful  control
of pressures.  There may also be interference  from carbon monoxide
under certain operating conditions.   The chcmiluminescent method is specific
in the Federal  motor vehicle certification regulations  for measuring exhaust from
gasoline powered engines.
     Fxhaust gases contain about 15 percent water and  varying levels
of particulate matter.  At room temperature the  water  will condense  in
sample lines and within the instruments.   This condensation along  with
particulate  matter will quickly cause an analytical  instrument to
Iria Ifunction  or give erroneous readings.  It is therefore  customary to
provide a water trap to condense excess water  and a  filter to remove
the particulate matter.  For delicate research grade instrumentation
commonly used in the Federal test procedure for  new  vehicle certification,
elaborate refrigerated condensing systems  and  high efficiency fiber  glass
filters are  used.  For the simplest instrument used  by garage mechanics
for diagnostic tests, simple ambiqnt  temperature knockout traps and
ceramic filters will do the job.
     The sampling system in its simplest configuration is a hand held
metal probe  attached to the instrument system  with flexible tubing.
A gas pump pulls gas through the probe, the clean-up system and the
analytical instrument.  Set up this way the measurement system measures
the concentrations of the pollutant compounds  in the exhaust.   Typically
the concentration is expressed as volume percent for the  carbon monoxide
and parts per million by volume for the hydrocarbons  and nitrogen oxides.
     If it is desired to make emission measurements  which will correlate
more closely with results that would  be obtained by  the Federal certifi-
cation procedure and provide the same units of grams/mile,  a  constant
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vo]unc sampling systen xvould be used.  This .system hn  the  effect of
weighting emissions at each driving condition by the flow rate of
exhaust eras at that condition.  It automatically weights and  averages
the emissions collected over changing operating conditions.   It  also  allow
correct comparison of emissions from different engine sizes.  Although
this procedure would provide the most accurate results, these systems
are oeneral.ly large and expensive and only feasible whore a Targe number
of vehicles are to be processed" By each system.
     Vehcile Preconditioning;  Pre-conditioning of the  vehicle is
important in achieving repeatable anc1 meanincful   results.  In tie
Federal test procedure, the vehicle mist stare1 inoperative  for at
least twelve hours within a specified range of arbient  temperatures
before the engine is started and the emission measurement begun.  This
procedure is called a cold start, and brings into play  the  effect of
cboko setting on emissions.
     An alternate, referred to as a hot start, is to start  the test
with the vehicle at or near its normal operating temperatures.   For
in-use vehicle emission inspection both these procedures require more
time than is normally available.  Since it is not reasonable  to  reouire
the car to stand for 12 hours until inspected, some variation of hot
tost preconditioning is necessary.  In the case of an idle  test, several
seconds of running at higher speeds in neutral will help clear the
engine.  This conditioning can be helpful if vehicles have  been  standing
in an inspection line idling for some time before the start of the test.
When a  loaded mode test is used, there can be some short  running at a
higher speed under load.
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     Vehicle Operating Modes;  The choice of the mode or modes of
operation over which the sample is taken determines how closely the
emissions measured by the inspection procedure correspond to or
correlate with the emissions to the atmosphere from vehicles in normal
use.  They also determine the amount of diagnostic information the test
will provide in the case of a vehicle failing the inspection test.
     An operating mode is a period of operation over which the vehicle
is either running at a constant speed or undergoing an acceleration
or deceleration.  A constant speed or cruise mode would be defined by
the speed and the time interval over which it was maintained.  Idle is a
constant speed mode of zero speed.  An acceleration or deceleration mode,
called transient modes, could be typified by the speed of the vehicle
at the start and end of the mode and the time interval between the two
speeds.
     An inspection may consist of sampling exhaust gases at one or more
nodes.  Up to a point, the greater the number of modes examined, the
better the correlation with emissions to the atmosphere and the more
diagnostic information available.
     The idle mode is commonly referred to as a no-load mode since there
is little or no resistance to the running of the engine.  All other
modes are considered loaded since the wind, rolling friction, and engine
friction all put a load on the engine.  To simulate the action on the
engine of running on the road a chassis dynamometer is used.
     A chassis dynamometer consists of a pair of parallel rollers which
support the rear wheels of the vehicle under test.   The car can then
be placed in gear and the rear wheels driven on the rollers while
the vehicle stands in place.   Adjustable,  heavy inertial weights are
attached to the rollers to resist changes  in speed,  thus simulating  the

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weiaht of the vehicle.  Also, a power absorption unit is usually attached



to the rollers to resist their rotation and thus simulate wind and



other resistances to the motion of a vehicle.  With a chassis dynamometer,



it is possible to fully simulate thp engine behavior for a vehicle



on the road while the vehicle stands in place - a great convenience for



emission testing.



     An idle mode inspection test is the simplest emission inspection



that can be performed.  It requires the simplest instrument system and



needs no dynamometer.  Pass or fail can be indicated by lights on the



instrument set to activate at the fall points.  The inspector need only



indicate which pollutants were above the standard.  There is no need to



indicate how far above since there is little or no diagnostic content



in this information.  The test should be completed in two minutes in a



licensed garage inspection and under a minute in a lane inspection.



     Loaded mode emission tests with a dynamometer allow for a variety



of test cycles.  One of the well known test cycles is the Clayton Key



node test.  In this test emissions are measured under each of three



successive constant speed modes, 50 mph, 30 mph, and idle.  The power



absorption is set proportional to the third power of the road speed giving



a high loading of 30 horse power at 50 mph.  Under this condition the



vehicle is at a higher load than would be experienced in level road



operation.  The high engine loading is said to provide better diagnostic



information than a normal load.  Fail limits can be set for each of



the conditions or a linear combination of them.  In any event, the



readings at all three conditions should be given to the vehicle owner



on a card so that thp mechanic can use them in performing the needed



maintenance.  An example of how the mechanic might use this informaiton



is as follows:  a normal hydrocarbon level at idle and a too high level




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at high speed points to electrical  problems.   The  reverse  would  indicate
incorrect adjustment of carburetor  at idle.   Alternatively,  a  card
indicating the probably faults may  be supplied.
     Since only cruising speeds are used,  the dynamometer  for  a  key mode
test does not require inertial weights.   The  result is  a substantial
reduction equipment in cost and elimination of th  need  to  set  inertia
weight for each vehicle.
     The driving cycle may also involve  transient  operating  modes.   An
                                   (2\
example is the so called ACID cyclev  ' in which the emissions  are
measured while the vehicle is accelerated at  a constant rate to  30  mph,
held at 30 mph, decelerated at a constant rate to  idle, and  held at
idle for a specified time.  This cycle was designed to  operate with a
constant volume sampler.  Because the loading is not as severe as with
the key mode, it may not be as valuable  a diagnostic tool.  The  ACID cycle
requires a dynamometer with both power absorption  and inertial weights  so
that it responds properly to the acceleration and  deceleration modes.   Use
of inertial weights increases the costs  substantially.
Engine Parameter Inspection
     The second major alternate strategy for  inspection and  maintenance
is the inspection of selected engine  parameters for departure  from
manufacturers' specifications.  Only  those parameters need be  inspected
which have an impact on vehicle emissions. Table  2-1  shows  the  significant
                                   (3)
parameters identified in one study  v  ' influencing carbon  monoxide  and
hydrocarbon emissions for precatalytic emission control systems.
     Note that an infrared analyzer is used in measuring the idle
adjustments.   Here the instrument is  being used as an air-fuel ratio

                                     II-9

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meter rather than as an emission measurement device.   With  the adoption
of devices for controlling nitrogen oxides and catalytic devices to meet
1975 and later standards, additional parameters will  have to be added to
those in Table 2-1.
      A check of the subsystems in Table 2-1 represents  an  extensive and
costly inspection.  Depending upon the extent of emission reduction ex-
pected from inspection and maintenance, a less extensive system might be
substituted.
      Failure limits would be established based on manufacturers speci-
fications, but his does not guarantee identifying all  the high emitters.
However, the engine parameter inspection strategy specifically identifies
the maintenance to be done.  It in effect combines inspection and diagnosis.
This also means that the car need not be reinspected  if  the repair is by
a certified garage.
Mandatory Maintenance
      Mandatory maintenance eliminates the inspection step  by simply
requiring that certain replacements and adjustments be made to the engine
periodically.  This can include replacement of spark  plugs, points and
condenser, air cleaner filter, catalyst, etc. and adjusting timing, air
fuel ratio,  air pump  belt tension, etc.  In the area of adjustments,
manufacturer tolerances would still have to be followed  so  that mandatory
maintenance does not eliminate the inspection phase but  rather, makes
it an integral part of the maintenance.  In effect, the  certified mechanic
who does the maintenance is also the inspector.  While this is a simplifying
step, it may result in more maintenance than is needed to achieve the
desired control of emissions from the in-use vehicle  population.
                                  11-10

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                          TABLE  2-1

                 Enoine Parameter
                                          Equipment
Subsystem           Engine Parameter     Requirements
Idle Adjustments    % Idle CO            IR CO Analyzer
                    RPM, Timing          Tachometer, Timing
                                         Light


Secondary Ignition  Plugs, Wires         Electronic Engine
                    Distributor          Analyzer
Induction           Air Cleaner          Air Cleaner Tester
                    PCV Valve            Pressure Gauge
                    Air Injection        Air Floy/meter
                    System
                              11-11

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                      Instrumentation and Equipment
     The necessary technology for conducting vehicle inspections  and
required maintenance has reached a point where a State has  a full  range
of alternate systems to choose from without the necessity of sponsoring
an extensive development effort.  The scientific instrument, computer,
dynamometer, and garage service industries have participated in various
inspection and maintenance programs over the last seven years and have
developed a substantial capability.
     The following companies have been involved in the design and
manufacture of emission test systems (not to be confused with manufac-
turers of individual system components)  for inspection and  maintenance
programs and may be consulted on the overall system design:
     1.  Automotive Environmental Systems, Inc.
     2.  Beckman Instruments, Inc.
     3.  The Bendix Corp., Environmental Science Div.
     4.  Horiba Instruments, Inc.
     5.  Interteck Corp.
     6.  Olson Laboratories
     7.  Sun Electric Corporation
     -8.  Scott Research Laboratories, Inc.
     The need for low cost infrared analyzers for measuring carbon
monoxide and hydrocarbons that would be  suitable for use in idle  emission
inspection and by repair garages has spurred a major and successful  effort
by the instrument industry to develop practical instruments.  Consequently,
there are a large number of good instruments now available.   Table 2-2
lists the infrared instruments currently approved by New Jersey for  use in
repair garages.  These same instruments  would be suitable for inspection
in a licensed garage inspection system.
                                  11-12

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     Effectiveness of Inspection and Maintenance Programs

     So many factors enter into determininq the effectiveness of the

programs which have been discussed that is is difficult at tho present

timo to mako an accurate assessment.  The information we have from

the various studies of this question is  summarized in this section.

Relative Effectiveness of Principal Programs

     The three main programs are compared in Table 2-3 on the basis of

reductions in emissions obtained immediately following required
           (4)
maintenance   .  The data shown for the exhaust emissions inspection

are a combination of results obtained using idle and a loaded mode

inspection tests.  The data show that it is possible to achieve

significant reduction in hydrocarbons and carbon monoxide in rejected

vehicles which have been serviced for each of the three general

programs.  Notice that there is no significant improvement in

for the pre-1972 vehicles tested in the case of nitrogen oxides.

This situation    can be expected to change as vehicles with nitrogen

oxides controls become prevalent.

     Comparisons are made of initial reductions immediately following

maintenance both for the vehicles that were serviced am? the total fleet

(serviced and unserviced).  The latter measure is a better indicator

of reductions in emissions to the atmosphere.
                              11-13

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                               Table 2-2

                          New Jersey Approved
                    Manufacturers  of Low Cost Infrared
                      Analyzers Suitable For Use
                           in Repair Garages
     Supplier
     Model
Allen Electric Company
Emission Analyzer Model # „
23-060 Series and 23-070 Series
American Motors Corp.*
AMserv Model #23-067 Series
and 23-077 Series
American Parts Company
Powerreody Infrared HCKO Analyzer
Model #370-400
Atlas
Exhaust Emission Tester Model
#340
Autoscan, Inc.
CO and HC Analyzer Model Nos.
710 and 4030
Barnes Engineering Co.
Emission Analyzer Model #8335
Beckman Instrument Company
HC/CO Vehicle Emissions Analyzer
Model #590
Chrysler Corporation*
Technician Service Equipment
Program.  Model Nos. DCE*75,
23-066 Series and 23-076 Series
Ford Motor Corporation*
Rotunda Equipment Program
Rotunda Analyzer Model Nos.
BRE-42-730 and BRE-42-731
Kal-Equip
HC/co Infrared Emissions
Analyzer Model #4094-C
Marquette Manufacturing Corp.
Emissions Analyzers Model Nos,
42-151 and 42-153
NAPA Balkamp
Infrared HC/CO Emissions
Analyzer Model #14-4787
                                  11-14

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                        Table 2-2 (cont'd.)
     Supplier
     Model
Horiba Instruments Ltd.
Engine Exhaust Analyzer
Models CSM-300 and Mexa-300
Peerless
Infrared Exhaust Gas Tester
Model #600
Stewart-Warner
Infrared Gas Analyzer
Model #3160-A
Sun Electric Corporation
Sun EET-910, U-912, U-912-I
and EPA-75 Exhaust Emission
Testers
Womaco-Yanaco
Exhaust Gas Analyzer Model# EIR-101
  Available only to New Car Dealers of the company.
                                   11-15

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Table 2-3  Initial Reductions in Pollutants
    With Major Inspection Strategies
           (Pre 1972 Vehicles)
I/M Strategy %
Vehicles
Serviced

Exhaust Emission Inspections
Loaded Test
Idle Test
Engine Parameter Inspection
Mandatory Maintenance


30%
30%
95%
100%
Initial Reduction in Mean Exhaust Emissions
From Serviced Vehicles From Total Fleet
HC

50%
45%
11%
15%
CO

41%
38%
6.5%
U%
NO

0
0
0
0
HC

27%
22%
10%
15%
cp_

19%
16%
6%
11%
NO

0
0
0
0

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     Looking at the reductions in the serviced vehicles only,
it appears that exhaust emission inspection is substantially
more effective than the other two programs.    However, in the
case of the exhaust emission inspection only the high emitters
were serviced and as seen in the table, this constituted only
30 percent of the vehicles.  Since the engine paramenter inspection
and mandatory maintenance resulted in servicing nearly the total
fleets, half of whom may have had little need for servicing from
an emission point of view, the average reduction per vehicle appeared
lower.  When the three programs   are compared on a total fleet
basis the results for each were roughly comparable.

Reductions in Emissions to the Atmosphere
     Before data such as that shown in Table 2-3 can be trans-
lated into reductions in emissions to the atmosphere it is nec-
essary to account for the deterioration of the emissions of a.npwiw
serviced vehicle as the vehicle detunes during subsequent use.
Unfortunately, there is an absence of good experimental data
on this point.  Deterioration rate varies widely in character
and level from one vehicle to the next and even within a given
vehicle.  The data available suggest that the simple assumption
of a linear deterioration rate over a period of a year is not
grossly in error.  On this basis, the figures in Table 2-4 were
developed to show the percentage reductions in emissions to the
atmosphere from a vehicle population subjected to annual  vehicle emis-
sion inspection.
                             •11-17

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                                   Table   2-4
          Reductions  in Polluting Emissions to  the Atmosphere from
            a Vehicle Population Subjected to Emission  Inspection
Percent Initial
 Failure Rate                 10      20     30      40      50
Idle  Inspection
      Hydroe'ai-Bons              6*       *%    10*    11*
      Carbon monoxide           3*       6*     3*     9%
Loaded Mode Inspection
      Hydrocarbons              8*     11*    13*    14*     15*
      Carbon monoxide           4*       7*     9*    11*     12*
     SOUPCE:   38  PR Part 51, Appendix N,  June  8,  1973
           These are the figures given in Appendix N of the "Requirements
     for Preparation, Adoption and Submittal  of  Implementation  Plans"
     (Federal Register, Vol. 38, No. 110 Part  III).  Information  similar
     to that shown  in Table 2-4 is not available at the present time for
     emission parameter inspection and mandatory maintenance.
           The initial failure rate is shown  here as an index of  the
     severity of the emission standard which  would be set to achieve the levels
     of reductions  in emissions shown.
     Establishing Pass/Fail Standards
           Table 2-4 can be used as a basis for  establishing emission standards
     for an emission inspection program.  It  is  first determined  what percentage
     reduction in emissions for carbon monoxide  and hydrocarbons  will be achieved
     with the inspection and maintenance program.  This consideration is part of
     the overall transportation plan.  Once this figure is established and a
                                     11-18

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     •H
     •P
     Cfl
                             Figure  2-1
                Derivation of Emission  Standard
           From Cumulative Distribution of Emissions
            80
           60
           20
                                          Emission
                                          Standard
                     Exhaust  Emission Level
decision made  as to whether an idle  inspection or Uoded mode inspection
will be used,  Table 2-4 can be consulted  to determine what  initial failure
rates for hydrocarbon and carbon monoxide are needed to  obtain the desired
reductions in  emissions.  It will then be necessary to run  an experimental
program to define tho dictribution •of-tgmtsstori"TWgl5'BT the-yfchtc-le
poptri-at4en.  '-ry-cmiiuia-o-nre .ai.s^n-DUTM-0ft.or tne Kind snown in Mgure Z-~
then constructefi.
                                 11-19

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    Given the needed rejection rate the standard can then be set.



Figure ?-] illustrates the emission standard corresponding to an



initial rejection rate of 20 percent.



    It needs to be emphasized again that initial failure rate is



not a prime consideration in setting the standard but only an



intermediary between Table 2-4 and Figure 2-1 to get from the



required reductions in the atmosphere to the emission standard which



v.'il] achieve that reduction.



    While this procedure can be applied to the population as a



v;hole, it is probably fairer to distinguish between vehicles



according to whether they have emission controls and according



to the sophistication of the emission control.  This follows



because fundamentally an emission inspection program is trying to



assure a vehicle is properly maintained and not emitting pollutants



in excess of its original design intention.



    New Jersey for example, whose idle inspection program became



fully operational on February 1, 1974, has segregated vehicles



into three classes and developed the following standards.



    Note that these standards become more stringent over the next



year.  An advantage of starting with less stringent standards and



tightening them is that it gives both the public and the repair



industry an opportunity to become accustomed to the system before



the standards come into full force.
                              11-20

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                               table  2-5

                  New Jersey Idle Inspection Standards
                           Effective          Effective       Effective
                         Feb. 1, 1974       July 1,. 1974    July 1,  1975
Vehicle M§del Year
                           CO     HC           CO    HC       CO    HC
_        (%}   (ppm)         (#r  (ppm)     (%)  (ppm)
   •Pre 1968               10.0   1600       -8.5   1400     7.5    1200

   1968 - 1969              8.0    800         7.0    700     5.0     600

   1970 - 1974             6.0    600         5-0    500     4.0     400


 Estimated Failure Rate       12-15$               25$            35$
                                11-21

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       Cost of Inspection and Maintenance Strategies
        overall costs of putting an inspection and maintenance program
into operation will vary markedly from one situation to another.
Some of the specific costs can be pinpointed with reasonable
accuracy.  This section describes estimated costs on several
bases to givei/ an appreciation of the nature of costs that will
be faced.
Costs Pe r_Veh 1 c le Inspected
    7* useful view of overall costs that will have wide applicabi-
lity is to place their on a per car inspected basis.  Annual emission
inspection in State operated lanes will cost about  $2.00 per vehicle.
Where the tests can he incorporated into existing state safety
inspection lares, costs can be still lover.  In the case of licensed
garages, costs have been estimated in the range of  $3.00 to $6.00 per
vehicle for an idle emission inspection.  Perforning an extensive
enaine parameter inspection in a licensed garage will cost approxi-
mately $P.OO. per vehicle.
    Repair costs for an average car failing an emission or engine
narameter inspection will be $20.00 to $30.00.  An  extensive mandatory
maintenance program could cost up to $60.00 per vehicle.
Ccv?ts_ of Instruments and Equipment for Emission Inspection
    T^s has been discussed, instrumentation and equipment for emission
inspection can vary widely from simple visual instrumentation1to fully
?iu tor a ted systems.  Table 2-6 shows the price range for systems that
can ho "ner1 with idle and loaded mode inspection programs.  The
specific systems shown do not cover al] the possibilities.  For example,
OP a State lane there may be a desire to add a municomputer 'for some
aclr'co automation.  This could easily raise the price an additional
S]ofonn.
                              11-22

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                                Table  2-6
               Cost of Equipment for Emission  Inspection
Idle Emission Inspection
     Infrared Hydrocarbon/Carbon Monoxide Instrument
      (Simple meter readout with pass/fail  lights)
$  1,800
Loaded Vehicle Emission Inspection
     Loaded constant speed modes (Key modes)
          Simple instrumentation for HC/CO
          Dynamometer with power absorption
         *Ventilation and exhaust disposal unit
   3,000
   5,000
 $  4.000
 $  12,000
     Constant speed Acceleration and Deceleration Modes
          Simple instrumentation
          Dynamometer with power absorption and inertia
            weights (direct drive)
         *Ventilation and exhaust disposal unit
   3,000
   21,000

   4.000
 $  28,000

'$" 67,000
     Fully automated system
          Accurate instrumentation
                               " • ~~- - v            r
          Automatic Data Treatment   N	
          C\IS System
          Dynamometer with power absorption and inertia weighty
         *Ventilation and exhaust disposal unit
 Repair Garage Instruments for Carbon Monoxide and Hydrocarbons    $600 - $1,500
 *The ventilation and exhaust disposal unit is considered optional.  However,
 since  this unit protects inspectors and/or the general public from objects
 that could be thrown by a dynamometer, the State may consider its use desirable.
                                     '11-23

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   Co^-.t of .•» State_ Opera ted Inspection Lane


       ^ablo 2-7 shows estirptes of the investment  and  annual  operating


   cosf> of State operated inspection lanes using the idle  and Key


   Mor> jnsrpctions.     For both methods  it was assumed thr-t  processing

  --                                     s^    ~--~—. _	_	. —=
  /cf p-m'ssion data was semi-autor.nted/  It is  seen that the equipment
                                    ^*f^*

  \cor,t for thi*  Key  Mode" is about rouble that of the idle inspection wji


i   the automated data handling  is addojfl.  Without the addition of this


   featnrr, tlie cost is about seven-fold greater for the Key  M0<:1e-   Tnc


   rrcc7oninant operating cost is labor which is seen to be  the same for


   both methods.  Note, however, the distinctly higher  capacity of


   the idle inspection lane vhirh will lead to  lower costs  on  a per


   vnhicle tested basis.


   Total Program Costs


       Total costs for a State  maintenance and  inspection program would


   also include costs for training, program planning,  initial  qualifi-


   cation and rertification of  the  inspection  facilities, maintenance


   and depreciation  of the facilities, and the  overall  program adminis-


   tration and enforcement requirements.


       -*n analysis of cost has  been performed  for  the State of California
                                     (4)
   and can serve as  a general guide.     The total  program costs are


   summarized in Table 2-8.  The testing capacity of the system is  based


   on a yearly inspection of a  total population of  ten  million vehicles.
                                 11-24

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                           Table  2-7
                   Inspection Station Cost Estimates

     Cost Element                         Station Type
                                 Idle Mode            Key Mode
Investment Costs         1 lane        2 lane    1 lane       2 lane

Inspection Equipment*  $11,200       $22,400     $20,000      $40,000
Administration           1,000         1,700       1,000       1,700
Site Acquisition                                               >,
 ($2/sq. ft.)           14,380        20,000      21,800     3J©,220
Construction
 ($8/sq. ft.)           10,960        16,320      16,320      24,480
      Total            $37,540       $60,420     $59,120     $ 96,400

Operating Cost (1st year)
Personnel Salaries     $22,000       $44,000     $22,000     $44,000
Supplies &
 Maintenance             1,748         3,186       2,216       3,994
      Total            $23,748       $47,186     $24,216     $47,994
Annual Capacities of Inspection Lanes:  Idle Mode -  32,000 vehicles/lane
                                        Key Mode  -  25,000 vehicles/lane
 *The  inspection  equipment  costs have been updated from th-e
 original' reference to allow  for higher cost of the absorption
 dynamometer.
                                 11-25

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                               Table 2-8
                          State of California
                         Total Program Costs*
                         (Thousands of Dollars)


Cost Element                          Idle Mode               Key Mode

Investment Costs
Site Acquisition & Construction           7,117                 12,445
Equipment & Installation                  4,090                  6,270
Planning & Training                          112                    193
Qualification f* Certification                745                	912
TOTAL                                    12,064                 19,820


Operating Cost  (1st year)
Salaries of Inspection Personnel          6,635                  6,648
Salaries of Administrative
       Personnel                             631                    981
Equipment Maintenance &
       Depreciation                       1,214                  1,473
Facility Maintenance &
       Depreciation                          256                    516
Program Administrative Costs              1.243                  1,301
TOTAL                                     9,979                 10,919
 *Estimated  for California vehicle  population  (10 million)
                                   11-26

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    Factors In Choosing An Inspection And Maintenance Strateqv

    Three major alternate approaches to an inspection and maintenance

program have been considered.  There are possible variations of

these programs and combinations of them that have not been

considered here.  The EPA and industry sponsored APRAC CAPE-13
       (3)
program    explored a number of programs experimentally and developed

a cost/benefit analysis computer program which could he helpful in

deciding which program vas most suited to a given regional problem.

    It is clear, however, from the material which has been presented

in this chapter that the emission inspection schemes are less costly

than pure engine parameter inspection or mandatory maintenance programs,

and appear equally effective in reducing emissions from the population

as a whole.  The emission inspection gives the added satisfaction of

identifying the high emitters and concentrating the maintenance

action on them.

    The chief problem with emission inspection procedures is that while

they identifv the high emitters, they do not specifically idertify the

cau^e of high emission values,  ^his throws a substantial burden on

the repair mechanic who at present is not trained in identifying and

correcting the malfunctions or maladjustments leading to high emission.

In fact, extensive studies have shown that mechanics are onlycbout
                                                                     (3)
50 percent effective in diagnosing and correctino emission problems.
                                                                (4)
Furthermore, they often over repair and adjust in their efforts.

How severe this probler may be will not be knotvn with certainty

until enission inspection is fully implemented in the field.  Clearly,

where the emission inspection program is adopted, consideration needs

to be given to proper training of mechanics and providing them with

diagnostic information whore feasible.


                             11-27

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    fjome  States  have  been  considering  providing training for



 inspectors  and mechanics  through  conmunity  colleges.   The automobile-



 ;ind oil  coir-panics  are aware of  the  problem  and arc beginning to provide



 training  to dealer garaacs and  service stations.



    The  loaded mode emission tost does provide limited diagnostic



 information.  However this benefit  needs  to be balanced in a



 specific  situation against the  added complexity and cost over ar idle



 inspection  test.  It  nay  also be  true  that  vehicles failing a simple



 idle  test ray ho brought  back into  compliance more easily.  Certainly



 the mechanic would he greatly aided, by the  use of low cost CO/IIC



 instruments which  would allow him to directly verify the effect of



 his corrective  actions or. the idle  emissions.



    operational  configuration is  another  major consideration.  Will



 State ovnesd or  franchisee5 inspection lanes  be used, or will the



 inspection  bo done in licensed, privately owned garages?  The



 decision,  in many cases will already be made if the State has set up



 n safety  inspection program.  In  this  case  it would be a simplification



 if tho inspection  could be included in the  sequence of safety tests.



 new .Terscv, for  example,  has 38 State  owned safety inspection stations



 and ad dec1 its idle emission test  at the beginning of the lane.



 Pennsylvania, on the  other hand,  employs  licensed, privately owned



 garages  for its  safety program.  Should it  deride on an idle emission]



"inspection  it would appear reasonable  to  add the test to the safety '



 inspection  tests now  performed  in the  licensed
 should the State decide on a more elaborate loaded mode test, it



 would be necessary to construct State owned or franchised lane  Gw&vlfr^


                                                                , l  1 -/ -
 systems olaced strategically around the State.                   *-"H.'T
                              11-28

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                               REFERENCES
     1.  Cline, E.L. and Tinkham L.., "A Realistic Vehicle Emission
Inspection System," Clayton Manufacturing Company, Air Pollution Control
Association Paper No. 68-152.
     2.  Elston, J. C., Andreatch, A. J. and Mislosk, L. J., "Reduction
of Exhaust Pollutants through Automotive Inspection Requirements--The New
Jersey REPAIR Project," International Clean Air Conference on Air Pollution,
Washington, D. C., February 1971.
     3.  TRW Systems Group, "The Economic Effectiveness of Mandatory
Engine Maintenance for Reducing Vehicle Exhaust Emissions," APRAC Project
Number CAPE-13, Coordinating Research Council, 30 Rockefeller Plaza, New
York, New York, Final Report, July 1972.
     4.  "Control  Strategies for In-Use Vehicles," U.  S. Environmental
Protection Agency, MSAPC,  November 1972.
                                   11-29

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                               CHAPTER III
                             LEGAL AUTHORITY

     The 1970 amendments  to the Clean Air Act give  EPA the necessary
legal authority for carrying out pollution abatement at the Federal
level.  EPA has direct authority to set automobile emission standards
and require automobile manufacturers to meet  these  standards.   Thus,
Federal authority preempts all  other state and local authority with regard
to "new car" emission levels.  However, this  preemption may be waived by
the Administrator, after notice and opportunity for public hearing, for
any State which has adopted emission standards (cbher than crankcase
standards) for new motor vehicles prior to March 30, 1966, unless the
State  does not require emission standards more stringent than Federal
standards.^  The Clean Air Act intended that other transportation controls
be implemented, monitored, and enforced by state agencies.  However, if
a state fails  to  provide the transportation controls that are considered
necessary  for  achieving air quality  standards, EPA has  the authority to
require a  state to provide such transportation controls.  Here again, the
responsibility for implementing, monitoring,  and enforcing transportation
controls would be placed on  the state, and the state must have or obtain the
necessary  legal authority  to comply.
      The  legal authority for an  inspection and maintenance  program should
be  held  by the state for  best  results, especially  if  the  program encompasses
a  large  number of vehicles spread  over a  wide geographical area.   The
training  requirements,  administrative and enforcement  procedures,  and the
 financial  requirements  for facilities, equipment,  and  salaries are normally
                                      III-l

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such that in most cases local  agencies may  hesitate  to  implement  an
inspection and maintenance program unless a substantial  number  of
vehicles would be covered by the program.  Some local agencies  such  as
those in Chicago, New York, and Washington, D.  C.  are planning  inspection
and maintenance programs.  In these cities, large  numbers of vehicles
in relatively small geographical areas will be  subject  to inspection and
maintenance.
     Although the state agency may have the responsibility for  carrying
out an inspection and maintenance program,  the  state may authorize local
agencies to carry out certain portions of the program such as testing,
compliance certification, performing maintenance,  and enforcement.  But
this does not relieve the primary agency of the ultimate responsibility
for the program's operation.  The state may also delegate authority for
certain portions of a program by licensing private businesses.   The state
agency would, in all likelihood, want to establish certification, licensing,
and bonding of private repair facilities if they are involved in the in-
spection and maintenance program.  This would ensure that sufficient equip-
ment, qualified  personnel, and  adequate  facilities were available for
operating the program.
      Effective control of  an inspection and maintenance program requires
adequate  legal authority under  which  enforcement actions can be effected.
The  legal authority may  be divided into  two major parts, state enabling
legislation  and  the rules  and regulations  of the individual air pollution
control  agencies within  any  state.
                                     III-2

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                       State Enabling  Legislation
     Sound enabling legislation at  the state  level  is  an essential  pre-
requisite in establishing the legal  and administrative framework necessary
to organize, staff and fund, provide procedures  for the passage of  rules
and regulations, and to authorize enforcement actions.  Imperfections  in
any enabling provision may cause delays and even failures  in  implementing
a control program.  Enabling legislation which identifies  specific
authority to be exercised by the agency responsible for the inspection
and maintenance program will be more likely to withstand challenges in court,
Some essential provisions include:
     1.  Adequate authority to adopt rules and regulations concerning:
         a.  Requirements for periodic inspection (should  specify  the
     type of inspection such as emission, parameter, etc.).
         b.  Establishment of fees for providing the inspection service.
         c.  Withholding vehicle registration for those vehicles which
     do  not satisfactorily complete the inspection, or which do not comply
     with an applicable variance.
         d.  Prohibition of tampering.
     2.   Provisions for providing adequate funds for implementing, moni-
 toring,  and enforcing  the inspection and maintenance program, if allowed
 by the State's  constitution.
     3.   Adequate authority to  obtain  pertinent data and information,
 and require periodic  reporting  of emission information.
     4.   Authority to make  emission reports  and information available
 for public  inspection.
     5.   Authority to compel  compliance with  rules  and regulations
                                     III-3

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supported by civil  or criminal  penalties.
     6.   Provisions for injunctive relief  where deemed necessary.
                          Rules and Regulations
     Regulations which specifically limit  emissions  of pollutants  to
the atmosphere are of paramount concern in an inspection and maintenance
program.  The nature and extent of emission control  regulations  are
primarily determined by the air quality problem.  The preparation  and
application of emission regulations requires knowledge of the polluting
characteristics of motor vehicles, and the type of program to be imple-
mented.   This is especially important in documenting violations  by
the enforcement personnel for the purpose of legal actions.   Inadequate
understanding in concepts and applications can result in the loss  of
court decisions, thus weakening the entire enforcement operation.   Rules
and regulations are generally comprised of the following:
     1.   Test Procedures:  These regulations specify the type of test to
be required, i.e., idle, loaded, parameter, and how often vehicle  owners
or operators must submit their vehicles for inspection.  Additional test
procedure requirements are also desirable.
     a.   Idle - procedures could include the type of measurement equip-
ment to be used and the engine revolutions per minute (rmp)  at which
vehicles would be tested.
     b.. Loaded - procedures for this type inspection are more complex
than for an idle inspection and thus, would require more information.
An agency could include such information as the modes through which
vehicles will be operated, stabilization time for each mode if required,
appropriate equipment operation, and emission measurement procedures.
                                     III-4

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     c.   Parameter - procedures could include the particular engine
parameters that would require testing and the criteria for determining
the need for maintenance or component replacement.
     2.   Emission Limitations:  These establish the rate of emission
above which a violation or test failure occurs.  There may be one emission
limit applicable to all vehicles subject to the prokjram, or several
limits based on vehicle age.
     3.   Equipment Design Standards:   These are a class of regulations
which specify permissible features, specifications, or standards relating
to the design of equipment or the prescribed use of equipment.  The
necessity for these type regulations is more prevalent for an inspection
and maintenance program in which private businesses participate in the
inspection and/or maintenance operation.
                                     III-5

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     4.   Prohibition of Use or Operation:   This type of regulation pro-
hibits the use or operation of motor vehicles which have emission rates
in excess of the standards.  Upon failure  of a vehicle to meet the standard,
the owner or operator of the vehicle is usually allowed some period of
time in which to bring the vehicle in to compliance.  There is usually a
requirement for a retest of failed vehicles or certification to be pro-
duced by the owner/operator that proper corrective maintenance has been
performed on his vehicle.
     5.  Vehicle Registration:  This type of regulation prohibits the
registration of vehicles which fail to comply with applicable emission
limits or a variance.
     6.  Inspection Fees:  A State would normally desire to establish an
inspection fee which would cover the cost of performing inspections,
whether or not inspections are performed by the State, or licensed private
businesses.
     7.  Variance:  It may occur that some motor vehicles cannot be brought
into compliance with emission standards.  This may be caused by peculiar
engine design or operating characteristics.   In these cases, the air
pollution control agency may wish  to exempt such vehicles from the require-
ment to comply with the emission standards.  An automatic exemption may
be  included for antique and/or classic vehicles.
     8.  Tampering:  To be effective,  emission control devices must be
in  good working order.  A regulation to prevent intentional tampering
or  adjustments to devices or  components required by Federal or State law
may be desirable.   Appropriate penalties should be  included in the regu-
                                    III-6

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lation for discouraging such tampering.
     9.  Powers:  These are a group of supporting  regulations  enacted
to establish right of entry, police powers,  and  requirements for
submission of information on pollutant emissions.
                                   III-7

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                               References

1.   National  Emission Standards Act,  Part A,  Section 209,  Environmental
    Protection Agency,  Washington,  D.  C., December 1970.
                                    III-8

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                       CHAPTER IV.   IMPLEMENTATION

                            Agencies Involved

     The purpose of this section is to discuss the  area of interagency
relationships as it applies to implementation of an inspection  and
maintenance program.  Several  types of agency relationships that already
exist or are likely to exist are presented and the  benefits and problems
of each type discussed.
     The reason that interagency relations are important is that develop-
ment and implementation of an inspection and maintenance program includes
a broad range of activities such as development of  program procedures,
equipment, procurement, vehicle inspection, enforcement, training of
inspectors and mechanics, monitoring results, and handling consumer
complaints or problems.  Usually one agency does not have the resources
or authority to carry out all these tasks without the cooperation or
assistance of other agencies.  Therefore, it is important to have good
working relations among all the agencies involved.
     The legislation authorizing the inspection and maintenance program
is an important factor in determining which agencies are involved.  In
some cases one agency is given total responsibility.  It is then up to
that agency to obtain cooperation and assistance from other agencies as
necessary during development, implementation, and monitoring of the
inspection and maintenance program.  In other cases the legislation
specified several agencies and the particular area  of responsibility
                                   IV-1

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of each agency.   The particular agencies specified in the  legislation  are
determined by factors such as the existence of a State vehicle safety
inspection program, current structure of governmental agencies,  and the
legislators' ideas of the most workable arrangement.
     Several  examples of existing inspection and maintenance programs
will help illustrate which agencies can be involved and how these
agencies relate to each other in the area of inspection and maintenance.
The first example is the program in New Jersey which involves the fol-
lowing four agencies:
     ' The Department of Environmental Protection
     • The Division of Motor Vehicles
     • The Department of Educations
     • The Office of Consumer Affairs
Mew Jersey had an existing State vehicle safety inspection program
administered by the Division of Motor Vehicles to which the emission
inspection could easily be added.  Therefore, the legislation authorizing
the inspection and maintenance program  called for the Division of Motor
Vehicles to work with the Department of Environmental Protection.  The
Department of Environmental  Protection  had the responsibility to develop
the inspection and maintenance program, provide technical assistance,
and monitor the  results.  The Department of Motor Vehicles does the
actual  inspection  and handles enforcement through the vehicle registration
procedure.  Two  other State  agencies  are becoming involved in certain
aspects  of the inspection  and maintenance program.   The Department of
                                  IV-2

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Environmental  Protection is working with the Department of Education
to investigate ways to train mechanics in the auto service industry
to repair autos that have failed the emission inspection.   The Office
of Consumer Affairs has become involved in investigating cases where
consumers have problems getting their vehicles repaired properly.
     This type of interaction  can present both problems and benefits.
One advantage is that the resources and experience of several  agencies
can be brought to bear on the new program.  Hopefully this will allow
the various parts of the program to be carried out in an expeditious
manner since each part is being handled by the most experienced agency.
On the other hand, more coordination and cooperation are required by  the
primary agency to see that all parts of the program are properly carried
out.
     Many of the States which will require inspection and maintenance
programs have existing vehicle safety inspection programs.  In most cases
the agency currently responsible for the safety inspection will also be
involved to some extent with the inspection and maintenance program.
The particular agency responsible for the safety inspection varies con-
siderably between States.  Some examples include the Registrar of Motor
Vehicles in Massachusetts, the Secretary of Revenue in Pennsylvania,  the
Administrator of the Vehicle Inspection Department in Indiana, and the
Superintendent of the State Highway Patrol in Ohio.
     An example of a local inspection and maintenance program  in an
area which requires a safety inspection of commercial vehicles only is
                                  IV-3

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the City of Chicago.   A City ordinance authorizes  the Department of
Environmental  Control  to carry out the inspection  and maintenance
program.  The Department of Environmental  Control  handles the entire
program including technical development and vehicle inspection.   In
the future the Department of Environmental Contrbl may become involved
in garage certification.
     In California the Bureau of Automotive Repair in the Department of
Consumer Affairs has the responsibility of regulating all auto repair
garages.  Beginning in January 1974 the Bureau of Automotive Repair was
given the responsibility to develop an inspection and maintenance program
for southern California including technical development, inspection, and
certification of repair garages.  An idle mode test was incorporated
into the random spot safety inspection conducted  by the Highway Patrol.
This random spot inspection is expected to be converted to a lane type
inspection.
     The primary advantage of having all  responsibility in one agency is
that the overall program can be controlled by one agency.  Presumably,
this would allow for tighter managerial control of the program.  However,
one disadvantage is that expertise must be developed  in several areas
which are  somewhat unrelated to the primary objective of reducing
emissions  from  vehicles.
      In all  cases the  agency with primary responsibility for the inspection
and maintenance  program must see  that  all  aspects of  the program including
technical  development, inspection, enforcement, monitoring, auto
                                   IV-4

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maintenance, inspector and mechanic training,  public relations,  and
consumer protection are developed.   In addition contact should be
maintained with the Environmental  Protection Agency through the
appropriate Regional Offices (see Appendix A).
                         Implementation Schedule
     In this section the factors leading to implementation and their
timing will be discussed.  Generalized implementation schedules will
be presented as models and the assumptions explained.  The models
illustrate the required steps and their time dependence.  The variables
affecting the implementation schedule and how these variables may differ
between States will be discussed.   Examples from State agency experience
will be used to illustrate certain points.
     The bar charts (Figures 1 and 2) show the estimated time period for
implementation of inspection and maintenance programs.  Figure 1 is for
a State owned program with either an idle or loaded mode inspection.
Figure 2 is for an idle inspection at licensed garages.  The estimated
time required for a State owned program is 26 months for an idle test and
29 months for a loaded mode test.   For a State licensed idle test program
the time required is about 26 months.  These time estimates include the
                                   IV-5

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first year cycle necessary to phase in the program to cover the vehicle
population.
     Some of the assumptions made to construct these model  implementation
schedules should be pointed out.   The first assumption which can be seen
from the charts is that the lead time begins at the point in time when
both legal authority and funding arrangements exist.  The time required
to obtain legal authority and to make the necessary funding arrangements
can be a critical factor in the total time required for implementation.
In some cases it may be possible to begin the planning, the pilot program,
and parts of the training program before legal authority has been granted.
The problem of obtaining legal authority and adequate funding will be
discussed further in Chapter IV, Part 5.  A second assumption is that no
facilities or pilot programs are available to build on.  In some cases
the inspection and maintenance programs may be incorporated into existing
safety inspection stations.  This would reduce the time required for
the facilities acquisition step.  -An existing, pilot plant program
could reduce the time required to evaluate and select test equipment
and procedures.  In addition, the staff would have  some
experience that would speed development of the program.  Another assumption
made in developing the model implementation schedules is that only an^idle
test program would be considered for States with State licensed garages.
It is unlikely that an adequate number of private garages would invest in
the more expensive testing equipment necessary for a loaded mode emission
inspection under a State  licensed program,  if such a program is used, the
                                   IV-8

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time required for implementation would be longer than  shown  in  the  model.
     For each specific case there will probably be factors that will  in-
crease or decrease the lead time from that shown in the models.  Some of
these have been pointed out in the above discussion of assumptions.
Additional factors and problems actually encountered by State agencies
will be presented below.
     The current status of a State safety program can have an effect on
the time required to implement and inspection and maintenance program.
For example, a planned State owned program could be implemented faster
in a State with an existing State owned safety program since the existing
stations could be expanded to incorporate the emission testing.  Likewise
a State licensed inspection and maintenance program could be implemented
faster  in a  State with an existing State licensed safety program.
     The experience of State or local agencies which have begun inspection
and maintenance programs supports the estimates shown in Figure 1 and 2.
Since each program went through a somewhat different development process,
                                     IV-9

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the exact timing of the various parts of the program differ.   However,
in general  they support the time period shown in the charts.   The primary
comments relating to lead time include the following:
     1.   Obtaining legal  authority can be a long drawn out process and
         thus a major time delay.
     2.   In some States locating sites for State owned facilities can
         cause time delays because of land procurement procedures.
     3.   In order to assure smooth implementation, considerable effort
         must be made to maintain interagency cooperation in  cases where
         more than one agency has responsibility for parts of the
         inspection and maintenance program.
                            FEDERAL ASSISTANCE
     The EPA is committed to assisting air pollution control  agencies in
various  ways.  Technical  assistance in developing implementation plans
has been provided to many States in the past several years and will
continue through EPA's Regional Offices.  States have also received
financial assistance through the grants program.  Technical and financial
assistance relating specifically to inspection and maintenance programs
are discussed in more detail in the following pages.
Technical Assistance
     Federal technical assistance for inspection and maintenance programs
through  EPA will be available in several forms.   The appropriate channel
for obtaining technical information or assistance in the area of inspection
                                  IV-10

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and maintenance is through the EPA Regional  Offices Csee Appendix A).
The various forms of technical support that are planned at this time
are itemized and discussed below.
       1.  A periodic newsletter will be published to report on recent in-
           spection and maintenance developments in State or local agency
           experience, EPA demonstration contracts, and other studies.
           The main points of information will be discussed in the newsletter
           with references given for those interested in a more detailed dis-
           cussion on the subject.  The newsletter will serve as an outlet
           for information on other automobile related subjects such as
           retrofit devices, engine tampering, and fuel economy.  The first
           issue should be available by June 1974.
       2.  The Emission Control Technology Division is evaluating objec-
           tives for  an inspection and maintenance evaluation program.
           By requiring mandatory maintenance for those vehicles which
           have emissions higher than allowable, inspection and mainte-
           nance effectiveness can be determined, the service industry's
           capability to handle the  required maintenance can be evaluated,
           maintenance costs  can be  determined, and public reaction to
           inspection and maintenance can be sampled.  While these data
           are very  important, the success of the evaluation program will
           depend  on  the willingness of State agencies to operate an
           inspection and maintenance program according to the program
           requi rements.
                                    IV-11

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3.  Planning is underway for a seminar sponsored by EPA for State
    and local officials on the subject of inspection and maintenance
    programs.  The seminar will provide a forum for EPA to dispense
    recent information and for State and local officials to share
    their experience and information.
4.  The document "Control Strategies for In-Use Vehicles" will be
    reissued with more emphasis on aspects of implementation and with
    recently developed information not contained in the first edition.
    The new information will include a discussion of an evaluation
    procedure for retrofit devices, high altitude emission inspection,
    and State agency experience with specific problems encountered in
    implementing their inspection and maintenance programs.
5.  A team of EPA technical experts will be available to handle re-
    quests for information or  assistance on technical matters relating
    to inspection and maintenance.  The kind of assistance that this
    team of experts could provide would include technical review of
    State inspection and'maintenance plans, recommendations on instru-
    mentation and other  testing equipment, assistance in mechanic
    training programs, testimony on technical questions at public
    hearings, and on-site visits to evaluate technical problems
    with the inspection  and maintenance program.  Requests for
    technical assistance should go through the EPA Regional Offices.
6.  Several  specific reports and studies related to inspection and
                                IV-12

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maintenance are discussed in Chapter VI.
Funding Assistance
      Acquiring adequate funding is an important factor in the develop-
ment of an inspection and maintenance program.  Funding an inspection and
maintenance program is basically the responsibility of the State, and/or
local agencies.
      In general funds are required for two purposes; (1) to provide
capital to start up the program, and (2) to operate and maintain the pro-
gram once it has been started.  The amount of the first item will depend
on three factors; (1) the type of program (State owned lanes or State
licensed garages), (2) the type of emissions test (idle or loaded mode) and
(3)  whether the emissions test is added to an existing safety inspection
or set up independently.  The initial capital can be acquired through
several mechanisms such as issuing bonds or borrowing from the State's
general fund.   In any case an inspection fee can be charged to cover both
the operating and maintenance costs and to pay off the initial investment.
Oregon's system is an example of this method of financing, that is, borrow-
ing the initial capital from the State's general fund and setting the in-
spection fee at a level to cover the operating costs and to pay back the
initial capital.
      The additional cost an air pollution control agency will incur when
setting up an inspection and maintenance program may be included in
the agency's operating budget.  As
                                 IV-13

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part of the agency budget the inspection and maintenance program costs
would be eligible for matching funds through EPA's grant  program to
support air pollution control agencies.   However, since EPA's agency grant
funds are not expected to increase, this funding mechanism will  not be  able
to provide substantial support.  Further information concerning  program
grants can be obtained from the EPA Regional Offices.
     As mentioned in the following  section on training, Federal funds  can
be obtained for inspector and/or mechanic training.  The EPA Regional Offices
have available some Manpower Development and Training Act (MDTA) funds  for
training of technician level people.  Several State and local agencies  in
Colorado, Oregon, and Texas have already used or proposed to use
this mechanism to obtain funds for training of inspectors and/or mechanics
necessary to carry out the inspection and maintenance programs.   Interested
agencies should contact the manpower development officer in their EPA
Regional Office.


                              Training
     An adequate supply of trained inspectors and maintenance mechanics is
necessary in order to successfully implement an inspection and maintenance
program.  This section will examine the importance of inspector and mechanic
training, the steps that the primary inspection and maintenance agency
should take to assure a supply of trained personnel,and some examples of
what is being done in the area of inspector and mechanic training.
                                  IV-14

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     Trained inspectors must be available before the program can become
operational, and trained mechanics are required to properly repair the
rejected vehicles.  The kind of training and magnitude of the training
program required would depend on whether the inspection and maintenance
system is State owned or Stated licensed, and whether an idle or loaded
mode inspection test is used.  In State owned systems the inspection
function is separate from the maintenance function which allows  separate
training programs to be developed.  Generally the professional staff
together with the instrument vendors can put together the necessary
training program for inspectors.  The training program for a loaded
mode test would be more extensive than the training program for  an
idle test, but both of the training programs for inspectors are  rela-
tively simple.  The main objective is to train the inspectors to
operate and maintain the Instruments, perform the test, and make the
proper record of the test results.  The main factor determining  the
magnitude of the inspector training program will be the size of
inspection and maintenance program.  For example, New Jersey has about 69
inspection lanes with one emission inspector per lane.  Other States with
a larger number of lanes will require a substantial number of inspectors.
                                   IV-15

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For example, Arizona's proposed plan calls for 511  employees  most of
whom are inspectors.
     In a State licensed system the personnel  at each station should be
capable of performing both the inspection and the maintenance functions.
Therefore, the training program should be directed towards the maintenance
function as well as the inspection function.  The degree to which the
inspection and maintenance agency can become involved in training of
mechanics under either type of inspection and maintenance system will
depend on several factors including legal authority, personnel and funding
capabilities, the level of expertise in the local auto service industry,
and their initiative.
     The agency responsible for the inspection and maintenance program
should decide early in the planning process the role it will have in the
training program.   In some States an agency, other than the implementing
agency, may  be better equipped to handle  the training program, for example,
the Department of Education.  The particular legislation under which the
agency operates may specify the agency's  role  in the training process.
Another factor to consider is the level of expertise in the local auto
service  industry and the  existence of private  education program.
Several oil  companies have training courses for their dealers.  Garages
may decide  to prepare themselves for future inspection and maintenance
business  by obtaining the necessary training  for their employees.
 In any case the  primary  inspection  and maintenance agency should assess
the need  for mechanic training and  take whatever measures are necessary
to prepare  the  auto service industry for  handling emission repairs.
                                   IV-16

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     EPA is involved in two aspects of the mechanic  training  area  which
can be useful  to the State or local agencies  responsible for  inspection
and maintenance programs.   One is In providing Manpower Development and
Training Act funds for inspector and for mechanic training.   Several  States
are using or plan to use the funds to set up  training programs in  their
States.  The Denver, Colorado program i£jm_ example of this type of program.
A contract was awarded to Colorado State University to develop a training
program and to train 60 persons.  This training program is directed at
training auto mechanic instructors and teachers who will then go back to
their technical institutes, junior colleges,  or other place of employment
to teach the working level mechanics.  The multiplier effect of this method
will  help  spread  the knowledge faster than training the working level
mechanics  directly.  A similar training grant for certified  auto teachers
has  been awarded  to the University to expand the training program  started
under the  first contract.   EPA expects to  gain training materials  and
methods from  the  work  carried out  under these contracts.  These materials
and  methods can then be made available to  others as  training packages.
Agencies  interested  in  using Manpower  Development and  Training  Act funds
for  mechanic  training  programs  should  contact the manpower officer in
their EPA  Regional  Office.
      The  Control  Programs Development Division of EPA  in  Durham,  N.  C.  is
 currently  working on  projects to develop  training programs for  inspectors
                                   IV-17

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and mechanics.   One program with materials has been devleoped and will  be
tested in the Denver mechanics training program mentioned above.   Once
the materials and methods are tested and approved, the training package
will be available for others.  Further study is being given to the need
for developing other training packages for people involved with Inspection
and maintenance at other levels such as supervisors.
     Because of the importance of having well trained inspectors and
mechanics on the outcome of any inspection and maintenance program, the
primary agency should assess the training needs for its program and make
sure that the necessary training is provided.  Who runs the training pro-
gram and how extensive it is will depend on the factors discussed above.
The primary agency will ultimately be responsible for the success of the
inspection and maintenance program, and therefore should make a special
effort to develop adequate training for inspectors and mechanics.
                                 IV-18

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                  Potential  Problems Associated with Inspection/
                             Maintenance Programs

     A variety of approaches can be followed in implementing an inspection/
maintenance program.  The program can be state owned and operated or
licensed to private garages; the inspection can be made while the
vehicle is at idle or under"simulated driving conditions; annual or semi-
annual inspections can be required, etc.  With all of these approaches,
implementing an automobile inspection/maintenance program may result in
a number of problems which should be considered early in the planning
process of such a program.  These problems fall into the following general
areas:
     1.    Legislative or statutory requirements
     2.    Organizational impediments
     3.    Funding or budgetary restrictions
     4.    Labor supply or skill shortages
     5.    Lack of public support
     6.    Lack of data
     7.    Equipment and facility procurement
     8.    Determination of Rejection Rate
     9.    Certification of mechanics
The discussion to follow will provide an explanation of some of the specific
problems associated with implementing inspection/maintenance program.
LEGISLATIVE OR STATUTORY REQUIREMENTS
     The implementation of an inspection/maintenance program requires
statutory authority for its development and operation.  Acquiring this
                                     IV-19

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authority necessitates formal approval  by the State Legislature for a
State opeEated program.  This is not necessarily true for a  program
established by a local agency.  In many instances this approval  is  given
in two phases - the first phase being for a pilot or demonstration, the
latter for the actual program to be implemeneted.  As an example,  in
Colorado, the legal authority for a pilot program was already included
as a part of the Colorado Clean Air Act; once the results of the pilot
are available, the necessary legal authority for the implementation of
mandatory inspection and maintenance must be acquired.  In Arizona, the
State Legislature approved in 1972 the construction and operation  of a
prototype inspection facility; a report containing emission  test data,
inspection station network studies, and specific recommendations regarding
how a statewide mandatory inspection system should be implemented  has
been completed and will go to the State Legislature in 1974.  In many
cases the State legislative body has only minimal technical  knowledge
and little understanding of the actual  requirements necessary for  attain-
ing the air quality standards.  The purpose of the transportation  plan
in helping attain these standards and the necessity for implementing an
I/M program must be appropriately presented to the legislators so  that
their approval will be forthcoming.  Adequate agency preparation may
require many months of work to construct a logical, understandable proposal
     Getting the necessary statutory authority can be a time consuming
task in implementing an I/M program.  This situation necessitates  early
                                   IV-20

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action on legislative approval.   However,  States  may be able to use
an EPA promulgated inspection and maintenance requirement as the
authority to act in implementing a program and thus, avoid time
del ays.
ORGANIZATIONAL IMPEDIMENTS
     As  was discussed earlier, the implementation of an inspection and
maintenance program may involve several  State or local agencies.  Cooperation
between these agencies is essential if the program is to operate successfully.
Having specific agency responsibilities  delineated in the legislative
authority will aid in avoiding controversy over assignment of duties and
enforcement of the program.
FUNDING OR BUDGETARY RESTRAINTS
     Once the legal authority for establishing a mandatory inspection and
maintenance program is acquired, an additional task which may pose problems
remains before actually implementing the program.  This task consists of
getting adequate funding to operate the program.  In many States, convincing
the legislature to fund such a program requires more effort and time than
getting the legal authrotiy.  State legislators may be reluctant to fund
such a program in one area of the State, or the State may not feel adequate
funds are available for such a program.   Time delays of a year or more
may be experienced in getting necessary appropriations, which would extend
the start-up date of the program.  If funding provisions are included in
                                   IV-21

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the enabling legislation, such as that suggested in Chapter IHi  significant
delays can be avoided.
     Location of Federal sources of funding (discussed earlier) may ease
this problem somewhat.  Although some Federal  funding may be available,
it is the responsibility of the State to provide the funds necessary to
implement an inspection/maintenance program.
LABOR SUPPLY OR SKILL SHORTAGES
     The successful implementation of an inspection/maintenance program
requires sufficient qualified staff to operate all  phases of the  program.
Due to the procedure for hiring personnel utilized  by many state  and local
government agencies, the hiring of competent  staff  to aid in implementing
an inspection/maintenance program may pose problems.   In many cases, finding
the qualified personnel  is simple, but getting them on the job may take
three to twelve months due to local government hiring mechanisms.   In a
state operated inspection program, both inspectors  to actually perform the
inspection and qualified staff to calibrate the equipment and verify the
accuracy of the inspection results must be employed.   In Arizona,  approximately
500 people must be employed to operate the state inspection/maintenance
program being considered.

     In the case of state operated inspection  programs individuals with
general skills may be hired as inspectors and  trained to perform  the in-
spections.  Also under a state operated inspection/maintenance program,
the mechanics in the individual  garages who perform the required maintenance
will  require some training in repairing or tuning engines to achieve
                                  IV-Z2

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emission reductions; the development of diagnostic skills in correcting
emission deficiencies is also essential  for accurate, cost effective
repairs.  Development of training programs for these mechanics and for
the inspectors should be considered an integral  part of the inspection/
maintenance planning process and should be included as a necessary step
in implementation of the program.
     In a licensed inspection/maintenance program, the training of
mechanics and inspectors to administer the inspection and perform necessary
maintenance is equally as important as in a state system.  This training
of mechanics may lead to a certification program for mechanics who complete
a specific amount of training for correcting automotive emission problems.
Currently in Colorado, where a licensed system is being considered, the
EPA is funding a pilot program for the training of mechanics in both
diagnosing emission problems and making corrective adjustments.
     In some instances, getting  legislative approval and funding for training
mechanics and inspectors has posed problems.  It becomes apparent, however,
 that lack of trained staff could bring an inspection/maintenance program
to a standstill or  lead to adverse public reaction.  The overall effectiveness
of such a program hinges on  the  ability of those operating the system to
complete the inspections accurately and to perform the maintenance adequately
and efficiently.  Therefore, training of mechanics and inspectors and timely
hiring of personnel are essential in getting the inspection program underway.

LACK OF PUBLIC SUPPORT
     Gaining public support  for  a motor vehicle inspection and maintenance
program may be one  of the more difficult problems associated with implementing
                                    IV-23

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such a program.   In areas where the public is in favor of an I/M program,
legislative approval is much easier to acquire.   For example, in Arizona,
the Speaker of the House has been strongly in favor of the I/M program for
Phoenix-Tucson;  he has ellicited great public support for this measure.   As
a result, the measure will in all likelihood gain legislative approval this
year.  A public  information program is under consideration in Colorado to
get the public acquainted with the inspection/maintenance program.
     One of the  prime reasons for the public concern stems from the fact
that individuals fear being overcharged for mandatory maintenance or paying
excessive fees for simple tune-up functions.  To prevent these events from
occurring, some  States are attempting to develop detailed diagnostic
techniques for use by mechanics in detecting deficiencies.  For example
in Arizona an innovative diagnostic tool may be employed.  If an auto fails
the motor vehicle inspection, the driver may take the car to another lane
where an electronic device will identify where his problem lies, the driver
then goes to his garage and has the specific deficiency corrected.  Other
States are setting up a detailed checklist of items which may cause specific
deficiencies so that diagnosis of problems can be handled more efficiently.
Proper training of mechanics will also aid in avoiding unnecessary maintenance
work.
     As an added preventive measure, the public should have some simple means
to make complaints regarding the inspection he undergoes or the maintenance
he has performed in a garage.  A "hot line" for making complaints or suggestions
or a return card to report problems would provide the individual with a
readily available means of making known to the proper agency officials
                                    IV-24

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his specific situation.   The New Jersey Department of  Environmental
Protection is considering a similar means  of monitoring  complaints.
LACK OF DATA REGARDING INSPECTION/MAINTENANCE PROGRAMS
     Another area of concern in establishing an inspection/maintenance
program is the gathering of adequate data  upon which  to  base a  decision
relative to the type of program to implement and the  emission reduction
to be achieved.  All of the data currently available  on  pilot projects
or research studies in this area were obtained from tests  on automobiles.
The data are not directly applicable to medium-duty vehicles, heavy-duty
vehicles, diesels, turbines or light-duty  trucks. Furthermore, most of
the vehicles used in the completed studies have been  pre-1970 vehicles and
none have been equipped with advanced control systems  which will  be  a
major factor in the total mobile source pollution levels at the time that
the inspection/maintenance programs are expected to be implemented.
     Some areas are undertaking pilot or demonstration inspection/maintenance
programs on a small scale to provide actual data for  decision making relative
to the type of inspection to utilize, the  operation and enforcement of the
program, the kind of results to expect, and the costs.  Some States  may
be hesitant to undertake an inspection and maintenance program  without
much more background data than is now available.  Nevertheless, States
must gather what information is available  and proceed with implementation
in order to meet compliance dates.
                                   IV-25

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     One specific area where lack of data is posing a problem is in
determining the rate of deterioration of the vehicle to before-maintenance
emission levels.  The emission reductions attributed to inspection/
maintenance are those recorded immediately after the vehicle maintenance
phase of such a program.  If the vehicles are allowed to deteriorate to
their pre-tuned emissions level before they are re-inspected and re-tuned,
the time averaged emissions will be considerably less than those measured
initially.  Since definitive data on the shape and period of the deterioration
curve is not available, a straight line deterioration to the pre-tuned
condition in one year has been used for estimating purposes.  This approach
was used in Appendix N of the Requirements for Preparation, Adoption and
Submittal of Implementation Plans (40 CFR 51).  The result of this assump-
tion is that the time-averaged emissions reductions are one half of the
initial reductions achieved.  Actual test data will be necessary to determine
what actual average deterioration rates will be.
EQUIPMENT AND FACILITY PROCUREMENT
     Procurement of emission inspection equipment may pose some problem in
implementing an inspection/maintenance program due to the purchasing pro-
cedures employed in State and local government agencies.  At present, there
appears to be no problem regarding adequate supply of the necessary testing^
equipment from the various manufacturers.  The problem maCjTdesirejas a result
of lengthy procurement process encountered in many state an'd"Tbcal agencies.
                                    IV-26

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For example, the State of Arizona estimates it will  require 12 months
to procure the necessary equipment for the inspection phase of the state-
owned program.  Much of this time is required to process the orders for
the equipment.
     In the case of testing facilities, a franchise inspection/maintenance
system presents no problem as individual garages will be inspected and
approved to administer the inspection.  No serious facility problems are
anticipated in States where, the emission inspection is to be completed
in parallel with a State operated inspection program.  If new facilities
must be purchased and constructed for the inspection/maintenance program,
considerable time must be allowed in the State's plan to allow for acquiring
sites, designing inspection stations, construction of stations, etc.  This
may pose a serious time delay.
DETERMINATION OF REJECTION RATE
     The potential for initial emission reductions as a result of an
inspection/maintenance program will depend upon the accuracy of the
inspection procedure and the level at which emission standards are set.
The level of the emission standards determines what the inspection
rejection rate will be.  This rejection rate may pose problems if it is
extremely high as large numbers of vehicles are likely to fail.  This
may lead to adverse public reaction.  Of course, the more stringent the
emission standards and the higher the rejection rate, the greater the
emission reduction allowed for this strategy will be.
                                   IV-27

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     One means of initially avoiding the problems of an extremely high
rejection rate is to set emission standards at a fairly high level  for
the initial year and reduce the allowable emissions each year.  In this
way, the more restrictive standards would be achieved over a period of
several years, but people would gradually become accustomed to the
corresponding higher rejection rates.
CERTIFICATION OF MECHANICS
     If training of mechanics to corfcect emission deficiencies is provided
by a State or local  agency as part of an inspection/maintenance program,
some consideration may be given to certification or licensing of these
mechanics.  This would provide consumers with some assurance that the
mechanic has had adequate training to perform the maintenance required to
pass the vehicle inspection.  In a state operated program, the mechanics
doing the necessary maintenance might receive a certification or license
if they complete the training being provided or pass a qualifying test.
     In a licensed inspection/maintenance program, state certification
of the garage as having the necessary facilities and equipment to perform
emission inspections and required maintenance is essential.  In addition,
assurance that the garage has the qualified staff to complete the inspections
and perform the maintenance must be provided.  Certification of the
individual mechanics as being capable of performing emission repairs may
                                  IV-28

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be a part of this assurance that the garage has qualified staff to
perform necessary inspection and maintenance.
     The certification or licensing of mechanics participating in
inspection maintenance programs may pose potential  problems with regard
to implementation and monitoring of the certification program.  This
would require additional work on the part of the agency operating the
inspection/maintenance program.  The certification might create an adverse
reaction among mechanics unless training could be provided on an equal
basis to all.  The certification does, however, serve as a consumer protection
measure and provide the operating agency with a lever to insure that if
quality maintenance work is not done, certification will be revoked.  The
type of certification or licensing procedure to be followed depends on
the specific inspection/maintenance program under consideration.
                                    IV-29

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                                CHAPTER V
                        MONITORING AND  REPORTING
                               Monitoring

     Once an inspection and maintenance program has  been  implemented,  it
is essential that the program be monitored and information  reported  to
Federal, State, and local  agencies as appropriate.   As  noted  in  Chapter II,
emission reductions achieved through an inspection and  maintenance program
can range up to 15 percent for hydrocarbons and up to 12  percent for carbon
monoxide, depending on the initial rejection rate, and  the  type  of program
selected.  I ^^rf^Dy|Depo§/s i bl e to detect thjfrse reductions through measurements
in air qualit^rjtfherefore, t& determine the effectiveness of  a program and the
adequacy of operating and maintenance procedures, data  must be collected
at the inspection station.  The data collected should be  sufficient, as a
minimum, to allow determination of the actual pass/reject rate and the
amount by which emissions are being reduced from  the vehicle population.
Rejection Rate
     The rejection rate can be easily determined.   All  that is required is
that the inspector be given a signal as to whether  a vehicle's emissions
are above or below the established emission limitation.  Such a  signal is
normally designed into testing equipment, either through  a dial  indicator
which shows the actual pollutant concentration measured,  or through a
simple  lighting system which is triggered when the measured concentration
is either above or below  the standard.  Usually both such signal methods
are available  on testing  equipment,  it will be necessary to record pass/
fail information for future analysis and reporting.   This can easily be
done at the time the inspection takes place by having the inspector (or
                                     V-l

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other appropriate person)  record the desired  information.   Figures V-l
and V-2 provide an example of a format for recording  pertinent  vehicle
information.  Of course, data collection forms can  be designed  for
recording the type and amount of data desired.
     The rejection rate can provide very useful information.   It can
indicate whether or not the operation of all  inspection stations are
                                   V-2

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                        FIGURE V-l
      VEHICLE EMISSION INSPECTION - IDLE METHOD
                 VEHICLE INFORMATION
Year
Make
Model
No. of Cylinders_
Serial No.
            Engine Displacement	cubic inches
Carburetor:
        Barrel, or Other
            (F.I. Etc.)
Transmission:  Automatic	  Manual	  No. of Shifts_
Date	Odometer Reading	
                 EMISSION INFORMATION
VEHICLE
YEAR
ALL
•
1967
AND
BEFORE
1968
AND
LATER
SUBJECT
ENGINE RFM
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
IDLE
Max. Mfrs. Specs + 100
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
OPEN THROTTLE
2400 +.100
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
                             V-3

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     VEHICLE EMISSION INSPECTION - LOADED METHOD
                 VEHICLE INFORMATION
Year
Make
Model
No. of Cylinders
Serial No.
            Engine Displacement	cubic inches
Carburetor:
        Barrel, or Other
            (F.I. Etc.)
Transmission:  Automatic	  Manual	
Date	Odometer  Reading
                               No. of Shifts
                 EMISSION INFORMATION
VEHICLE
YEAR
1967
AMD
BEFORE
1968
AND
LATER
POLLUTANT
-rC-
CARBON MONOXIDE
-HC-
HYDROCARBONS
-CO-
CARBON MONOXIDE
-HC-
HYDROCARBONS
IDLE
Max. 9.0%
Max. 1200 PPM
Max. 7.0%
Max. 600 PPM
LOW CRUISE
Max. 5.5%
Max. 900 PPM
Max. 4.25%
Max. 450 PPM
HIGH CRUISE
Max. 4.5S
Max. 900 PPM
Max. 3.75%
Max. 450 PPM
                             V-4

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consistent.  Too high or too low a rejection rate can mean  that a station
is not following proper testing procedures,  equipment is  not functioning
properly, vehicles tested at a particular station are above or below
average emitters, or a combination of these causes.   The  first two of
these causes can be corrected through proper program management.  The
third cause is an additional indicator itself.
     If proper procedures are being followed and equipment  is functioning
as it should, then a high or low rejection rate may  reflect the adequacy
of maintenance being performed on the vehicles.  This is  especially true
when vehicles are retested after being rejected.  The adequacy of main-
tenance can also be determined in other ways.
     If rejected vehicles are required to undergo a  retest  before being
allowed to operate, the number of times a vehicle returns for retest will
indicate that corrective maintenance is either  good  or poor.  A vehicle
owner who is required to have repeated maintenance on his vehicle will  not
undergo the cost and inconvenience long before  complaining  to the testing
officials.  If a high percentage of rejected vehicles pass  on the first
retest, then this is an indication that corrective maintenance is being
properly diagnosed and performed.  Regardless of whether  the indication
is that maintenance is good or poor, the agency should investigate to
determine the cause.  If maintenance is good, the diagnosis and treatment
methods used can be passed on to other maintenance facilities, incorporated
into a certification program, and/or used in mechanic training programs.
If the maintenance is poor, the agency will  want to   correct the situation,
for the maintenance function is critical  to  the success of  the inspection
and maintenance program.
                                     V-5

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Emission Reduction
     The emission reduction from a vehicle population is the key indicator
that nn inspection and maintenance program is achieving the desired success
(see Figure V-l and V-2  for an example method of data collection).  The
most accurate method of  quantifying emission reductions is through surveil-
lance using the Federal  test procedure.  However, sufficient estimates of
emission reductions can  be obtained by measuring pollutant concentrations
in exhaust gases using an idle mode or loaded test.  An agency may wish
to record, summarize, and analyze pollutant concentrations from each vehicle
test.  This procedure would provide the most accurate results.  However,
if an agency  lacks sufficient manpower or data processing facilities, a
portion of the vehicle population can be sampled at various intervals to
provide sufficiently accurate estimates of emission reductions.  Of course,
the accuracy  of these data will be affected by the size of the sample, and
its representativeness of the population, and the type of emission test
conducted  (idle mode tests provide the least accurate results).  Proper
statistical procedures should be used to determine the sample  size and
vehicle mix  (age and weight class) of the sample.  New Jersey  is instituting
such a monitoring system for their idle inspection and maintenance program.
     A surveillance  team is maintained in the field to visit each inspec-
tion station once a month.   During these visits,  testing equipment is
calibrated, and for a period of two hours,  concentrations of carbon monoxide
and hydrocarbons from a sample of from 50 to 60 vehicles are recorded.   The
vehicle year, make, and model, any test problems  encountered,  and whether
a  vehicle is being retested are also recorded.   Data on about 2,500
vehicles  are obtained per quarter.   A computer program provides a distri-
bution of pollutant concentration by vehicle age,  weight class, and by
make and  model.  Rejection  rates are also computed.   Through study  of
                                      V-6

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these data,  trends can be observed and  the overall  effectiveness  of
the program determined.
State Operated vs. State Licensed Programs
     The above discussion of the surveillance team  concept applies most
appropriately to a State operated program where there are a limited
number of inspection stations located over a relatively small  geographical
area, and where a large volume of vehicles are tested at each station.
The surveillance team concept would not be practical  for a State licensed
inspection and maintenance program where there would  be a low rate of
inspection at a large number of stations spread over  a wide geographical
area.  Licensed stations must be required to report rejection rate and
emissions data either to the licensing agency or other appropriate agency.
This requirement could be part of the licensing agreement.
     Licensed facilities would normally perform maintenance as well as
vehicle testing.  Thus, it would be relatively easy for the "before" and
"after" emission data to be collected on rejected vehicles.  Some problems
may be encountered in collecting these data if a majority of owners of
rejected vehicles elect to have maintenance and retesting done other than
where the initial test was conducted.  This may occur if it becomes common
knowledge that maintenance at a particular licensed station is poor.
     An additional step in the monitoring system can be  included to
survey the testing and maintenance functions of licensed stations.  This
can be accomplished through direct calibration of testing equipment by
agency personnel at periodic intervals, and through calibrated vehicles
with known maladjustments.
                                     V-7

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                                Reporting
     Operation of an inspection and maintenance program will  involve
reporting information to various levels of State and local  agencies and
EPA.  Development of data collection and analysis procedures  and design
of the information reporting mechanism should be carried out  early in
program development phase to insure that information flow both vertically
and horizontally through the managing and/Or participating agencies is
smooth.
State and Local Agency Reporting Requirements
     The State and local agency reporting requirements will vary in de-
tail and content between States and according to the type of  inspection
and maintenance program implemented.  As suggested by the discussion on
monitoring, reporting requirements for a State owned and operated program
would be somewhat more simplified than for a program operated through State
licensed inspection and maintenance facilities.  This primarily results
from the requirement to report information "internally" between and through
State and local agencies who, in all probability, already have established
lines of communication.  In addition, there would probably be more control
over agency personnel as regards collecting and analyzing data and sub-
mitting reports in a timely manner.
     For licensed facilities, reporting requirements must be  levied on
private businesses.  Thus, control over the accuracy of data  collection
and timely submittal would be limited.  Of course, the owner  of a facility
whose success depended primarily on operating under a license in good
standing, would probably be more prudent in fulfilling reporting require-
ments.  Data reporting for inspection and maintenance programs which, are
                                    V-8

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incorporated with existing safety inspection programs should be less
complicated if some form of reporting exists where owners and operators
are already in the habit of collecting and submitting information.
Federal Reporting Requirements
     There are two separate cases in which a State and/or local  agency
may be required to submit data to EPA.  If a State has an approved  imple-
mentation plan which contains an inspection and maintenance program,
emission data generated by the program, along with other emission and
air quality data must be submitted to EPA, through the appropriate
Regional Office (See Appendix A), in the semiannual  report required
by EPA regulations (38 FR Part 51, Section 51.7, Para. (B)).
     If a State is required to implement, operate, and enforce an inspec-
tion and maintenance program, the State must submit vehicle emission  data
resulting from the program on a quarterly or semiannual basis in accordance
with the promulgated reporting requirements.  These data must be submitted in
the format prescribed by Appendix M to 38 FR Part 51, which is shown  here as
Table V-l.  The time periods in the first column represent the quarter or
semiannual period for which the data are being reported.  The subregion  can
represent an inspection station at which data are collected, a county in which
                                                                 i
data are collected, or any other geographical area which is specifically
defined.  The choice of subregion selection belongs to the State or local
agency.  Emission data collected while the inspection and maintenance
program is operating are entered in the second column opposite the
appropriate time period and subregion.  Vehicle emissions that would
have occurred had the program not been in operation are entered in  a
similar manner in the third column.
                                    V-9

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     States required to implement an inspection and maintenance program
must submit actual per vehicle emission data to EPA.  Analysis of these
data will indicate the effectiveness of the inspection and maintenance
program, and will also assist EPA in handling the warranty and recall
provisions of the Clean Air Act.
     Emission  data are submitted quarterly or semi annually for that
period only.  At the end of a calendar year, data are summarized for all
quarters or seminannual periods during which data were collected, and
this summary is also submitted.  Thus, at the end of a calendar year,
the reporting agency will submit two reports, one covering the last
quarter or semiannual period for the year, and one summary for the year.
                                Table V-l
                Inspection and Maintenance Emission Data
                                    (Specify Pollutant Here)
                                    With             Without
                               Control Measure   Control Measure
Time Period 1
  Sub region 1
  Sub region 2
  Sub region 3
Time Period 2
  Sub region 1
  Sub region 2
  Sub region 3
                                    V-10

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     As mentioned previously,  dissatisfaction with  poor  maintenance and
high costs can be expected to  surface through motorists'  compliants.
An effective procedure for soliciting and receiving such complaints, and
following up with solutions to legitimate problems  can greatly enhance
the effectiveness of the entire program.
                                    V-12

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                         Chanter VI


             Federal and State Programs Related

                  to Inspection/Maintenance



     Over the past seven years, a variety of programs on

inspection and maintenance programs have been sponsored hy

Fedrral am" State governments, and a number of new programs have

heen starter! recently.  This chapter wil] summarize pertinent

proaror.s, past and present.


        Programs Sponsored by the Federal Government

Fast Program^

     In order to collect information for use by the States in

establishing inspection and maintenance programs, several

experimental studies have been conducted over the past four years.

The results of those studies have been made available to the

States and other Interested agencies through the Federal Register,
                     (1)
a Control Strategies    document, the reports of the Coordinating
                                            (2)
research Council APP7-C CAPE 13-68 committee   , and various

contacts between FPA personnel and State and local pollution

control aqencJes.

     Tps/^J^ Program;  The purpose of this program conducted at

F.PA in Ypsilanti, Michigan and Los Angeles, California was to

r"oterrine the r'eareo of correlation between the emissions durino

scvrra] rf tbo romp'on inspection cycles and those during the 1975

Federal Tent Procedure which is considered to be the only test

th^t is capable of predicting air duality effects from vehicle


                               VI-1

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emissions.  In addition, the study provided data on the cost and
effectiveness of mandatory maintenance programs.
     Short Cycle Study:*3' The purpose of the Short Cycle Study was to
evaluate the costs and effectiveness of idle tests and the Clayton Key-
mode procedure.  A full report of the study including a comparison of the
Key mode test, the idle test, and Federal Short Cycle test and the 7-mode
test will be available in the near future.
     High Altitude Study/4) This study, sponsored by the EPA Region VIII
Office, compares the costs and effectiveness of idle and keymode  testing
at high altitudes.  The results of the testing which was conducted in
Denver, Colorado are in general agreement with those obtained in  other
studies at low altitudes.
     Cape 13-68 Study.  ' The primary purpose of this Coordinating Re-
search Council Inc. study was to develop a computer model which could
be used to predict the air quality effects of various inspection and
maintenance procedures.   In support Of the computer model, experimental
studies were conducted to quantify typical values of many of the parameters
involved  in the computation.  Among the  parameters studied were:
     1.   Effect of parameter adjustment  on emissions,
     2.   Inspection station costs,
     3.   Demographic data on Los.Angeles and Detroit,
     4.   Emission baseline data on Los Angeles  and Detroit,
     5.   Engine parameter data on Los Angeles and Detroit,
     6.   Typical  repair costs,
     7.   Parameter and  emission deterioration rates,
     8.   Service  industry diagnostic and repair effectiveness, and
     9.   Emission measuring  instruments  comparison.
                                   VI-2

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The results of this three year study are now available in a multi-
volume report from CRC at Thirty Rockefeller Plaza,  New York,  New York 10020.
     Evaluation of Post '74 Prototypes:   The purpose of this task is to
obtain information on-the applicability of present short cycle (e.g. steady
state, idle, and keymode) tests to post-1974 light-duty vehicles.  Proto-
type versions of post-1974 light-duty vehicles will  be subjected to the
1975 Federal test procedure and additional short cycle tests.   Particular
attention will be paid to the applicability of the cycles, instruments, and
procedures to these vehicles.
     Programs Sponsored by State and Municipal Governments
Arizona
     Two pilot emission inspection stations capable of running loaded mode
tests are being set up.  One station will be in Phoenix and the other in
Tucson.  The State is also experimenting with an instrument for diagnosing
malfunctions leading to high emissions.   A State wide inspection and main-
tenance program is planned eventually.
California
     The State Bureau of Automotive Repair is presently running an inten-
sive program to certify hydrocarbon-carbon monoxide instruments for
repair garages.  These will be required in all Class A garages by July,
1974.  The California Highway Patrol presently spot checks vehicles,
with an idle test as part of their random sample safety inspection pro-
gram.  Vehicles which fail are sent to Class A garages for correction.
A new State law requires a loaded mode test and will result in an inten-
sive development program.
                                   VI-3

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     T'T Bureau of Automotive Fepair 3 K planninrr  to establish  a



pilot inspection station in Riverside County to run loaded  mode



p^iif^-ion t.pst.s.  Vehicles von Id ho tested once a  voar.   If  a



vehicle foiled the test, it v/ill be referred to a a certified  and



licensed Clriss A garage for needed repair.  A vehicle will  not



have to return for a second inspection after the  repair  has been



made.  Idle emission tests vil] be performed randomly by the



Ilighwav Patrol as nart of its on-the-road safety  inspection prooram.



If a vehicle fails this test at any time, it must go back to a



Class * onrane for repair.  California plans to first spread



tho pronrar to the counties of southern California after the



completion of the pilot pr iran and then to the entire State.



Colorado




     The state has rur a proqram to determine the effect of altitude



on enissjor.s and at what operatina conditions vehicles should  be



set to ir,inim.ize emissions.



Illinois




     The citv of Chicano has set up low budget emission  inspection



s tat Jons.  The procfram is in a data gathering phase at present.



Little is being done by way of maintenance and rrpair.   There  is



sore interest in spreading the program to all of Cook County.



;.'ew Jersey




     MJ three safety inspection facilities have  been performing



an idle test for carbon monoxide and hydrocarbons since  July,  1973.



Tnpair and retestina of rejected vehicles was voluntary.  Beginning



in February ]974, rejecter! vehicles must be repaired and retestec1



until they pass inspection.  TTie State has a continuing  program




                               VI-4

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to certify instruments for measuring hydrocarbons  and  carbon  monoxide
for use by garages and dealers.   The present standards fail about  10 percent
of the vehicles which are tested.  More stringent  standards will  be
adopted within a year.  The State is developing a  loaded mode CVS  test
for mass emission measurement to eventually replace the idle  test  currently
used.  In the past the State conducted extensive programs on  emissions
from used vehicles, studying effectiveness of short cycles, and effective-
ness of repair in reducing emissions.
New York
     The State is operating a pilot program for upstate cities employing
mobile inspection units.  They collect emission data primarily in
shopping centers.  Several thousand vehicles have  been tested so far.
New York City has an active development program for trucks and buses.
This is the only research program now being run on inspection and  main-
tenance of heavy-duty vehicles.
Oregon
     The State legislature appropriated one million dollors for an
inspection and maintenance program which will be used to set  up and
operate prototype inspection stations.  The State  currently favors a
loaded mode emission test.
Washington, D. C.
     The District has one inspection lane with a dynamometer  and
analyzer for conducting loaded mode tests.  Additional lanes  will
be equipped by March, 1974.  They are collecting only emission
data now.  No maintenance program has as yet been  established.
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                         PEFFRF.NCFS
1.   'Control  Strategies for In-Uso Vehicles," U.S.
    rnvironnertal Prctpction Agency, MSAPC, November, 1972.

2.   TPIT pwstems Croup/Scott research Laboratories, APFAC
    Prnn^ct CAPF 13-68,"A Study of the Feasibility of
    f'flp
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                                APPENDIX  A

                     ENVIRONMENTAL PROTECTION AGENCY

                            REGIONAL OFFICES
     REGION
     STATES/TERRITORIES
Environmental  Protection Agency
Region I
John F. Kennedy Federal Bldg.
Boston, Massachusetts  02203

Environmental  Protection Agency
Region II
26 Federal Plaza
New York, New York  10007

Environmental  Protection Agency
Region III
Curtis Bldg.,  6th & Walnut Sts.
Philadelphia,  Pennsylvania  19106

Environmental  Protection Agency
Region IV
1421 Peachtree Street
Atlanta, Georgia  30304

Environmental  Protection Agency
Region V
1 North Wacker Drive
Chicago, Illinois  60606

Environmental  Protection Agency
Region VI
1600 Patterson Street
Dallas, Texas   75201

Environmental  Protection Agency
Region VII
Kansas City, Missouri  64108

Environmental  Protection Agency
Region VIII
Lincoln Tower  Bldg.
1860 Lincoln Street
Denver, Colorado  80203
Connecticut, Maine,
Massachusetts, New Hampshire,
Rhode Island, Vermont
New Jersey, New York,
Puerto Rico, Virgin Islands
Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia
Alabama, Florida, Georgia,
Kentucky, Mississippi,
North Carolina, South Carolina,
Tennessee

Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
Arkansas, Louisiana,
New Mexico, Oklahoma,
Texas
Iowa, Kansas, Missouri,
Nebraska
Colorado, Montana,
North Dakota, South Dakota,
Utah, Wyoming
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     REGION	STATES/TERRITORIES

Environmental Protection Agency     American Samoa, Arizona,
Region IX                           California, Guam, Hawaii,
TOO California Street               Nevada
San Francisco, California  94111

Environmental Protection Agency     Alaska, Idaho, Oregon,
Region X                            Washington
1200 Sixth Avenue
Seattle, Washington  98108
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                                APPENDIX  B

                                GLOSSARY

1.   Inspection and Maintenancne Program - A program to reduce  emissions
from in-use vehicles through identifying  vehicles  that need  emissions
control related maintenance and requiring that maintenance be  performed.
2.   Emission Inspection Program - An inspection and maintenance  program
in which each vehicle is subjected at specified intervals to a test of
its emissions under specified conditions.  The emission levels are
compared with a standard established for  the vehicle class.   If  the
emissions are higher than the standard, the vehicle is failed  and must
be adjusted or repaired to bring its emissions into compliance with the
standard.
3.  Loaded Mode Test - An emission inspection program which  measures
the exhaust emissions from a motor vehicle  operating under  simulated
road load on a chassis dynamometer.
4.  Idle Test - An emission inspection program which measures the exhaust
emission from a motor vehicle operating at  idle.  (No motion of  the rear
wheels).  A vehicle with an automatic transmission may be in drive gear
with brakes applied or in neutral gear.
5.  Key Mode Test - A loaded mode test in which exhaust emissions are
measured at high and low cruise speeds and at idle.  The cruise  speeds
and dynamometer power absorption settings vary with the weight class of
the vehicle.  The dynamometer loading in the high cruise range is higher
than normal load  in order to more effectively expose malfunctions leading
to high emissions.
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6.  Light-Duty Vehicle - A motor vehicle designed  for highway use of
less than 6000 pounds gross vehicle weight.   Further distinctions are
sometimes made between light duty automobiles and  light duty trucks
such as pickup trucks.
7.  Chassis Dynamometer - A machine equipped with  two parallel rollers
which support the rear wheels of a motor vehicle.   When positioned on
the dynamometer the vehicle may be "driven"  to simulate the loadings the
engine would experience when the vehicle is  operated on the road.  A
power absorption unit is connected to the rollers  to simulate the
loading from the various sources of fluid and mechanical friction present
during road operation.  Weights can also be coupled to the rollers to
simulate the inertia! effects of vehicle mass during acceleration and
deceleration.
8.  Positive Crankcase Ventilation - A system designed to return blow-
by  gases from the crankcase of the engine to the intake manifold so that
the gases  are burned  in the engine.  Blow-by gas is unburned fuel/air
mixture which leaks  past the piston rings into the crankcase during the
compression and  ignition cycles of the engine.  Without positive crank-
case  ventilation these  gases, which are rich in hydrocarbons, escape
to  the atmosphere.
9.  Transportation Control  Strategy - The sum total of all transportation
control measures used in an area to reduce  emissions of air  pollutants
from  transportation  sources.
10.  Transportation  Control Measure - Any measure that  is directed  toward
reducing  emissions of air  pollutants from transportation sources.   Examples
of  measures  include  reducing vehicle use, changing  traffic flow  patterns,
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decreasing emissions from individual  vehicles, through inspection  and
maintenance or retrofit, and altering existing modal  split patterns
(e.g. getting people to use buses or  car pools instead of individual
cars).
11.  Vehicle Emissions Standard - A specific emission limit allowed  for
a class of vehicles.  The standard is normally expressed in terms  of
maximum allowable concentrations of pollutants (e.g.  parts per million).
However, a standard could also be expressed in terms  of mass emissions
per unit of time or distance traveled (e.g. grams per mile).
12.  Initial Failure Rate - The percentage of vehicles rejected because
of excessive emissions of a single pollutant during the first inspection
cycle of an inspection and maintenance program.  (If  inspection is con-
ducted on more than one pollutant, the total failure  rate may be higher
than the failure rates of any single  pollutant,)
13.  Mandatory Maintenance Program -  A special case of an inspection and
maintenance program which requires each vehicle,  regardless of its emis-
sion level or mechanical condition, to have specific  maintenance operations
performed at specified intervals.  There is no inspection phase to deter-
mine what maintenance is necessary.  The appropriate  maintenance is  explicit-
ly specified for each type of vehicle.
14.  Parameter Inspection Program - An inspection and maintenance  program
in which each vehicle is subjected to a sequence  of diagnostic tests which
evaluate the mechanical condition of  various emission related systems or
components and determine if malfunctions or maladjustments are present.
Vehicles showing measurements outside acceptable  tolerance ranges  are
failed and required to have corrective maintenance performed.
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15.  Rejection Rate - The percentage of total vehicles tested in an
inspection/maintenance program in a given time period that fail inspec-
tion and are required to have maintenance performed.
16.  Heavy-Duty Vehicle - Any motor vehicle designed  for highway use
which has a gross vehicle weight of more than 6000 pounds and less than
10,000 pounds.
17.  Medium-Duty Vehicle - Any motor vehicle designed for highway use
which has a gross vehicle weight of more than 6000 pounds and less than
10,000 pounds.
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