United States
Environmental Protection Agency
Office of Air and Radiation
Washington, DC 20460
March 1993
Air

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Table of Contents
Page
51.350	Applicability	1
51.351	Enhanced I/M Performance Standard	2
51.352	Basic I/M Performance Standard	3
51.353	Network Type and Program Evaluation	5
51 354	Adequate Tools and Resources	7
51.355	Test Frequency and Convenience	8
51.356	Vehicle Coverage	9
51.357	Test Procedures and Standards	10
51.358	Test Equipment	11
51.359	Quality Control	12
51.360	Waivers and Compliance Via Diagnostic Inspection	14
51.361	Motorist Compliance Enforcement	15
51.362	Motorist Compliance Enforcement Program Oversight	19
51.363	Quality Assurance	21
51.364	Enforcement Against Contractors, Stations and Inspectors	23
51.365	Data Collection	24
51.366	Data Analysis and Reporting	25
51.367	Inspector Training and Licensing or Certification	28
51.368	Public Information and Consumer Protection	30
51.369	Improving Repair Effectiveness	31
51.370	Compliance with Recall Notices	32
51.371	On-road Testing	32
51.372	State Implementation Plan Submissions	33
51.373	Implementation Deadlines	34

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I/M SIP REVIEW CHECKLIST
Instructions for Reviewers
1)	Review the SIP
r
2)	Then answer each of the numbered questions (and their sub-questions) in the checklist
by entering Yes, Arguable, No, or NA in each blank provided. For arguable cases and
other situations requiring more explanation, attach labeled comments as needed.
2) After answering the questions for each section, answer die capital A and B questions.
4)	On the bottom of each page, indicate whether the SIP meets the requirements of the
Clean Air Act and the I/M rule, as discussed on that page.
5)	Then complete die sections below
Background
State: 	
List names of urban areas (or MSAs in the OTR) covered by this checklist:
Overall Findings
	 Does the SIP include all elements required by the I/M rule and the Clean Air Act?
	 Are all portions of the SIP approvable?
Discussion
Reviewers
Date

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Introduction
Tliis checklist has been developed by EPA to assist states in the development of
Inspection/Maintenance (I/M) State Implementation Plans (SIPs) as required by the 1990 Clean Air Act
and the November 5, 1992 I/M rule. EPA requests that States use the order suggested by the checklist
in developing the SIP In order for EPA to approve an I/M SIP, all answers to the questions in the
checklist should be "yes" or not applicable ("NA"). There are entire sections of the checklist that are
not applicable to basic areas, such as on-road testing; and only one of the performance standards may
apply in a given state (although states with both basic and enhanced areas that do not choose to do
enhanced in all areas would need to address both standards). In cases where the question does not
distinguish between basic and enhanced areas, one can assume it applies to both. Consult the I/M rule
if further clarification is needed. "No" answers mean the SIP is not approvable. Specific questions
which may be "not applicable" in either basic or enhanced areas include requirements in:
51 351(B)(2) applicable to areas using alternative means, such as vehicle scrappage, to meet the
performance standard; 51.353(B)(3) applicable to areas that the Administrator has determined do not
need NOx reductions; 51.353(B) concerning test-and-repair programs; 51.361 concerning
enforcement mechanisms other than registration denial; and 51.356(B)(2) concerning fleet self-
testing. In the case of basic areas opting up to enhanced programs, i.e., those meeting the enhanced
performance standard, all enhanced requirements will apply except for the requirements for a $450
expenditure for waivers and on-road testing. EPA will use this checklist to review the plans required
to be submitted November 15, 1993. States are invited to submit a completed checklist along with the
SIP including page number references for each applicable question. It should be noted, however, that
the I/M rule and the Clean Air Act requirements must be met and will be relied on for deciding whether
a plan is approvable, not the strict wording of the checklist. The checklist cannot change or interpret
the rule or Act. For further guidance, see the full text of the I/M rule or contact your Regional Office.

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Applicability
Are all required elements present in this portion of the SIP?
1	Does the SIP describe the areas that are required to implement I/M?
2	Does the SIP include legal authority or rules which establish geographic
boundaries for the program?
Is this portion of the SIP approvable?
1.	Are subject areas required to implement enhanced I/M?
a.	Is enhanced I/M required in all MSAs with a 1990 population of 100,000
or more in an ozone transport region?
b.	Is enhanced I/M required in all serious or worse ozone areas with a 1980
urban population of 200,000 or more?
c.	Is enhanced I/M required in all carbon monoxide nonattainment areas with
a design value 12.7 ppm or greater and a 1980 urban population of
200,000 or more?
d.	Is enhanced I/M required in urban portions of 50,000 or more as defined
by the 1990 Census that are part of a multi-state urbanized area subject to
enhanced I/M?
2.	Are subject areas required to implement basic I/M?
a.	Is basic I/M required in marginal ozone areas and carbon monoxide areas
that were either required to be or actually were in the SIP on 11/15/90?
b.	Is basic I/M is required in all moderate ozone areas that contain one or
more urbanized areas?
c.	Is basic I/M is required in all serious or worse ozone area with a 1980
urban population of less than 200,000?
d.	Is basic I/M required in urban portions of 50,000 or more as defined by
the 1990 Census that are part of a multi-state urbanized area subject to
basic I/M?
3.	Does the program include sufficient geographic coverage?
a.	Is enhanced I/M required in the entirety of each MSA county with a
population density of 200 persons per square mile or more, based on the
1990 Census in areas required as part of an ozone transport region?
b.	If counties within the MSA with population densities of less than 200
persons per square mile are excluded, is at least 50% of the MSA included
in the program?
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c Does the I/M program cover at least the number of people in the subject
urbanized area(s) based on the 1990 Census, m areas required not as pan
of an ozone transport region?
4 Does the SIP include legal authority requiring or allowing operation of the I/M
program through the applicable attainment date?
5. Does the SIP include a list of the ZIP codes of all areas covered by I/M?
51.351 Enhanced I/M Performance Standard
	 A. Are all elements present in this portion of the SIP?
		1. Does the SIP include a modeling demonstration that the I/M program meets the
performance standard for the pollutant(s) which caused it to be subject to the
program?
		2. Does the SIP include an on-road testing program?
	 B Is this portion of the SIP approvable?
		1. Does the I/M program meet or exceed the enhanced I/M performance standard
for each pollutant which caused the area(s) to be subject to the requirement?
a.	Does the SIP contain model input and output files showing the
assumptions and results used in demonstrating the program meets the
performance standard?
b.	Was the modeling performed using the most current version of EPA's
mobile source emission model (or approved alternative)?
c.	For each applicable pollutant and milestone, including the attainment
deadline, enter below the emission factor for the local performance
standard and the program target and indicate, whether the performance
standard is met for each pollutant in the left column (enter NA for not
applicable). If multiple runs are submitted, use tons, or attach a
description of your analysis and indicate "okay" below.
January 1:	2000 2003 2006 2008 2QL
VOC (ozone areas)
Performance Standard 	 	 	 	 	
Program Target
NOx (ozone areas)
Performance Standard
Program Target		
CO (CO areas) January 1. 2001
Performance Standard 	
Program Target
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d Are the assumptions used to model the performance standard targets
consistent with those listed below?
Network:	Centralized
Start date.	1983 for existing programs; 1995 for
areas newly subject under 1990 CAA
Frequency.	Annual
Model years:	1968+
Vehicle types.	LDV, LDT1, LDT2
Emission test:	IM240 on 1986+
Emission test:	Two speed on 1981-1985
Emission test:	Idle on 1968-1980
Emission standards:	0.8/20/2.0 grams per mile (EM240)
Emission standards:	1.2% CO, 220 ppm HC (steady-state)
Visual check:	Catalyst and Inlet checks on 1984+
Functional test:	Pressure test on 1983+
Functional test:	Purge test on 1986+
Pre-1981 stringency:	20%
Pre-1981 waiver rate:	3%
Post-1980 waiver rate:	3%
Compliance rate:	96%
e. Are the correct local characteristics used for the following?
	 Registration distribution
	 VMTMix
	 Min/Max temperature
	 Vehicle speed
	 ASTM class
	 RVP
	 Altitude
Note: All applicable mobile source programs for which MOBILE5
specifies parameters should be included in the modeling for both
the performance standard and for evaluating the state program,
e.g. Stage II
2.	If alternative approaches, such as vehicle scrappage, have been used to
contribute to meeting the performance standard, are the benefits estimated
from alternatives consistent with guidance established for making such
calculations?
3.	If the administrator has found that NOx reductions are not beneficial for
this particular ozone area, has the program been designed to offset NOx
increases resulting from the repair of HC and CO failures?
51.352 Basic 1/M Performance Standard
	 A. Are all elements present in this portion of the SIP7
Does the SIP include a modeling demonstration that the I/M program meets the
performance standard for the pollutant(s) which caused either the program or
the area to be subject to the program?
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2. Does the SIP include a modeling demonstration that, in ozone nonattainment
areas, no increase in NOx will occur as a result of the program7
B. Is this portion of the SIP approvable?
1. Does the I/M program meet or exceed the basic I/M performance standard for
each pollutant which caused diem to be subject to the requirement?
a Does the SIP contain model input and output files showing the
assumptions and results used in demonstrating the program meets the
performance standard?
b.	Was the modeling performed using the most current version of EPA's
mobile source emission model (or approved alternative)9
c.	For each applicable pollutant and milestone, including the attainment
deadline, enter below the emission factor for the local performance
standard and die program target and indicate, whether the performance
standard is met for each pollutant in the left column (enter N/A for not
applicable). If multiple runs are submitted, use tons, or attach a
description of your analysis and indicate "okay" below
January 1:	1222 2QQQ 2QQ2
VOC
Performance Standard 	 	 	
Program Target
NOx
No I/M Factor
Program Target
CO	1226 2SM
Performance Standard 	 	
Program Target		 	
Are the assumptions used to model the performance standard targets
consistent with those listed below?
		Network:	Centralized
		Start date:	1983 for existing areas; 1994 for areas
newly subject under 1990 CAA
		Frequency:	Annual
		Model years:	1968+
		Vehicle types:	LDV
		Emission test:	Idle on 1968+
		Emission standards:	1.2% CO, 220 ppm HC
		Pre-1981 stringency:	20%
		Pre-1981 waiver rate:	0%
		Post-1980 waiver rate:	0%
		Compliance rate:	100%
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Registration distribution
VMT Mix
Min/Max temperature
Vehicle speed
ASTM class
RVP
Altitude
Note: All applicable mobile source programs for which MOBILE5
specifies parameters should be included in the modeling for both
the performance standard and for evaluating the state program,
e.g. Stage LI.
51.353 Network Type and Program Evaluation
	 A. Are all required elements present in this portion of the SIP?
		1. Does the SIP describe the network type for each I/M area?
		2. Does the SIP include legal authority which allows for this network type to be
implemented in the subject areas?
		3. Does the SIP include a description of the biennial program evaluation?
		a. Is a schedule for the program evaluation included?
		b. Is a methodology for the program evaluation included?
		4. Does the SIP include legal authority which enables the State to conduct testing
(each year) to provide data for the biennial evaluation program?
	 B. Is this portion of the SIP approvable?
1. Network Type
		a. If an enhanced program is required for the subject area, do the regulations
in the SIP specify that the program be operated in a centralized, test-only
format?
		b. If not (and an enhanced program is required), does the SIP specify a
decentralized, test-only program?
		1. Is the only function of the test station in this I/M program to perform
official emissions testing (with the possible exceptions of conducting
state safety-related inspections, renewing vehicle registrations/drivers
licenses, collecting feesAaxes, or engaging in the sale of refreshments
to employees/waiting customers)?
		2. Do the I/M regulations in the SIP contain a stipulation that owners and
employees of an official I/M test station are contractually or legally
barred from engaging (either directly or indirecdy) in motor vehicle
repair or service, motor vehicle parts sales or motor vehicle sale or
leasing?
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3. Do the I/M program regulations in the SEP bar owners and/or
employees of official I/M testing stations from referring vehicle
owners to particular repair service providers?
c If not (and an enhanced program is required), does the SIP specify a test-
and-repair program, with an accompanying demonstration which includes
a smaller credit reduction than would normally be assigned to the various
test protocols of such a test-and-repair program?
1.	Is the demonstration provided based upon past performance of an
existing test-and-repair program that utilized the specific test-type,
inspection standards and waiver criteria to be employed?
2.	Does the demonstration include, at a minimum:
i.	Repair effectiveness surveys performed on vehicles that failed
the tailpipe and evaporative emissions system tests?
ii.	In programs with visual checks, measurement of actual
tampering rates, their change over time, and the change
attributable to finding/fixing tampering as opposed to the
deterrence effect associated with having a visual check?
iii.	Results of covert auditing of inspector effectiveness?
3.	If 1 and 2 above are not satisfied, are there program features which
provide complete assurance that the credit loss from the test-and-repair
portion of the program will not exceed the margin by which a test-only
system with the otherwise equivalent features would exceed the
performance standard?, i.e. can the program still meet the performance
standard? (Assertions that this is the case should be discussed with
OMS immediately).
d. If a basic program is required, does the SIP specify that the program be
operated using a test-and-repair or hybrid network? If so:
1.	In demonstrating equivalence with the performance standard, is full
emission reduction credit claimed only for that portion of the fleet
passing an initial or subsequent test at a test-only facility, or for that
portion of the fleet failing a test-and-repair initial test, but
subsequently passing a test-only retest?
2.	Are appropriate credit loss assumptions assigned for portions of the
fleet initially passing at a test-and-repair facility and to the portion
initially failing at a test-only facility, but subsequently passing a retest
at a test-and-repair facility?
Program Evaluation
a.	Does the SIP provide that the first biennial evaluation be reported to EPA
by July of 1997 in enhanced I/M areas?
b.	Does the SIP include a description of:
1. The evaluation schedule and protocol?
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2. The sampling methodology?
		3. The data collection and analysis system?
		4. The resources and personnel for the evaluation program, and related
details of the evaluation program?
		c. Do the measures included in the evaluation program (as described in the
SIP) include, at a minimum:
		1. Surveys assessing the effectiveness of repairs performed on vehicles
failing the tailpipe or the evaporative emissions portions of the test (as
applicable)?
		2. In programs with visual checks, measurement of actual tampering
rates, their change over time, and the change attributable to
finding/fixing tampering as opposed to deterrence effects?
		3. The results of undercover surveys of inspector effectiveness related to
identifying vehicles in need of repair?
		4. The results of mass emissions testing and evaporative emissions
checks on a sample of subject vehicles, including assurance that:
		i. The sampling methodology results in a representative, random
sample (at time of initial inspection - before repair) of at least
0.1% of the vehicles tested in a given year?
		ii. The test data is submitted to EPA?
		iii. The test data is used to calculate local fleet emission factors and
to assess the actual effectiveness of the I/M program?
51.354
	 A.
B.
Adequate Tools and Resources
Are all required elements present in this portion of the SIP?
1.	Does the SIP describe the resources to be used for program operation?
2.	Does the SIP describe how the emission reduction targets will be met?
3.	Does the SIP include a detailed budget plan?
4.	Does the SIP include a description of personnel resources?
5.	Does the SIP include a description of equipment resources?
Is this portion of the SIP approvable?
1.	Does the SIP demonstrate adequate resources to perform and maintain all
program functions?
2.	Does the SIP have a mechanism to insure future funding of program
operations?
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		a. Is a portion of the test fee or a separately assessed per vehicle fee collected
and placed in a dedicated fund? Or,
		b. Does the SIP demonstrate a suitable alternative funding mechanism?
		3. Does the program provide for sufficient staff to carry program duties, e.g.,
inspection and enforcement oversight; program evaluation and oversight; data
analysis; and public education and training?
		4 Does the program have equipment necessary to achieve the objective of the
program and meet program requirements?
51.355 Test Frequency and Convenience
	 A. Are all required elements present in this portion of the SIP?
		1. Does the SIP describe the test frequency in detail?
		2. Does the SIP require and include a definition of acceptably short waiting times
and driving distances?
		3 Does the SIP include the legal authority, rules, or contract provisions necessary
to implement and enforce the test frequency and convemence requirements?
	 B. Is this portion of the SIP approvable?
		1. Do the test frequency requirements in the program rules insure that vehicles are
tested at the assumed frequency?
		a. Does the plan describe how the test date is assigned for vehicles that
change ownership? Are such vehicles kept on the required test schedule?
		b. Does the plan describe how the test date for newly registered used
vehicles is assigned? Are such vehicles be kept on the required test
schedule?
		c. Does the SIP explain how the test frequency will be integrated into the
enforcement process?
		d. Have sufficient safeguards been built into the enforcement system to
ensure that vehicles will be tested according to schedule?
		2. For enhanced I/M areas does the SIP describe mechanisms to insure short wait
times during actual operation?
		3. Does the SIP describe the test network and demonstrate that stations are
conveniently located?
		4. For basic and enhanced programs, does the SIP define and require adherence to
regular testing hours by the test stations?
		5. For basic and enhanced programs, does the SIP require testing stations to test
any subject vehicle presented for a test during a station's operating hours?
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51.356 Vehicle Coverage
A.	Are all required elements present in this portion of the SEP7
1 Does the SIP include a description of the number (as of a date specified in the
SIP) and types (broken down by model year, fuel type, vehicle class, and
weight class) of vehicles in the program, and a plan for how those vehicles will
be identified?
2.	Does the SIP include a description of special exemptions, if any, allowed by the
program?
3.	Does the SIP include legal authority or rules necessary to implement and
enforce the vehicle coverage requirement?
B.	Is this portion of the SIP approvable?
1.	Does the number of vehicles account for vehicles registered or required to be
registered in the program area (i.e., does the SIP provide an estimate of
unregistered vehicles)?
2.	If fleet vehicles are subject to the I/M program, then:
a.	Are fleets inspected by independent test-only facilities subject to the same
test requirements as the primary program using the same quality control
standards?
b.	If fleets are not tested by independent, test-only facilities, is one of the
following criteria met?
i.	Is there no emission reduction benefit assigned for the all vehicles
(including non-fleet vehicles) within the model year class that dealers
and fleets are allowed to self-test?
ii.	If credit is assumed for some fraction of the model years that dealers
and fleets are self-testing, is the credit assumed only for vehicles that
are not resold through a dealership or fleet in a given test cycle, is this
percentage documented, and are the requirements for receiving any
credit for the affected model years including requiring test-only
certificates for title transfer and not allowing two self-tests in a row
met?
4.	Are provisions made to allow inspection of vehicles registered in other program
areas and for issuance of certificates of compliance or waiver?
5.	Are subject vehicles registered in the program area but primarily operated in
another I/M area required to be tested in the program or by the program in the
area the subject vehicle is primarily operated'7
6.	Does the plan include a description of the Federal fleet inspection program?
a. Are Federal installation managers required to show proof of inspection
for all Federal employee-owned vehicles operated on the installation?
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		b Are all Federally owned vehicles (other than tactical military vehicles)
required to be inspected?
		7. Does the description of special exemptions include an estimate of the number of
vehicles exempted and the percentage of the subject fleet, and are the
exemptions accounted for in the emission reduction analysis?
51.357 Test Procedures and Standards
	 A Are all required elements present in this portion of the SIP?
		1 Does the SIP include detailed procedures for each test and the pass/fail
standards for each applicable model year for each test?
		2. Does the SIP include die rule, ordinance or law establishing the test procedures?
	 B. Is this portion of the SIP approvable?
		1 Do the test procedures in the SIP correspond exactly to approved EPA test
procedures or official EPA test procedures pending approval?
		2. Are initial tests performed without prior repair or adjustment at the test facility
(except as necessary to perform functional tests)?
		3. Is there a provision for the vehicle operator to have access to the test area to
observe die entire inspection?
		4. Is there a provision for rejection of vehicles with missing or leaking exhausts or
other unsafe conditions?
		5. Are there pass/fail standards for ail test procedures for all applicable model
years?
		6. To the extent that repair of a failure on one part of a test can lead to failure on
another part, does the test procedure provide for a retest on the originally failed
component and the second component?
		a. Is an exhaust emission retest required along with a retest of the
evaporative system following an evaporative system failure and repair?
		b. Are all criteria pollutants measured on retest after failure of a given
pollutant?
		7. Do the pass/fail standards correspond to those used in modeling emission
reduction benefits of the program?
		a. Are standards established for both HC and CO in basic I/M areas, and
also for NOx in enhanced areas?
		b. Are evaporative test standards, if any, equal to or more stringent than EPA
established standards?
		Note: EPA encourages states to structure their regulations to allow quick
response adjustment to cutpoints in case actual failure rates at start-up are
not as expected
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8 Does the SEP have a commitment to maintain tailpipe emission test pass/fail
standards for pre-81 vehicles so as to produce the stringency rate used in
modeling emission reduction benefits?
		9. For vehicles with switched engines, are all test procedures and standards for the
chassis model year and type applied, or for the engine model year if it is newer?
		10. For vehicles that are switched to a fuel type for which there is no certified
configuration, are vehicles tested according to the most stringent emission
standards established for that vehicle type and model year?
51.358 Test Equipment
	 A. Are all required elements present in this portion of the SIP?
		1. Does the SIP contain written technical specifications for all test equipment to be
used in the program?
		2. Does the SIP describe equipment acceptance testing criteria and procedures?
	 B. Is this portion of the SIP approvable?
		1. Are computerized test systems required for all measurements performed on
subject vehicles?
		2. Are there provisions for the equipment to be:
		a. Automated to the highest degree commercially available to minimize the
potential for intentional fraud and/or human error?
		b.	Secure from abuse and/or tampering?
		c.	Based upon written specifications?
		d.	Capable of simultaneously sampling dual exhaust vehicles?
		3. Does the test system automatically:
		a.	Make a pass/fail decision for all measurements?
		b.	Record test data to an electronic medium?
		c.	Conduct regular self testing of recording accuracy?
		d. Perform electrical calibration and system integrity tests before each test,as
applicable?
		e. Initiate system lockouts for the following:
		1. Tampering with security aspects of the test system?
		2. Failing to conduct or pass periodic calibration or leak checks?
		3. Failing to conduct or pass the constant volume sampler flow rate
check, if applicable?
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4.	Failing to conduct or pass any of the dynamometer checks including
coast-down, roll speed and roll distance, power absorption capability
and inertia weight selection checks?
5.	Failing to conduct the pressure monitoring device check, if applicable?
6.	Failing to conduct or pass the purge flow metering check, if
applicable?
7.	Having a full data recording medium or one that does not pass the
cyclical redundancy check?
4 Is the emission test equipment capable of testing all subject vehicles?
5.	Does the SIP commit to updating emission test equipment to accommodate new
technology vehicles and changes to the program?
6.	In enhanced programs, does the SIP require that test systems be connected by a
real-tune data link to a host computer that prevents unauthorized multiple initial
tests on the same vehicle and ensures data accuracy?
51.359 Quality Control
	 A. Are all the required elements present in this portion of the SIP?
		1. Does the SIP include a description of quality control measures for emission
measurement equipment?
		2. Does the SIP include a description of record keeping procedures and other
measures taken to ensure document security?
		3. Does the SIP include the procedure manual, rule, ordinance or law which
describes and establishes quality control and record keeping requirements?
	 B. Is this portion of the SIP approvable?
		1. Will these measures insure that the equipment is calibrated and properly
maintained?
		2. Will these measures insure that inspection, calibration records, and control
charts are accurately created, recorded, and maintained?
		3. Does the SIP include alternative quality control measures not included under
51.359 or Appendix A of the I/M rule?
		a If so, have these measures been approved by the Administrator?
		5. Does the SIP include periodic preventive maintenance of all inspection
equipment?
		6. Does the SIP include a provision for computerized analyzers to automatically
record quality control check information, lockouts, attempted tampering, and
other recordable circumstances that impact quality control?
		7. For steady-state testing equipment, does the SIP:
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a.	Include a description of the maintenance procedures?
b.	Do these procedures follow good engineering practices to ensure test
accuracy?
c.	Include calibration and adjustment requirements complying with those
described 111 Appendix A of the I/M rule?
d Have equipment specifications including:
1.	Minimum housing construction requirements to protect the analyzer
bench and electrical components from ambient temperature and
humidity fluctuations exceeding the range of the analyzer's design
specifications?
2.	A requirement that analyzers be designed to automatically purge the
analytical system after each test?
3.	For analyzers that use ambient air as zero air, have provisions been
made to draw air from outside the inspection bay or lane?
For transient exhaust emission test equipment, does the SIP:
a.	Include a description of the maintenance procedures?
b.	Do these procedures follow good engineering practices to ensure test
accuracy?
c.	Require the use of computer controlled quality assurance checks and
quality control charts whenever possible?
d.	Provide exceptions to the procedures and the frequency of the checks
described in Appendix A of the I/M rule?
i. If so, have these exceptions been approved by the Administrator?
For evaporative system functional test equipment, does the SIP:
a.	Include a description of the maintenance procedures?
b.	Do these procedures follow good engineering practices to ensure test
accuracy?
c.	Require the use of computer-controlled quality assurance checks and
quality control charts whenever possible?
d.	Provide exceptions to the procedures and the frequency of the checks
described in Appendix A of the I/M rule?
i. If so, have these exceptions been approved by the Administrator?
Does the SIP include measures to maintain the security of all documents by
which compliance with the inspection requirement is established?
a. Are such documents required to be counterfeit-resistant?
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b Do such documents include unique serial numbers and an official seal?
c Does the SIP include measures to ensure that compliance documents
cannot be stolen or removed without being damaged?
Waivers and Compliance Via Diagnostic Inspection
Are all required elements present in this portion of the SIP?
1.	Does the SIP include a maximum waiver rate for estimating emission reduction
benefit?
2.	Does the SIP include a commitment to:
a.	Take corrective action to reduce the waiver rate to equal or below the
maximum waiver rate used for estimating benefits, or:
b.	revise the SIP and emission reductions claimed based on the actual waiver
rate?
3.	Does the SIP include specific criteria and procedures for the issuance of
waivers?
4.	Does the SIP include the necessary legal authority, rules, or ordinance to issue
waivers, set and adjust cost limits, and administer the waiver system?
Is this portion of the SIP approvable?
1. Are approvable waiver issuance criteria included?
a.	Are waivers allowed only after failing a retest and after all qualifying
repairs are completed?
b.	Is available warranty coverage required to be used before expenditures are
counted for waivers?
c.	Is repair of tampering not applicable towards the waiver limit?
d Is performance and appropriateness of repairs confirmed by visual
inspection and review of receipts?
e.	Must repairs be performed by recognized repair technicians (except for
pre-1980 models)?
f.	Are minimum expenditures required before waivers are issued?
1.	Is the minimum expenditure at least $75 for pre-81 vehicles and at
least $200 for 1981 and newer vehicles in basic programs?
2.	In enhanced I/M areas, is the minimum expenditure based on $450
and adjusted annually using the Consumer Price Index, with a base
year of 1990, according to established procedures described in the I/M
rule?
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		g. If lower minimum waiver limits are established, are vehicles that do not
pass the retest and have not received $450 in repair required to be
scrapped?
		h. If time extensions are granted:
		1. Are criteria (beyond vehicle model year or value) specified that
establish that economic hardship exists?
		2. Is the extension granted only once for the life of a vehicle?
		3. Is there a mechanism for tracking that will insure vehicles can be
identified as having gotten an extension?
		2. If compliance via diagnostic inspection is allowed, are approvable policies and
procedures specified?
		a. Is an IM240 test performed on eligible vehicles?
		b. Are cutpoints established in 51.351(a)(7) (or more stringent) in force for
eligible vehicles?
		c. Is a complete, documented physical and functional diagnosis performed
by the I/M agency or its contractor?
		3. Is the quality control of waiver issuance approvable?
		a. In enhanced areas, are waivers to be issued only by the agency or a single
contractor (no inspector issuance)?
		b. In basic areas, if inspectors are allowed to issue waivers, are
comprehensive reviews of waiver issuance conducted during overt audits?
		c. Is a program described to alert vehicle owners to warranty coverage and
ways to obtain repairs?
		d. Are procedures described to authenticate repairs receipts and prevent their
reuse?
		e. Are procedures established to limit a waiver to one test cycle?
		f. Are procedures established to track waivers and time extensions and
prevent their improper issuance?
51.361 Motorist Compliance Enforcement
	 A. Are all required elements present in this portion of the SIP?
		1. Does the SIP provide a detailed description of the motorist compliance
enforcement mechanism to be used in implementing the I/M program?
		2. Does the SIP identify all agencies responsible for implementing the motorist
compliance enforcement program?
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3.	Does the SIP provide a description of and accounting for all classes of exempt
vehicles?
4.	Does the SIP include a description of the plan for testing fleet vehicles, rental
car fleets, leased vehicles, federal fleet vehicles, state and local government
vehicles, and other subject vehicles which are operated in, but not necessarily
registered in, the 1/M area?
5 Does the SIP include an estimate of the current compliance rate, including an
assessment of the noncompliance due to loopholes, counterfeiting, and
unregistered vehicles?
6.	Does the SIP include estimates of the effect of closing the above loopholes and
otherwise improving the enforcement mechanism, if improved compliance is
assumed for modeling purposes?
7.	Are the required estimates of compliance losses and the impact of fixes based
upon a detailed analysis of actual data?
8.	Does the SIP include the legal authority and/or rules which establish the
enforcement program?
9.	Does the SIP include a commitment to an enforcement level to be used in
modeling and to be maintained, at a minimum, in practice?
B. Is this portion of the SIP approvable?
1.	If the enforcement mechanism is based upon registration denial, does the
program ensure that an application for initial registration or reregistration of a
subject vehicle is rejected without proof that the vehicle has complied with the
testing requirement and been passed or waived?
2.	If the enforcement mechanism is based upon registration denial, does the design
of this program include:
a.	An external, readily visible means of determining a vehicle's compliance
with the registration requirement?
b.	A schedule of testing (annual, biennial, or a mix) that clearly determines
when a vehicle must be tested?
c.	A mechanism for certifying that a vehicle has met the testing requirements
and has been either passed or waived (and is therefore eligible for initial
registration or reregistration), including:
1.	Expiration date of the certification?
2.	Unambiguous vehicle identification information?
3.	Whether the vehicle was passed or received a waiver?
d.	Assurance that this certification is available, checked, and validated prior
to the registration or reregistration of a subject vehicle?
e.	Routine issuance of citations to motorists who fail to comply with the
registration requirement?
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f.	A penalty schedule including mandatory, minimum, meaningful fines for
noncompliance with the registration requirement?
g.	A requirement that noncompliance cases not be closed until compliance is
demonstrated?
h.	A mechanism for preventing owners or lessors of vehicles from avoiding
the testing program through manipulation of the registration or titling
requirement?
i.	The requirement that all applications for exemption-triggering changes to a
vehicle's registration information be confirmed through a physical
examination of the vehicle or the provision of some valid form of
documentation (in the case of address changes)?
j. A means for tracking and limiting the use of time extensions and out-of-
state exemptions?
k. A mechanism for encouraging the enforcement of vehicle transfer
requirements when vehicle owners move into the I/M area?
3.	If the program is in an enhanced area and is to be enforced by some means other
than registration denial:
a.	Was the alternative mechanism part of an approved I/M SIP pnor to
enactment of the 1990 Amendments to the Clean Air Act?
b.	Were the I/M program and alternative mechanism in question actually in
place and operating prior to enactment of the 1990 Amendments to the
Clean Air Act?
c.	Does the SIP include a demonstration that this alternative enforcement
mechanism is more effective than registration denial?
d.	Is this demonstration based upon a determination (and comparison) of the
relative compliance numbers and percentages for both the registration
program and the I/M program?
i.	Is this comparison based upon data for at least one full test cycle?
ii.	Does this comparison show that the fraction of vehicles complying
with the I/M program is higher than the fraction of vehicles complying
with the registration requirement?
4.	If the program is in a basic area and is to be enforced by an alternative
mechanism:
a.	Does the SIP include a demonstration that this alternative enforcement
mechanism is as effective as registration denial?
b.	Is this demonstration based upon a determination (and comparison) of the
relative compliance numbers and percentages for both the registration
program and the I/M program?
i. Is this comparison based upon data covering at least 1 full test cycle?
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ii. Does this comparison show that the fraction of vehicles complying
with the I/M program is at least equal to the fraction of vehicles
complying with the registration requirement?
5.	If a program is using sticker-based enforcement:
a.	Does the SIP include a demonstration that this enforcement mechanism (in
addition to meeting the general requirements for alternative enforcement
mechanisms) will swiftly and effectively prevent operation of
noncomplying subject vehicles?
b.	Does the demonstration required of sticker-based programs in item
(B)(4)(a) above include an assessment of the following forms of
noncompliance and a means for limiting each:
1.	Use of stolen, counterfeit or fraudulently obtained stickers?
2.	In states with safety inspections, the use of "Safety Inspection Only"
stickers on vehicles subject to the emission test ?
3.	Operation of vehicles with expired stickers, including a breakdown by
length of noncompliance and model year?
c.	Does the program require external, easily visible and unambiguous
identification of vehicles as subject to the I/M requirement?
d.	Does the program require external, easily visible and unambiguous
identification of a subject vehicle's compliance status?
e.	Does the program include fines which make the cost of noncompliance
greater than the upper limit cost of compliance?
f.	Are the external identifiers used or planned by the program:
1.	Counterfeit resistant?
2.	Difficult to remove without destroying?
3.	Durable enough to last until the next inspection cycle without fading,
peeling, or otherwise deteriorating?
g.	Does the program require the performance of compliance surveys
involving at least 10% or 10,000 (whichever is less) of the subject vehicle
population?
h.	Are all external compliance identifiers tracked and accounted for?
i.	Are meaningful fines assessed against test stations for all unaccounted for
identifiers?
6.	If a program is using computer-matching enforcement, either as a supplement to
registration denial or in lieu of registration denial:
a. Does the SIP include a demonstration that this enforcement mechanism (in
addition to meeting the general requirements for alternative enforcement
mechanisms in the case of areas using computer matching in lieu of
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registration denial) will swiftly and effectively prevent operation of
noncomplying subject vehicles?
		b. Does the demonstration required of computer-matching programs in item
(B)(6)(a) above include requirements that ensure that:
		1. 90% of subject vehicles are in compliance within 4 months of the
compliance deadline?
		2. Subsequent compliance deadlines are based upon the date of
scheduled compliance (not the date of actual compliance)?
		3. Fines for noncompliance are at least as great as the upper limit cost of
compliance?
		4. Registration suspension and denied of rercgistration for continued
noncompliance?
		5. Demonstration of the current computer system's adequacy to store and
manipulate the I/M vehicle database?
		6. Provisions for periodic system backup and auxiliary storage?
		c. Does the computer-matching program track each vehicle through the steps
taken to ensure compliance, including:
		1. The compliance deadline?
		2. The date of initial notification?
		3. The dates warning letters are sent?
		4. The dates notices of violation and other penalty notices are sent?
		5. The dates and outcomes of other steps in the process?
		6. The final compliance date?
		d. Does the SIP commit to compiling and reporting monthly summaries
including statistics on the percentage of vehicles at each stage in the
enforcement process?
		e. Does the SIP commit to tracking the number and percentage of vehicles
which are never tested as a result of being junked, sold outside the I/M
area, or for other reasons?
51.362
	 A.
Motorist Compliance Enforcement Program Oversight
Are all required elements present in this portion of the SIP?
1.	Does the SIP include a description of how the motorist compliance enforcement
program is quality controlled and quality assured?
2.	Does the SIP include a description of the program's information management
activities?
3.	Does the SIP include the legal authority and/or regulations necessary to
implement this aspect of the program?
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	 B. Is this portion of the SIP approvable?
		1. Does the oversight program included in the SIP quality assure its information
base by:
		a. Verification of exempt vehicle status through inspection?
		b. Data accuracy assurance through automatic or redundant data entry?
		c. Establishment and maintenance of an audit trail for all program
documentation so that all such documentation can be controlled and
tracked?
		d. The assessment of fines against stations for missing or unaccounted for
program documents reflecting the "street value" of those documents (i e.,
test fee plus minimum waiver expenditure)?
		e. Analysis of the registration database to target exemption-triggering
changes in registration data?
		f Follow-up and confirmation of exemption-triggering registration changes?
		g. Periodic audits of test records and other program documentation to assess
program effectiveness?
		2. Are the activities of enforcement personnel quality controlled through:
		a. Written procedures to be followed by personnel directly involved in the
enforcement of the I/M program?
		b. Written procedures for personnel involved in handling or processing of
program documentation, such as registration clerks or other document
distributors?
		i. Are these personnel to be audited using written procedures?
		c. Are all enforcement personnel (direct and indirect) covered by
enforcement procedures including disciplining, retraining, or removing
such personnel who deviate from established procedures?
		3. Are evaluations of actual or projected program effectiveness based upon a
quality assured information base that includes:
		a. An accurate determination of the subject vehicle population?
		b. Quality assurance of the registration and other program documentation
databases?
		c. Periodic auditing and analysis of the testing database?
		d. Comparison of the testing and enforcement databases to determine
program effectiveness and to trigger additional enforcement activities?
		e. The use of parking lot surveys, road-side pullovers, and other strategies
to assess the compliance status of the in-use fleet (and to quality assure the
enforcement database)?
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f. Does the SIP permit EPA audits of the enforcement process?
Quality Assurance
Are all required elements present in this portion of the SIP?
1.	Does the SIP include a description of the quality assurance program?
2.	Does the SIP include legal authority or rules necessary to implement the quality
assurance requirements?
Is this portion of the SIP approvable?
1.	Are performance audits (overt and covert) based on written procedures?
a.	Are audit results recorded and retained in station and inspector files?
b.	Are records of sufficient detail to support administrative or civil hearings
required to be maintained?
2.	Are stations and inspectors suspected of violating regulations as a result of data
analysis or consumer complaints audited at a greater frequency?
3.	Are overt performance audits conducted at least twice a year for each lane or test
bay?
a.	Are auditors required to check for document security?
b.	Are auditors required to check to see that required records are being kept?
c.	Are auditors required to check for proper licenses or ceitificates along
with other required display information?
d.	Do auditors observe and produce written evaluations of each inspector's
ability to properly perform testing procedures?
4.	Are coven audits included in the quality assurance program?
a.	Are auditors required to remotely observe inspector performance one per
year per inspector for high volume stations (i.e., those performing more
than 4,000 tests per year)?
b.	Is the number of covert audits performed annually at least equal to the
number of inspectors in the program?
c.	Are covert vehicles set to fail in some fashion?
d.	In addition to the above covert audits, are test-and-repair stations covertly
audited at least once per year, including the purchase of repairs and retest
if the vehicle is initially failed for tailpipe emissions?
e.	Is the required audit documentation sufficient for building a legal case and
ongoing performance evaluation?
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f Does the fleet of covert vehicles used cover the range of vehicle
technology groups and include a full range of malfunctions?
g.	Are there a sufficient number of covert vehicles and auditors to allow for
rotation to avoid detection?
h.	Are auditors (or other designated agents) able to access the inspection
database to permit the creation and maintenance of covert vehicle records?
5 Are station and inspector records reviewed at least monthly to assess station
performance and identify potential problems?
a.	Does the review use software-based, computerized analysis to identify
statistically inconsistent information?
b.	Does the review require visits to stations to review records not covered m
an electronic analysis?
c.	Does the review require comprehensive accountability for all forms that
can be used to demonstrate compliance with the program?
6. Are auditors required to conduct quality control evaluations of testing equipment
during overt site visits? Does the equipment audit include:
a.	A gas audit using gases of known concentration at least as accurate as
those used for routine quality control checks?
b.	A check for tampering and general serviceability of the equipment?
c.	A check for critical flow in the Constant Volume Sampler (CVS)?
d.	A check for CVS flow calibration?
e.	A check for the optimization of FID fuel-air ratio using methane?
f.	A leak check?
		g. A check to determine that station gas bottles used for calibration are
properly labelled and within relevant tolerances?
		h. A functional check of the dynamometer addressing coast-down, roll speed
and roll distance, inertia weight selection, and power absorption?
		i. A check of the system's ability to detect background pollutant levels?
		j. A check of the pressure monitoring devices used to perform the
evaporative canister pressure test?
		k. A check of the purge flow metering system?
		7. Is completion of a formal training program required for auditors? Does this
training address
		a.	The use of analyzers?
		b.	The program rules and regulations?
		c.	The basics of air pollution control?
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		d.	The basics principles of engine repair related to emission performance7
		e.	The basics principles of motor vehicle emission control systems?
		f.	Evidence gathering?
		g.	State administrative procedures?
		h.	Quality assurance practices?
		1.	Covert audit procedures?
		8. Are auditors themselves audited at least once per year?
51.364 Enforcement Against Contractors, Stations and Inspectors
	 A Are all the required elements present in this portion of the SIP?
		1. Does the SIP include a penalty schedule and the legal authority to enforce it?
		2. Does the SIP include an official opinion from the state Attorney General to
support all claims of state constitutional impediments to the requirements under
this section of the I/M rule?
		3. Does the SIP provide descriptions of:
		a. The administrative and judicial procedures and responsibilities relevant to
the enforcement process?
		b. A listing by area of responsibility the agencies, courts, and jurisdictions
involved in the above procedures?
		c. Identification of the body responsible for prosecuting and adjudicating
cases?
		d. A description of the resources to be allocated to this function and their
source(s)?
		4. If state does not have the authority to immediately suspend station/inspectors,
does the SIP demonstrate that sufficient resources, personnel, and systems are
in place to process cases directly impacting emission reductions within three
days?
	 B. Is this portion of the SIP approvable?
		1 Does the penalty schedule include categories and lists of violations with
minimum penalties to be imposed for the first, second, and subsequent
violations and are those penalties adequate?
		2. For test-and-repair programs, is there a provision for suspension of inspector
and station licenses for at least 6 months?
		3. For test-only programs, is there a provision for removal of an inspector for at
least 6 months, or a retainage penalty equivalent to an inspector's salary for at
least 6 months?
		4. Do cases of gross neglect result in a penalty for the first offense of no less than
$100 or 5 times of inspection fee (whichever is greater) for the contractor or the
station and the inspector (if involved)?
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5. In cases of inspector incompetence, retraining required before restoration of
privileges?
6 Does the license or certification suspension process include provisions that
effectively bar the individual from any involvement, direct or indirect, in the
inspection operation during the full term of the suspension?
7.	Does the auditor have authority to temporarily suspend station and inspector
licenses or certificates immediately upon finding a violation or equipment
failure? If not:
a.	Has the state demonstrated that its enforcement system has adequate
resources to hold a hearing to suspend or revoke the station or inspector
license within three business days?
b.	Has the state demonstrated that such authority is prohibited by the state's
constitution?
8.	Does the oversight agency have the authority to impose penalties against
licensed stations or contractors, as well as the inspector, even if the licensee or
contractor had no direct knowledge of the violation?
9.	Is the oversight agency specifically required to maintain records of all
enforcement activities, including all warnings, civd fines, suspensions,
revocations, and violations?
10.	Does the SIP commit to compiling and reporting statistics on the above
enforcement activities on an annual basis?
51.365	Data Collection
	 A.	Is data collection included as part of the I/M program?
		1. Does the SIP describe the type of data to be collected?
		2. Does the SIP describe how the collected data shall be used?
B. Is this portion of the SIP approvable?
1. Is the following data collected with respect to all vehicles tested?
a.	Test record number?
b.	Inspection station number?
c.	Inspector number?
d.	Test system number?
e.	Date of the test?
f.	Emission test start time?
g.	The time final emission scores are determined?
h.	Vehicle identification number?
i.	License plate number?
j. Test certificate number?
k. Gross vehicle weight rating (GVWR)?
1. For each vehicle:
1.	Model year?
2.	Make?
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3 Vehicle type?
m.	Number of cylinders or engine displacement? (for IM240 vehicles)
n.	Transmission type? (for IM240 vehicles)
o.	Odometer reading?
p	Category of test performed (i e., initial, first retest, or subsequent retest)"7
q.	Fuel type of the vehicle (i.e., gas, diesel, or other fuel)?
r	Type of vehicle preconditioning performed (if any)?
s	Emission test sequence(s) used?
t.	Emission scores for HC, CO, CO2, and NOx (in enhanced areas)?
u.	For each test mode, standards for HC, CO, CO+CO2, and NOx?
v. Results (Pass/Fail/Not Applicable) for the following visual inspections:
1.	Catalytic converter?
2.	Air system?
3.	Gas cap?
4.	Evaporative system?
5.	Positive crankcase ventilation (PCV) valve?
6.	Fuel inlet restnctor?
7.	Other visual inspection for which emission reduction credit is claimed?
w. Pass/fail results fon
1.	Evaporative system pressure test?
2.	Evaporative system purge test?
x. Total purge flow in liters achieved during the test?
2. Does the SIP include a commitment to gather and report the results of the
quality control checks described in 51.359?
a. Will each check be identified by:
1.	Station number?
2.	System number?
3.	Date?
4.	Start time?
b. Will the data reports contain the concentration values of the calibration
gases used to perform the gas characterization portion of the quality
control checks?
51.366	Data Analysis and Reporting
	 A.	Is data analysis and reporting included as part of the I/M program?
		1. Does the SIP include a commitment to submit annual reports?
		2. Does the SIP include a commitment to submit biennial evaluations?
	 B. Is this portion of the SIP approvable?
		1. Is the first annual report scheduled to be submitted within 18 months of initial
program implementation?
		2 Does the SIP commit to submit a report each July, for January through
December of the previous year, which provides statistics on the testing element
of the program? Will this report cover the following program statistics:
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a.	The number of vehicles tested by:
1.	Model year?
2.	Vehicle type?
b.	By model year and vehicle type, the number and percentage of vehicles:
1.	Failing the emissions test initially?
2.	Failing each emission control component check initially?
3.	Failing the evaporative system functional and integrity checks initially?
4.	Failing the first retest for tailpipe emissions?
5.	Passing the first retest for tailpipe emissions?
6.	Initially failed vehicles passing the second or subsequent retest for
tailpipe emissions?
7.	Initially failed vehicles passing each emission control component
check on the first or subsequent retest by component?
8.	Initially failed vehicles passing the evaporative system functional and
integrity checks on the first or subsequent retest by component?
9.	Initially failed vehicles receiving a waiver?
10.	Vehicles with no known final outcome (regardless of reason)?
c.	The initial test volume by model year and test station?
d.	The initial test failure rate by model year and test station?
e.	The average increase or decrease in after repair tailpipe emission levels for
HC, CO, and NOx by model year and vehicle type, for vehicles receiving
a mass emissions test or approved alternative?
3. Does the SIP commit to submit a report each July, for January through
December of the previous year, which provides statistics on the quality
assurance program? Will this report cover the following program statistics:
a.	The number of inspection stations and lanes which are in operation:
1.	Throughout the year?
2.	Only part of the year?
b.	The number of stations and lanes operating throughout the year:
1.	Receiving overt performance audits in the year?
2.	Not receiving overt performance audits in the year?
3.	Receiving covert performance audits in the year?
4.	Not receiving covert performance audits in the year?
5.	That have been shut down as a result of overt performance audits?
c.	The number of covert audits:
1.	Conducted with the vehicle set to fail the emission test?
2.	Conducted with the vehicle set to fail the component check?
3.	Conducted with the vehicle set to fail the evaporative system checks?
4.	Conducted with the vehicle set to fail two or more checks?
5.	Resulting in a false pass for emissions?
6.	Resulting in a false pass for component checks?
7.	Resulting in a false pass for the evaporative system check?
8.	Resulting in a false pass for two or more checks?
d.	The number of inspectors:
1.	Suspended, fired, or prohibited from testing because of covert audits?
2.	Suspended, fired, or prohibited from testing for other causes?
3.	Fined for any reason?
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e.	The number of stations:
1.	Suspended, fired, or prohibited from testing because of covert audits?
2.	Suspended, fired, or prohibited from testing for other causes?
3.	Fined for any reason?
f.	The number of inspectors licensed or certified to conduct testing?
g.	The number of hearings:
1. Held to consider adverse actions against inspectors and stations?
2 Resulting in adverse actions against inspectors and stations?
h.	The total amount collected in fines from inspectors and stations by type of
violation?
i The total number of covert vehicles available for undercover audits over
the year?
j. The number of covert auditors available for undercover audits?
4.	Does the SIP commit to submit a report each July, for January through
December of the previous year, which provides statistics on the quality control
program? Will this report cover the following program statistics:
a.	The number of emission testing sites and lanes in use in the program?
b.	The number of equipment audits by station and lane?
c.	The number and percentage of stations that have failed equipment audits?
d.	Number and percentage of stations and lanes shut down as a result of
equipment audits?
5.	Does the SIP commit to submit a report each July, for January through
December of the previous year, which provides statistics on the enforcement
program?
a.	For all varieties of enforcement programs, will this report cover the
following program statistics?
1.	An estimate of the number of vehicles subject to the program,
including the results of an analysis of the registration data base?
2.	The percentage of motorist compliance based upon a comparison of
the number of valid final tests with the number of subject vehicles?
3.	The total number of compliance documents issued to stations?
4.	The number of missing compliance documents?
5.	The number of time extensions and exemptions granted to motorists?
6.	The number of compliance surveys conducted, number of vehicles
surveyed in each, and the compliance rates found?
b.	For registration denial enforcement programs, will this report cover the
following program statistics?
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1.	An assessment of the program's efforts and actions to prevent
motorists from falsely registering vehicles out of the program area or
falsely changing fuel type or weight class on the vehicle registration?
2.	The results of special studies to investigate these activities?
3.	The number of registration file audits, including
i. The number of registrations reviewed?
li. Compliance rates found?
c.	For computer-matching based enforcement programs, will this report
cover the following program statistics?
1.	The number and percentage of subject vehicles that were tested by the
initial deadline, and by other milestones in the cycle?
2.	An assessment of the program's efforts to detect and enforce against
motorists falsely changing vehicle classifications to circumvent
program requirements, and the frequency of this type of activity?
3.	The number of enforcement system audits, and the error rate found
during those audits?
d.	For sticker-based enforcement systems, will this report cover the
following program statistics?
1.	An assessment of efforts to prevent, detect, and enforce against sticker
theft and counterfeiting, and the frequency of such activity?
2.	A report on efforts to detect and enforce against motorists falsely
changing vehicle classifications to circumvent program requirements,
and the frequency of this type of activity?
3.	The number of parking lot sticker audits conducted, the number of
vehicles surveyed in each, and the noncompliance rate found during
those audits?
5. Does the SIP commit to submit the first biennial report by July 1996 (in basic
I/M programs) or July 1997 (in enhanced programs)? Will the report include:
a.	Changes made in program design, funding, personnel levels, procedures,
regulations, and legal authority, with detailed discussion and evaluation of
the impact on the program of all such changes?
b.	Any weaknesses or problems identified in the program?
c.	Steps taken to correct those problems, the result, and any future efforts
planned?
51.367
	 A.
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Inspector Training and Licensing or Certification
Are all required elements present in this portion of the SIP?
1. Evidence that the state has the authority to require mandatory inspector training?
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2.	Does the SIP contain a description of inspector training program?
3.	Does the SIP contain a description of the written and hands-on tests?
4.	Does the SIP contain a description of the licensing or certification process?
B . Is this portion of the SIP approvable?
1.	Are inspectors required to receive formal training?
a.	Does the training program at a minimum cover the following areas:
1.	Air pollution problems (causes and effects)?
2.	Purpose, function and goal of state inspection program?
3.	State inspection regulations?
4.	Test procedures and rationale for their design?
5.	Emission control devices, configuration and inspection?
6.	Test equipment operation, calibration and maintenance?
7.	Quality control procedures?
8.	Public relations?
9.	Safety and health issues related in the inspection process?
b.	Does the state commit to monitoring and evaluating the training program
delivery, if the training is not administered by the program?
2.	Are inspectors required to be licensed or certified?
a. Must inspectors pass a written test covering the elements required in the
training program above?
c.	Is a correct score of at least 80% (or lower if an occupational analysis
justifies) required to pass the test?
d.	Does the inspector have to demonstrate the ability to, without assistance,
conduct a proper inspection, properly use equipment, and follow other
procedures in order to pass the training course?
e.	In test-only programs, is the certification or licensing administered by a
state agency or contractor other than the testing department or testing
contractor?
3.	Are inspectors required to be relicensed or recertified?
a.	Is there a requirement that the license or certification expires within 2
years?
b.	Is there a requirement that upon expiration of the license or certification,
the inspector undergoes either a refresher training course prior to license
or certification renewable or a comprehensive skill examination and
determination of inspector competency?
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51.368 Public Information and Consumer Protection
	 A. Are all required elements present in this portion of the SIP?
		1. Does the SIP include a plan for informing the public on an ongoing basis
throughout the life of the I/M program?
		2. Does the SIP include a plan to offer motorists that fail the test repair facility
performance data and diagnostic information in enhanced areas?
		4. Does the SIP include provisions to protect the public from fraud and abuse by
inspectors, mechanics, and others involved in the I/M program?
	 B. Is this portion of the SIP approvable?
1. Does the public awareness plan include strategies to educate the public on the:
		a. The air quality problem?
		b. The requirements of federal and state law?
		c. The role of motor vehicles in the air quality problem?
		d. The need for and benefits of an inspection program?
		e. The ways to maintain a vehicle in a low-emission condition?
		f. How to find a qualified repair technician?
		g. The requirements of the I/M program?
		2. For motorists that fail the test in enhanced areas, will the information offered to
motorists include:
		a. A list of repair facilities in the area and statistics on:
		1.	The number of vehicles submitted for a retest after repair?
		2.	The percentage of vehicles passing on first retest?
		3.	The percentage of vehicles requiring more than one trip to comply7
		4.	The percentage of vehicles receiving a waiver?
		b. Software-generated, interpretive diagnostic information based on the
particular portions of the test that were failed?
		3. Does the consumer protection provisions include:
		a. A challenge mechanism to contest the result of an inspection?
		b. Protection of whistle blowers and following up on complaints by the
public or others involved in the process?
		c. A program to assist owners in obtaining warranty covered repairs for
eligible vehicles that fail a test?
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51.369 Improving Repair Effectiveness
	 A. Are all required elements present in this portion of the SIP?
		1 Does the SIP include legal authority, rules or procedures necessary to conduct
performance monitoring, provide technical assistance, and insure training is
available?
	 B. Is this portion of the SIP approvable?
		1. Does the SIP provide for technical assistance related to diagnosis and repair of
vehicles that fail the I/M test to the repair industry?
		a. Is there a mechanism to regularly inform repair facilities of changes in the
inspection program, training program, common problems being found
with particular engine families, diagnostic type and the like?
		b. Does the SIP provide for the establishment of an ongoing hot line service
to assist technicians with specific repair problems, and answer legal and
technical questions?
		2. In enhanced areas, is there a system of repair facility performance monitoring?
		a. Does this system include gathering statistics, by repair facility, on:
		1.	The number of vehicles submitted for a retest after repair?
		2.	The percentage of vehicles passing on first retest?
		3.	The percentage of vehicles requiring more than one trip to comply?
		4.	The percentage of vehicles receiving a waiver?
		b. Is a summary of the performance of individual motor vehicle repair
facilities, that conveys information on the relative ability of repair facilities
in providing effective and convement repair, provided to the public at the
time of initial failure?
		c. Does the system provide feedback to individual repair facilities on a
regular basis (at least annually)?
		d. Is a completed repair form indicating which repairs were performed, any
recommended additional repairs, and identification of the facility that
performed the repairs required as a prerequisite for retest?
		3. Is repair technician training available which includes the four areas listed below
or are there provisions to make such training available?
		a. Diagnosis and repair of malfunctions in computer controlled, closed-loop
vehicles?
		b. Application of emission control theory and diagnostic data to the diagnosis
and repair of failures on the transient emissions test and the evaporative
system functional test?
		c. Utilization of diagnostic information on systematic or repeated failures
observed in the transient test and the evaporative system function test?
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d. General training on the various subsystems related to engine emissions
control?
Compliance with Recall Notices
Are all required elements present in this portion of the SIP?
1.	Does the SIP include provisions to ensure vehicles subject to enhanced I/M
receive all required recall repairs?
2.	Does the SIP include legal authority to require owners or lessees of vehicles
with unresolved recalls to show proof of compliance with recall in order to
complete the inspection or registration cycle?
Is this portion of the SIP approvable?
1.	Are motorists required by regulations to obtain recall repairs in order to
complete the inspection process or before obtaining a vehicle registration?
a.	Is there a process for notifying motorists of a specific recall requirement
prior to the test deadline?
b.	If so, is compliance required on the next registration or inspection date
after state notification of recall was received by the vehicle owner?
c.	If not, are motorists required to comply when notified at the station of the
outstanding recall, prior to completing the inspection or registration
requirement?
2.	Are quality control methods used to insure recall repairs are properly
documented and tracked?
a.	Are vehicles with unresolved recalls automatically identified as
noncomplying when they show up for testing or registration?
b.	Does the SIP commit to updating the list of unresolved recalls at least
quarterly?
c.	Is there a means to document repairs on vehicles that have received repairs
but remain on the recall list?
d.	Does the data system include the recall campaign numbers for vehicles
with unresolved recalls?
3.	Does the SIP commit to submitting an annual report providing information on
recall compliance including
On-road Testing
Are all required elements present in this portion of the SIP?
1. In enhanced areas, does the SIP include an on-road testing program?
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2. In enhanced areas, does the SIP include the legal authority necessary to
implement the on-road testing program?
B Is this portion of the SIP approvable?
1 Does the SIP include a detailed description of the on-road testing program,
including:
a.	Types of testing to be used?
b.	Test limits and criteria?
c.	The number of vehicles (percentage of the fleet) to be tested?
d.	The budget dedicated to the on-road testing effort?
e.	The methods for collecting and reporting the results of on-road testing?
f.	The methods for analyzing and utilizing the results of on-road testing?
g.	The number of employees dedicated to the on-road testing effort?
2. Are motorists that fail the on-road test required to get an off-cycle inspection
and bring the vehicle into compliance?
State Implementation Plan Submissions
Are all required elements present in this portion of the SIP?
1. Does the SIP include a schedule of implementation of the program?
Is this portion of the SIP approvable?
1.	Does the schedule include milestones for the following:
a.	Obtaining enabling or statutory authority?
b.	Proposal of draft regulations and final promulgation?
c.	Issuance of final specifications and procedures, including RFPs?
d.	Licensing or certification of stations and inspectors?
e.	The start of mandatory testing
f.	The date full-stringency outpoints take effect?
2.	Does the analysis of emission level targets use current EPA mobile source
emission model meet the performance standards described in 51.351 or
51.352 of the regulation subpart?
a. If an alternative model approved by the Administrator is used, does it also
meet the same performance standard?
3.	If the program is not county wide, does the SIP include a list of the ZIP codes
of areas covered by the program?
4.	Is there a discussion of the required design elements, including provisions for
federal facility compliance?
5.	Does the SIP include legal authority requiring or allowing operation of the I/M
program through the applicable attainment date?
6.	Is there evidence of adequate funding, resources, implementing regulations,
interagency agreements, and memorandum of understanding?
51.372
	 A.
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7
Does the SIP include a description of personnel resources?
51.373 Implementation Deadlines
	 A. Are all required scheduling elements present in this portion of the SIP?
		1. Does the SIP include deadlines for implementing the program?
	 B Is this portion of the SIP approvable?
		I If the program is a basic, decentralized system, is it scheduled to be fully
implemented by January 1, 1994?
		2. If the program is a basic, centralized system, is it scheduled to be fully
implemented by July 1, 1994?
		3. If the program is enhanced, are all enhanced features scheduled to be
implemented by January 1, 1995 with the following exceptions?
		a. In an area switching from an existing test-and-repair network to a test-
only network, is at least 30% of the subject vehicle population (statewide)
scheduled to be tested starting January 1, 1995?
		c In areas starting new test-only programs and those with existing test-only
programs, does the SIP include a phase-in of new test procedures
between January 1,1995 and January 1, 1996?
		b Are all subject vehicles scheduled to be tested starting January 1,1996?
		4. In areas newly required to implement I/M (not subject as of November 15,
1992)
		a. Does the SIP include implementation:
		i. In enhanced areas, within 2 years of obtaining legal authority?
		ii. In basic decentralized areas, within 1 year of obtaining legal authority?
		iii. In basic centralized areas, within 2 years of obtaining legal authority?
		b. Has the legal authority for the program been obtained during the first
applicable legislative session?
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