/HIGH ALTITUDE VEHICULAR EMISSION CONTROL PROGRAM
VOLUME V. DEVELOPMENT OF TECHNIQUES, CRITERIA, AND
STANDARDS TO IMPLEMENT A VEHICLE INSPECTION,
MAINTENANCE AND MODIFICATION PROGRAM
PREPARED FOR:
STATE OF COLORADO
DEPARTMENT OF HEALTH
DENVER, COLORADO 80220
ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
DENVER, COLORADO 80203
OLSON LABORATORIES, INC.
a subsidiary of NORTHROP CORPORATION
421 East Cerritos Avenue
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44^7
HIGH ALTITUDE
I 4 Q>
t< I
VEHICULAR EMISSION CONTROL PROGRAM
DEVELOPMENT OF TECHNIQUES, CRITERIA, AND STANDARDS
TO IMPLEMENT A VEHICLE INSPECTION,
MAINTENANCE AND MODIFICATION PROGRAM
Prepared under Contract Agreement
dated 28 August 1973
with the
State of Colorado
Department of Health
Approved by
Vice President
Research and Engineering
OLSON LABORATORIES, INC.
a subsidiary of NORTHROP CORPORATION
421 East Cerritos Avenue
Anaheim, California 92805
FINAL REPORT
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REVIEW NOTICE
This report has been reviev/ed and approved for publication by
the U. 3. Environmental Protection Agency, the State of
Colorado Air Pollution Control Commission and the Air Pollu-
tion Control Division. Approval does not signify that the
contents necessarily reflect the views and policies of the
EPA, APCC or APCD, nor does mention of trade names or commer-
cial products constitute endorsement or recommendation for use.
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ACKNOWLEDGMENT
This volume of the final report was prepared under contract with
the State of Colorado, Department of Health, Division of Air
Pollution Control and the Commission on Air Pollution Control.
Olson acknowledges the assistance provided by the State of
Colorado, the Region VIII office of the U. S. EPA, and the other
study contractors, TRW and Automotive Testing Laboratories.
However, Olson Laboratories assumes sole responsibility for the
contents of this volume.
Because this study was designed to update a previous report, it
draws heavily from the "Vehicle Emission Inspection and Control
Program" study prepared in November 1972 for the Health Depart-
ment. In addition, much of the information on vehicle safety
inspection was extracted from the "Motor Vehicle Safety Inspec-
tion Program Study" prepared in November 1972 for the Colorado
Department of Revenue, Motor Vehicle Division. Both studies
were prepared by Olson Laboratories under separate contract with
the respective departments.
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ABSTRACT
This volume of the final report evaluates the factors that would
affect the integration of the proposed vehicle emission inspec-
tion program with the existing vehicle safety inspection program.
The analysis considers only light-duty, passenger vehicles and
excludes motorcycles, trucks, busses, and trailers which current-
ly also are safety inspected.
Included in the reported results are federal and Colorado vehi-
cle safety inspection procedures, estimated task times, and an
approximate inspection fee. An estimate of vehicle Idle emis-
sion inspection also is provided in terms of task time and
approximate fee. Cost estimates are provided for both state-
operated and privately-operated stations performing both safety
and emissions inspections. Based on expected investment and
operating expenses, the inspection fees for annual and semi-
annual testing are determined.
The results of three previously completed public opinion surveys
are evaluated. Responses to questions relative to various trans-
portation and emission control strategies are discussed. Results
of this analysis are used to develop requirements for future sur-
veys and public information programs. Vehicle owner considera-
tions are discussed in terms of certified stations and inspec-
tors, posted signs and labor rates, procedures for requesting
waivers and filing consumer complaints, and other factors that
promote consumer protection. Legislative considerations are
included as they affect future programs involving vehicle retro-
fit and engine modifications.
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TABLE OF CONTENTS
REVIEW NOTICE
ACKNOWLEDGEMENT j- i i
ABSTRACT iv
Section
1 CONCLUSIONS 1--1
1.1 Vehicle Emission Inspection and
Modifications 1-1
1.2 Vehicle Safety Inspection ». . . 1-3
1.3 Public Opinion Surveys l-:>
1.4 Vehicle Tampering and Modifications 1-7
2 RE COMMENDATIONS 2-1
3. INTRODUCTION 3-1
3.1 Study Background 3-1
3.2 Study Objectives 3-3
3.3 Study Conduct 3-3
4 VEHICLE SAFETY AND EMISSION INSPECTION .... 4-1
4.1 Vehicle Safety Inspection 4--.L
4.2 Vehicle Emission Inspection 4-7
4.3 Vehicle Retrofit and Modification 4--lf.5
4.4 Data and Information Processing 4-29
4.5 State Program Administration and
Management 4-33
4.6 Cost Analysis 4-40
5 PUBLIC OPINION SURVEYS 5-1
5.1 Survey Descriptions 5-1
5.2 Opinions on Air Pollution 5-4
5.3 Opinions on Vehicle Emission Control
Strategies 5-6
5.4 Future Public Indoctrination
Requirements 5-21
5.5 Further Investigations Required 5-24
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TABLE OF CONTENTS
(continued)
Section Page
6 VEHICLE OWNER CONSIDERATIONS 6-1
6.1 Public Information Dissemination 6-1
6.2 Licensed Stations 6-2
6.3 Consumer Protection Considerations 6-4
6.4 Approved Emission Control Practices 6-6
7 LEGISTLATIVE CONSIDERATIONS 7-1
7.1 Federal EPA Policy 7-1
7.2 Colorado Legislation 7-5
7.3 U.S. Senate Bill 2236 7-6
7.4 Manufacturer's Warranty Requirements 7-7
REFERENCES R-l
Appendixes
A NHTSA INSPECTION STANDARDS A-l
B DRAFT OF RECOMMENDED INSPECTION PROCEDURE,
EQUIPMENT, AND REJECTION LIMITS B-l
C INSPECTION TASK TIME ANALYSIS C-l
D RECOMMENDED SAFETY INSPECTION EQUIPMENT
LIST D-l
E PROGRAM COST SUMMARY FOR VEHICLE
EMISSION INSPECTION E-l
F INTEGRATED SAFETY-EMISSIONS PROGRAM
COST F-l
G EPA ADVISORY CIRCULAR ON HIGH ALTITUDE
MODIFICATIONS G-l
H EPA INTERIM TAMPERING ENFORCEMENT POLICY ... H-l
I MANUFACTURER'S WARRANTY CORRESPONDENCE .... 1-1
J IDLE TEST PROCEDURES FOR PARTICIPATING
GARAGES J-l
K EXAMPLES OF INSPECTION DATA FORMS K-l
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LIST OF TABLES
Table Page
4-1 Estimated Inspection Times. . . . 4-5
4-2 Emission Reduction for Serviced Vehicles
Only 4-10
4-3 Emission Reduction for Total Vehicle
Population 4-10
4-4 Survey Results of Maintenance Cost Estimates. . 4-16
4-5 Program Costs - Vehicle Emissions Inspection. . 4-43
4-6 Program Costs - Vehicle Emissions and Safety
Inspection 4-45
5-1 Demographic Characteristics 5-3
5-2 Control Measures to Achieve Federal Ambient
Air Quality Standards 5-7
5-3 Traffic Control Concepts 5-20
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SECTION 1
CONCLUSIONS
1.1 VEHICLE EMISSION INSPECTION AND MODIFICATIONS
© Vehicle emissions inspection following Idle test
procedures in privately-operated, licensed facilities,
with two qualified inspectors and one HC/CO analyzer
costing up to $2,500 per station, was estimated in
1972 to cost the vehicle owner approximately $5.45,
which included $0.60 for State administrative costs.
® A reduction of inspector training requirements and
initial capital equipment required to perform
emission testing would lower the estimated emissions
inspection fee at licensed stations to $4.00 per
vehicle.
© The pilot program for Idle inspection, as described
in Volume II, showed that the average inspection
charges were $4.05 for inspections in privately
operated stations.
© Vehicle owner maintenance to satisfy Idle emission
limits would average $10.57 per serviced vehicle,
as established in the pilot program. Previous
studies have established the average costs to be on
the order of $17 to $36 per vehicle.
& Emission reductions for Idle inspection coupled with
emission-related maintenance was determined to be
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a function of limits established to reject a given
proportion of inspected vehicles. Analysis and
interpretation of data from Volume II indicate that
emission limits set to fail about 50 percent of
inspected vehicles would be near optimum in terms of
reductions in HC, CO, and N0X.
• With emission limits set to fail roughly half of
the inspected vehicles, the overall emission reduc-
tion which considers both serviced and unserviced
(passed) vehicles would be about 13 percent for HC,
8 percent for CO and 1 percent for NO^.
• Idle emissions inspection at newly constructed,
State-operated facilities would cost the vehicle
owner approximately $2.10 for an annual inspection.
• Vehicle retrofit systems are effective in achieving
further emission reductions. The more costly approaches
such as catalytic converters and LPG fuel systems
are most effective in reducing HC and CO emissions.
Less costly approaches, including exhaust gas re-
circulation, vacuum spark advance disconnect, and
air bleed to the induction system, are not as effec-
tive in achieving reductions of HC and CO. Combina-
tions of these basic approaches also are available.
The most cost-effective retrofit system evaluated
and discussed in detail in Volume II was the air
bleed with an exhaust gas recirculation (EGR) system,
with an average installed cost of $25 per vehicle.
« Vehicle manufacturers' high altitude modification
kits included replacement of various carburetor and
distributor components and adjustment in ignition
timing. In general, these modification kits, as
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described in detail in Volume II, were not effective
in achieving reductions, and in some cases were found
to increase emissions appreciably, notably N0X.
Average installed costs ranged from $4 to $14 per
vehicle.
o Engine tuning specifications as modified for high
altitude operation included modifications to the
vacuum choke kick, basic ignition timing, idle air-
fuel mixture and basic idle speed. As described in
Volume II, these modifications taken individually or
in combinations had degrading effects on NO emis-
sions. However, HC and CO reductions on the order of
10 to 25 percent may be expected. No additional
vehicle owner costs are anticipated because these
modifications, if imposed, would become variations
of an integral part of all vehicle tune-up speci-
fications .
e Mandatory maintenance for all vehicles would involve
the removal and replacement of spark plugs, distri-
butor points and condenser, and carburetor air filter
element. Adjustments would be made as necessary for
proper distributor dwell angle, ignition timing,
idle speed rpm, and carburetor idle air-fuel mixture.
The expected average cost would range from $33 to $59
per vehicle, as determined in Volume II. Expected
emissions reductions would be 19 percent for HC,
9 percent for CO, and 8 percent for N0X.
1.2 VEHICLE SAFETY INSPECTION
e Vehicle safety inspection in accordance with the
U. S. National Highway Traffic Safety Administration
(NHTSA) requirements would require approximately
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ten minutes of inspection task time and would cost
the vehicle owner $2.25 per inspection.
e Safety inspection in accordance with the Colorado
Motor Vehicle Division requirements is more compre-
hensive, would not require additional inspection
equipment than currently used, would involve approx-
imately 13 minutes of task time, and would cost the
vehicle owner $2.90 per inspection.
o Combined safety-emissions inspection at licensed
stations has been estimated to require 22 minutes and
cost the vehicle owner $5.73 per annual inspection,
which includes $4.40 station cost plus $1.33 State
cost. The owner cost for a semi-annual, combined
inspection would be approximately $5.07 per inspec-
tion, with $4.40 for station cost plus $0.67 for
State cost.
• For a combined inspection, roughly 4,200 privately-
operated, licensed stations distributed throughout the
State would be upgraded to include emission testing.
For the State-operated alternative, 66 fixed sites
and 23 mobile units would be required at an initial
investment cost of $11 million and an annual opera-
tion cost of $9.8 million.
e A combined safety-emissions inspection at newly con-
structed State facilities would cost the vehicle
owner $8.30 for an annual inspection and $4.15 for
a semi-annual inspection.
9 Semi-annual safety — emissions inspection is less
costly than annual inspection at State-operated
facilities because of increased utilization which
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approaches maximum design capability. Fixed costs
are allocated over more vehicles inspected leading
to a lower inspection fee.
e The licensed station inspection cost is comprised
of a fixed State administrative annual cost allo-
cated over the number of compliance stickers sold
plus the apportioned station labor rate. Charge-
able inspection time does not vary per visit; only
the allocated State sticker cost varies. Conse-
quently, there is little difference between annual
and semi-annual cost.
1.3 PUBLIC OPINION SURVEYS
& A comparative analysis of three public opinion
surveys conducted in Colorado during 1972 indicated
the following sentiments regarding vehicle emissions
inspection, maintenance and modification:
— There is no majority agreement on what a reason-
able emission inspection fee should be. However,
a fee of $2.00 or less would receive the highest
favorable response.
— The residents are somewhat divided as to who should
operate the emission inspection facilities, a
governmental agency or privately-owned, licensed
stations. On a statewide basis, there is a slight
preference, less than a majority, for licensed
stations. A majority of rural residents favor
licensed stations.
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— The majority of residents favor twice-a-year
emission inspections.
— The majority of residents agree that emission
control strategies should apply to all motorists
regardless of residency and to all vehicles re-
gardless of age.
— The majority of residents would support an emis-
sion control program because they believe that
the automobile is the greatest contributor to
air pollution. However, the residents expressed
a definite lack of knowledge about the existence
of emission control devices on cars and the asso-
ciated costs to have vehicles inspected and ser-
viced for lower emissions.
— With respect to program enforcement and penalties,
the most frequent responses indicated a desire to
keep vehicles off the roads until repaired, and
to provide some form of government financial
assistance to the financially handicapped. The
more popular penalties suggested for emission
control violations included monetary fines up
to $50, an initial warning with a subsequent
monetary fine, the suspension of a driver's
license and the removal of vehicle license plates.
• In regard to the current vehicle safety program, the
public opinion surveys showed that the overwhelming
majority favor the concept, the twice-a-year inspec-
period, and the private garages performing the in-
spection. They are divided as to whether they would
be willing to pay increased inspection fees to im-
prove the program.
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0 In regard to other emission control strategies, the
surveys showed that the majority would favor a mass
transit system although they currently do not use
the system. They are definitely opposed to gaso-
line rationing or toll ramps on major expressways.
They would be receptive to staggered work hours
and limited traffic and parking in central business
districts. The residents would be somewhat receptive
to car pooling, converting existing lanes of traffic
to "bus or car pool" lanes. However, they are op-
posed to building more freeways or increasing traf-
fic speed limits.
1.4 VEHICLE TAMPERING AND MODIFICATIONS
0 With respect to the legality of modifying vehicles
and engines to achieve lower emission levels, the
federal EPA advisory circular on modifications for
high altitude operation, in conjunction with its
interim tampering enforcement policy, provides the
State of Colorado with a sufficient basis of
authority to impose vehicle retrofit devices and/or
high altitude engine modifications. The Colorado
Senate Bill 393 authorizes the Air Pollution Control
Commission to adopt rules and regulations governing
vehicle tune-ups, engine modifications and alterations.
® New car warranty requirements would not be voided
if original-equipment-manufacturer parts are removed
and replaced by after-market parts. The emission
control system is warranted at the time of sale to
be free from defects. After a vehicle and/or engine
modification has been made to achieve lower emissions
if a failure to comply with EPA regulations occurs,
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an assessment needs to be made to establish whether
the fault was due to a defect existing at time of
sale. Component failures related to or caused by
the modifications will not be covered by the war-
ranty.
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SECTION 2
RECOMMENDATIONS
o Vehicle emission inspection coupled with emissions-oriented
maintenance has been shown to be effective in achieving re-
ductions. Because no conclusive relationships exist between
emission levels and vehicle cumulative mileage and/or age
at present, it is recommended that when emission inspection
and maintenance become mandatory, annual emission inspections
are imposed to minimize vehicle owner costs. This inspection
interval may be modified subsequently based on results of
studies currently in process. (see paragraphs 4.2 and 4.5.1)
• Air bleed to the induction system, and air bleed coupled with
exhaust gas recirculation (EGR) have been shown to be feasible
retrofit approaches to further emission reductions. The
Colorado Air Pollution Control Commission and Division should
establish definite procedures for approving these emissions-
related vehicle modifications and/or retrofit devices and
others so that present and future after-market manufacturers
are cognizant of existing State requirements, (see paragraphs
4.3.1, and 6.4.1)
® Based on the pilot program data of Volume II and the analytical
results of Volume III, the APCD and APCC should establish an
implementation plan that considers both vehicle emission in-
spection and retrofit system installation (see paragraphs
4.2.2 and 4.3.2).
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o The Departments of Health and Revenue should establish a data
and information management system to capture inspection data
and to analyze, interpret, and disseminate the information on
program effectiveness for emissions reduction and vehicle
safety, (see paragraphs 4.4, 4.5.2, and 5.3.1)
® A public information program should be established to inform
the motorists initially of the inspection program objectives,
inspected items and related maintenance costs, enforcement
and penalties, and consumer protection plans. Periodically
thereafter, the public should be advised of the inspection
program effectiveness, failure trends, malpractice cases and
dispositions, and other pertinent findings, (see paragraphs
4.5.2 and section 5)
• A public opinion survey should be conducted subsequently
to assess the effectiveness of this public information and
education program, to identify topic areas requiring
further elucidation, and to evaluate control strategies
not previously covered in surveys reviewed herein, (see para. 5.5)
• An opinion survey of business leaders, community leaders,
academic institutions, special interest groups, legislators
and others who are influential in creating, modifying or
swaying public sentiment should be conducted. This survey
would be to determine their sentiments on specific control
strategies, identify other alternatives not considered,
determine the effects of strategies on businesses and the
environment, and define areas or questions requiring further
analysis, (see paragraph 5.5.1)
• Consumer protection plans should consider the continuation
and/or implementation of the following: (see section 6)
(a) Licensed stations initially certified and periodically
recertified four times a year on a quarterly basis.
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(b) Certification of qualified safety and/or emissions
inspectors.
(c) Posted "licensed station" signs for safety and/or
emissions, displayed station and inspector certificates.
(d) Posted inspection fees and related labor rates for
typical safety-related repairs and/or emission-related
adjustments and servicing.
(e) Preparation and presentation of written repair cost
estimates prior to any maintenance or servicing.
(f) Return to owner of original parts removed.
(g) Identification on repair invoice of all work performed,
indication of rebuilt or remanufactured parts used,
associated costs.
(h) Posted sign defining procedure for filing consumer
complaint in cases of alleged malpractice.
(i) Posted sign defining procedure for filing waiver
request in cases of undue hardship or disproportionate
repair cost.
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SECTION 3
INTRODUCTION
The automobile has long been recognized as a major contributor
to air pollution. Studies have shown that the major pollutants
emitted from an automobile are hydrocarbons, carbon monoxide,
and oxides of nitrogen. Three primary sources of these pollu-
tants are the engine crankcase emissions, exhaust emissions, and
fuel evaporative emissions. Federal regulations were first
imposed over a decade ago to limit crankcase emissions. Exhaust:
emissions were regulated initially in 1968, with more stringent
limits imposed in succeeding years. Evaporative emissions were
regulated beginning with the 1971 model automobile.
Recent studies conducted by federal and state agencies and also
by independent laboratories have concluded that vehicles operat-
ing at high altitudes emit greater amounts of pollutants than
similar vehicles operating at or near sea levels. Even vehicLes
that are well serviced and maintained exhibit this phenomenon.
Various emission reduction and control strategies have been
proffered and evaluated in the past. This volume of the high
altitude emissions study addresses those factors that would
facilitate implementing a program involving vehicle inspection,
maintenance, and modification.
3.1 STUDY BACKGROUND
The 1972 Colorado Legislature, under House Joint Resolution
Number 1012, directed the Department of Health to conduct a
study for the Air Pollution Control Commission concerning the
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feasibility and problems of controlling motor vehicle emission
through a statewide implementation of an inspection and control
program. Many issues were cited in the resolution which the
legislature desired to have investigated and evaluated prior
to making any policy decision.
3.1.1 Emission Inspection Study
The Northrop Corporation, in association with its subsidiary
Olson Laboratories, Inc., completed a study for the Health
Department which was designed to evaluate the technical and
economic feasibility and public acceptability of a mandatory
and periodic vehicle inspection program. The study prepared
for the Health Department was completed in November 1972 and
was entitled "Vehicle Emission Inspection and Control Program."
Results,, conclusions, and recommendations from this previous
study and others performed by the Air Pollution Control Division
provided the bases for this subsequent study.
3.1.2 Safety Inspection Study
Also in November 1972, Olson Laboratories completed a study for
the Department of Revenue, Motor Vehicle Division. The objec-
tive of that investigation was to analyze the existing vehicle
safety inspection program, define areas for improvement, and
develop an implementation plan. The Motor Vehicle Safety
Inspection Program study submitted to the Revenue Department
included recommendations concerning safety items tested, in-
strumentation, procedures and document format. Both of these
studies touched on the subject of integrating safety and emis-
sions inspection in a single facility. However, while the
Health Department was interested primarily in the issues and
problems associated with vehicle emission testing, the Revenue
Department was interested primarily in updating and revising
the existing vehicle safety inspection program. Consequently,
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neither study was funded sufficiently to investigate the feasi-
bility of performing both safety and emissions inspections in
either privately-operated, licensed stations or state operated
inspection facilities.
3.2 STUDY OBJECTIVE
The purpose of this study is: 1) to update the findings of the
two previous submittals; 2) to identify the factors and deter-
mine the costs associated with an integrated safety-emissions
inspection program; 3) to evaluate public attitude with respect
to vehicle inspection; and 4) to assess legal changes necessary
for a vehicle modification program.
3.3 STUDY CONDUCT
The general study approach was to review the data used in.the
previous two studies, update the findings based on any data
revisions, evaluate the results to ascertain whether previous
conclusions should be modified, and evaluate previous recommen-
dations to determine if any additional ones were warranted.
Summarized below are the general areas of investigation and the
applicable study approach. Sections 4 through 7 include the
detailed analysis and results.
3.3.1 Vehicle Safety and Emissions Inspection
The previous study for the Motor Vehicle Division (Ref. 3)
resulted in the following general conclusions:
& The public opinion survey indicated that vehicle
owners' attitudes are favorable to the existing
safety inspection. Vehicle owners feel that the
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program is effective, necessary, and adequately
implemented. They are in favor of an improved
inspection program, but are divided on the subject
of an increased inspection fee.
e A major change to the existing safety inspection
program at that time would not be in the best
interest of vehicle owners, inspection station
operators, or the program itself. The reasons
for this position were: 1) lack of firm, existing
National Highway Traffic Safety Administration
standards; 2) lack of conclusive evidence that
State-operated facilities are more effective than
privately-operated stations; and 3) public accep-
tance of the current safety program.
9 The current safety inspection procedure and the
required instrumentation allow excessive arbitra-
riness in interpretation and implementation of
vehicle safety inspection. The current procedure
contains outdated and redundant inspection infor-
mation and can be improved by reorganization,
revision and procedural format changes.
The recommendations from this MVD study were directed toward
the areas of inspection procedures, inspection equipment, inte-
gration of safety and emission inspection, and noise inspection.
These recommendations are summarized below.
• The existing procedure should be reorganized and
reformatted. The restructured procedure should
define the component or function to be inspected,
the approved equipment to be used and the rejection
limits. These individual inspection functions
should be grouped into families and compiled in
a binder which allows convenient editing by adding
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or deleting sections and/or pages. The recommended
preliminary safety procedures, reorganized and re-
formatted, were appended to that report. It was
further recommended that the procedures be finalized
as part of a continuing task.
& Section X (Tools and Equipment) of "Rules, Regula-
tions, Requirements for Motor Vehicle Official
Inspection Stations" should be revised to be
compatible with the recommended inspection proce-
dure. The recommended list, as appended to that
report, was to provide minimal safety inspection
equipment and tool investment, maintain correlative
inspections, and reduce the number of inspection
rejections which were determined previously by
inspector judgment.
o The Idle exhaust emissions inspection should be
initiated in a minimum of 561 official safety
inspection stations distributed throughout the
State capable of measuring HC and CO. Inspection
failure limits for HC and CO should be established
by the Colorado APCD.
© Noise monitoring of in-use vehicles should be
limited to the physical inspections of the con-
dition of the original vehicle equipment intended
to suppress noise. Lack of proven techniques and
measurement equipment for inspection purposes
precluded recommending any instrumented testing
at that time.
Since the submittal of that earlier study, the NHTSA has promul-
gated the vehicles-in-use safety inspection standards (Ref. 1).
Section 4 compares these Federal standards with the Colorado
standards.
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The previous study for the Health Department (Ref. 5) arrived
at the following general conclusions:
e Vehicle emissions of HC and CO at Colorado
altitudes are significantly higher than at low-
altitude cities.
o Periodic vehicle emission inspection, coupled with
emissions-oriented maintenance, is one feasible
approach to achieving reductions in emitted HC
and CO.
• Key Mode inspection, which involves testing the
vehicle under dynamic simulated road-load condi-
tions using a chassis dynamometer, is more effective
than Idle inspection.
o For emissions inspection only, State-operated
facilities are more cost effective than privately-
operated facilities.
o The private sector should perform emission-oriented
maintenance regardless of which sector performs
the inspection.
• Installation of emission control systems on pre-
1968 vehicles on a retrofit basis appears to be
another technically and economically feasible
approach to emission reductions. Further testing
of selected systems was recommended at various
Colorado altitudes.
e The high altitude modification packages designed
by Pontiac Motor Division in Denver appear to be
effective in reducing the emissions of 1972 GM
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vehicles. Further testing was recommended on
other vehicles at various Colorado altitudes to
validate this approach.
e The opinion survey of urban and rural Colorado
residents determined that the majority of the
residents (72 percent) identify the automobile
as the greatest contributor to air pollution.
© The majority of the residents (81 percent) would
approve of a vehicle inspection and control program.
o The majority of the residents (65 percent) feel
that all vehicles, regardless of age, should have
emission control systems installed.
® Residents were divided on who should conduct emis-
sion inspections, with 49 percent favoring private
stations, 44 percent favoring State operation, and
7 percent undecided.
e Residents expressed a definite lack of knowledge
concerning the cost of emission-oriented vehicle
maintenance. Seventy-eight (78) percent did not
know what a realistic amount should be.
Based on that study results and the conclusions, the following
recommendations were made:
o Conduct a pilot Idle emission test program
involving at least three Air Quality Control
Regions (AQCR), metropolitan Denver being one of
these. The other two should be selected accord-
ing to the mean altitude of principal cities.
This pilot program should include all facets of
a statewide program encompassing inspector training.
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approved test procedures and instrumentation,
selected sample vehicles, pre-established emission
failure limits, and data collection, analysis, and
interpretation.
• Develop a public indoctrination program to inform
the residents of the implementation plan, the
benefits of emission inspection and maintenance,
the approximate costs to the vehicle owners, and
the similarities and differences between vehicle
safety and emission inspections.
• Review existing and proposed consumer protection
plans relative to: 1) unfair practices in vehicle
inspection and vehicle service and repair; 2)
penalties for non-compliance; and 3) procedures
for requests-for-waivers and filing of complaints.
Plans should be summarized and communicated to the
general public.
e Design and conduct a study project to evaluate
retrofit device ef fectivene.-ss at higher altitudes.
Similarly, a study project should evaluate the
effectiveness and associated costs of vehicle
engine modification packages.
« Develop or strengthen the APCD's capabilities to
evaluate existing and future vehicular emission
control concepts and systems, to assess after-
market devices, to evaluate emission measurement
instrumentation, to remain continuously cognizant
of emission control strategies and federal standards,
and to conduct investigations on research and
development projects related to vehicle emission
reduction.
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© Compile and analyze pilot program data to verify
emission altitude relationships, modify as neces-
sary, and arrive at inspection failure criteria
for statewide implementation.
The above conclusions and recommendations were the bases for
much of the study areas investigated and discussed in this final
report. Section 4 that follows describes the costs of a program
involving vehicle safety combined with Idle emissions inspection.
Estimates are calculated for both annual and semi-annual inspec-
tion in State-operated facilities and in licensed stations.
State administrative functions are defined and cost-estimated
for both alternatives.
3.3.2 Public Opinion Surveys
Three public opinion surveys conducted in Colorado during 1972
are reviewed. The results are evaluated and compared in Section
5. Each survey was designed to accomplish different objectives.
However, the three have many similar questions. The analysis
was directed primarily toward assessing public attitudes regard-
ing vehicle inspection. Secondarily, opinions related to other
emission control strategies were evaluated. "The State of
Colorado Air Pollution Control Transportation and Land Use Plan,"
as submitted to the U.S. Environmental Protection Agency in
May 1973, was used as a source for identifying emission controJ
strategies currently being considered by the Department of Health
(Ref. 15) .
3.3.3 Vehicle Owner Considerations
Vehicle owner considerations are evaluated in Section 6 to
assist in defining the program management functions. Of primary
concern is consumer protection. Consequently, the areas of
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discussion dealt with certified inspection stations, uniform
procedures and qualified personnel, public display of labor
rates and inspection signs, preparation of written preliminary
cost estimates, replacement parts, and procedures for filing
waiver requests and malpractice complaints.
3.3.4 Legislative Considerations
Various vehicle engine modifications and retrofit devices are
described and evaluated in other volumes of this report. The
legality of these modifications and device installations are
discussed in Section 7. Several of the leading vehicle manufac-
turers, both domestic and foreign, were queried as to the possi-
bility of warranty voidance because of post-delivery vehicle
modifications. Their replies are discussed in Section 7.
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SECTION 4
VEHICLE SAFETY AND
EMISSION INSPECTION
This Section identifies and evaluates the federal and Colorado
requirements for vehicle safety inspection. Various inspection
task times are estimated, generic inspection instrumentation is
defined and the costs estimated, and facility and personnel
requirements are defined. Similarly, the requirements of a
program involving vehicle emission testing and maintenance are
evaluated and their costs estimated. A program involving the
integration of vehicle safety and emission testing, as performed
in privately-operated facilities, is then evaluated. Also, for
comparative purposes, the same integrated testing program per-
formed in State-operated facilities is described and analyzed.
4.1 VEHICLE SAFETY INSPECTION
The Objectives of afty ffiotor Vehicle safety program are to iden-
tify serious deficiencies in safety-related components of vehi-
cles and to effect the required corrective measures. A major
task, however, is to identify and select those vehicle properties
that deteriorate with use or time and which may endanger the
vehicle occupants and the general public. Of equal importance,
is the design and selection of an organized method of detecting
these deteriorated conditions considering a reasonable invest-
ment in time, money, and effort.
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4.1.1 Federal Inspection Standards
The U.S. Department of Transportation, through the National
Highway Traffic Safety Administration (NHTSA), has issued the
Vehicles-in-Use Inspection Standards (Ref. 1). As stated in
the foreword to the standards, the NHTSA does not intend these
in-use standards to supplement existing State standards which
establish a higher performance. Additionally, the federal
standards do not preclude states from establishing or main-
taining standards for other vehicle systems not specifically
covered by the NHTSA inspection standards. As issued, the
initial federal standards are intended to cover those vehicles
and systems whose maintenance in good order have proven to be
critical in the prevention of traffic accidents.
The NHTSA inspection standards and procedures have been adopted
for the hydraulic service brake systems, steering and suspension
systems, and tire and wheel assemblies. Requirements for less
critical vehicle systems are under study; and the NHTSA intends
to take further action as may be appropriate to cover them
(Ref. 1). Appendix A summarizes the inspection standards as
published in the Federal Register.
4.1.2 Colorado Inspection Standards
The Department of Revenue, Motor Vehicle Division, administers
the vehicle safety inspection program. Vehicles are inspected
twice a year by licensed facilities following the procedures-
and policies promulgated in the "Rules, Regulations and Require-
ments for Motor Vehicle Official Inspection Stations" (Ref. 2).
The Colorado inspection standards and procedures include the
following vehicle systems: wheels and tires; steering, align-
ment and suspension; brakes; lighting and electrical; exhaust
and fuel systems; body and sheet metal; and speedometer.
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The Motor Vehicle Division has reviewed the current rules and
regulations to determine the adequacy and shortcomings of the
procedures and inspecting instrumentation (Ref. 3). The
analysis and evaluation resulted in methods of improving safety
inspection effectiveness through procedural, instrumentation,
and documentation changes. It should be noted that these recom-
mendations were the result of an in-depth investigation of
existing studies and State standards, and was performed approxi-
mately a year before the aforementioned federal inspection
standards were recorded in the Federal Register. As such, the
recommended procedures are much more detailed than those in the
federal standards. However, a few items listed in the federal
standards do not appear in the Colorado standards.
For example, the federal standard requires at least one front
and one rear wheel be removed for visual examination of brake
system components. Current Colorado standards require at least
one front or one rear wheel be removed. Also, there are several
differences in the test variable using the same test methods.
For example, pedal force exerted over a specified time period may
differ between federal and Colorado standards; however, the test
procedure is similar. In general, Colorado test requirements
are more detailed but not necessarily more stringent than the
federal requirements.
Appendix B contains the recommended inspection procedure, equip-
ment, and rejection limits as extracted from the referenced
study performed by Olson Laboratories under contract with the
Motor Vehicle Division.
4.1.3 Estimated Inspection Task Time
Appendix C contains the detailed analysis of inspection task
times. These estimates are based on previous work-study programs,
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discussions with equipment manufacturers, and observations of
inspection sites.
Table 4-1 shows the estimated elapsed time for one vehicle to
be inspected in accordance with both the federal and Colorado
standards. Note that the Colorado standards include all require-
ments suggested by the federal in-use vehicle standards plus
others.
The inspections performed according to the federal standards
would require about 10 minutes of an inspector's time. This
assumes that all test equipment is available and operational
for his immediate use. To perform the inspections according
to Colorado standards, approximately 13 minutes of an inspec-
tor's time would be required. Again, this assumes uninterrupted
inspection and all test equipment available and operational.
If two wheels are removed instead of only one, as currently
required, then roughly 14 minutes (12.6 original plus 1.5 addi-
tional) of an inspector's time would be required.
4.1.4 Safety Inspection Equipment
Based on the analysis of Colorado inspection standards, a revised
equipment list was recommended in the study performed for the
Motor Vehicle Division (Ref. 3). Appendix D includes the recom-
mended equipment list for privately-operated, safety inspection
stations. The equipment and tool list reflects those items
necessary to ensure that every inspection station has the capa-
bility of performing vehicle inspections as specified by the
recommended procedure. This recommended list is designed to
provide minimal safety inspection equipment and tool capital
investment, maintain correlatable inspections, and reduce the
number of inspection rejections which are now determined by
inspector judgment.
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Table 4-1. ESTIMATED INSPECTION TIMES*
Time
(minutes)
Vehicle System
Federal
Colorado
Standards
Standards
Service Brake
4.0
2.5
Brake Power Unit
0.5
0.5
Steering System
1.0
1.0
Suspension System
0.5
0.5
Tires
0.5
0.5
Wheel Assemblies
1.0
1.0
Lighting and Electrical
1.3
Glazing
0.2
Body and Sheet Metal
0.5
Exhaust and Fuel System
1.0
Inspection Subtotal
7.5
9.0
Vehicle Receiving
0.3
0.3
Vehicle Certification
1.3
1.3
Non-Functional Time
1.0
2.0
Inspection Total
10.1
12.6
*See Appendix C for detailed analysis.
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4.1.5
Estimated Safety Inspection Cost
The federal vehicle in-use inspection standards do not mandate
any new safety-related vehicle testing. Accordingly, privately-
operated inspection stations in Colorado are not required to
invest in additional instrumentation. Assuming that flat rate
labor charges remain unchanged, the inspection fee can be
approximated on labor charges only. Based on a limited survey
of service facilities, a representative labor charge in Colorado
is estimated at $10 per hour. This labor rate is based on
station personnel wages, benefits, equipment and building depre-
ciation, and other operating expenditures.
Considering the uncertainty of cost escalation, the variation
in labor rates, and the variability of personnel task times,
the estimated time for performing the federal and Colorado
inspections is increased by 15 percent. Consequently, the time
to perform the federal procedures is increased to 12 minutes
and the Colorado procedures to 16 minutes. The resulting inspec-
tion fees would then be as follows:
12
Federal Procedures Fee = 777 x $10 = $2.00
oU
16
Colorado Procedures Fee = x $10 = $2.65
Currently, the inspection stations pay the State $0.25 for each
inspection sticker. The income from the stickers pay the State
expenses for managing the statewide program. Assuming that
State expenses will not increase because of the new procedures,
then it can be assumed that the sticker cost will remain unchanged.
Thus, the new estimated inspection fees would be:
Federal Procedures Fee = $2.00 + $0.25 = $2.25
Colorado Procedures Fee = $2.65 + $0.25 = $2.90
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The validity of this assumption regarding State expenses will
be analyzed in a subsequent section.
4.2 VEHICLE EMISSION INSPECTION
Many studies and experiments have been conducted to determine
the effectiveness of vehicle emission inspection and maintenance.
The consensus of findings has been that regular and periodic
service and repair of emission-related vehicle components has
benficial effects in reducing exhaust emission of all light-
duty vehicles, whether emission-controlled or uncontrolled.
Recognizing these benefits, both governmental agencies and
private businesses have conducted further investigations to
determine the more effective methods of conducting inspection
and maintenance.
In one of these investigations, five alternative inspection/
maintenance concepts were evaluated for possible statewide
implementation (Ref. 4). Of the five alternatives, Idle test
and Key Mode test were determined to be the most feasible for
a state program both technically and economically.
Recently, the State of Colorado, Department of Health, contracted
with Olson Laboratories, Inc., to evaluate the costs, benefits,
and public acceptability of instituting a statewide vehicle
emission control program of inspection and maintenance. Addi-
tionally, as a secondary control measure, the State desired to
determine the feasibility of requiring the installation of
exhaust emission controls on a retrofit basis (Ref. 5). The
following paragraphs present a summary of the findings from this
previous study. Where applicable, recently acquired data from
other studies are included. Because the information presented
is in summary form, it would be advisable for the reader to
refer to the original study in order to grasp fully the study
-------
scope, methodology, and context from which these results were
taken.
4.2.1 Evaluation of Emission Inspection Procedures
Two inspection procedures were evaluated — Idle and Key Mode.
Idle emission testing requires sampling the exhaust emission
of a vehicle during curb idle and also with the engine running
at 2,500 rpm and the transmission in neutral. The sample
is analyzed for levels of hydrocarbons (HC) and carbon monoxide
(CO) . See Appendix J for a copy of the Idle Emission test procedures.
Key Mode testing involves running the vehicle under dynamic,
simulated, road-load conditions using a chassis dynamometer.
Sampled exhaust emissions are analyzed while the vehicle is
operated under conditions of idle, high cruise (approximately
50 mph) and low cruise (approximately 30 mph). Gas analysis
is done for levels of HC and CO. Under these simulated road-
load conditions, oxides of nitrogen (NO^) also may be analyzed
with proper instrumentation.
4.2.2 Inspection and Maintenance Effectiveness
The initial study report and the findings were needed to satisfy
certain legislative requirements. Time and economic constraints
precluded the inclusion of an experimental phase during which
assorted vehicles could undergo emission testing and servicing.
Also, it was concluded that sufficient test data existed from
other studies to provide the necessary data base for the investi-
gation.
Information on emission testing and maintenance relative to vari-
ous operating altitudes was acquired from the State of Arizona
-------
Department of Health, Air Pollution Control Division, Vehicular
Emissions Control Section. Data on several thousand vehicles
tested at various altitudes ranging from near sea level (Yuma
at 140 feet), to 6,900 feet (Flagstaff), were processed by
the Colorado APCD.
Additional emission test data were acquired in Denver at 5,280
feet and at Alamosa at 7,540 feet. The mobile van for emission
testing was provided by the State of Arizona through arrangements
by the Colorado Air Pollution Control Commission.
Through special arrangements with the EPA, Region VIII, Denver,
the results of an emission test program involving 75 emission -
controlled vehicles (1968 to 1972) were available for inclusion
in the study. Other EPA studies performed by Olson Laboratories
as part of the national surveillance program also were referenced
for emission test data involving Denver vehicles as well as
cities such as Los Angeles, Detroit, Houston, and Washington,
D.C. Vehicles for these surveillance programs included 1968
through 1971 models.
Another source of data was the recently completed study (1971)
performed in California for the Air Resources Board which
involved testing 1,100 vehicles of model years 1955 to 1970
(Ref. 4). All of these data were used in conjunction with
another EPA study, the Short Cycle Project (Ref. 6), to arrive
at a composite representation of vehicles operating at various
altitudes similar to that of Colorado. Regression equations
were developed to establish the relationship between emission
levels of HC and CO as a function of operating altitude for
various emission control vehicle classes.
Table 4-2 shows the average expected emission reductions for
serviced vehicles only, (i.e., those inspected vehicles that
exceed the established limits and are subsequently serviced ana/
or repaired to satisfy these limits).
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Table 4-2. EMISSION REDUCTION FOR SERVICED
VEHICLES ONLY
Inspection
Emission
Reduction (Percent)
HC
CO
NO !
X i
Idle
45
34
- 6* '
Key; Mode
58
47
-14
*Minus sign
denotes increase.
Table 4-3. EMISSION REDUCTION
FOR TOTAL
1
VEHICLE
POPULATION
! Calendar
Idle
Test*
Key Mode*
Year
HC
CO
HC CO j
1974
5.1
6.8
00
0D
i—¦
1976
4 . 7
7.0
CO
-J
o
1979
4 . 2
6.8
7.6 6.7 1
1982
3 . 5
6.0
6.7 5.7
*HC and CO reductions are in percentage of total emissions
before inspection and maintenance. Emission limits set to
Eail 30 percent of inspected vehicles, reductions include
50 percent degradation.
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While significant changes can be expected for individual vehicles,
as shown in Table 4-2, it must be recognized that in an inspec-
tion/maintenance program, not all vehicles will be or need to be
serviced. The number of serviced vehicles is related to the
rejection limits established. These limits in turn establish
the program effectiveness (emission reduction measurement).
The effects of varying the emission limits such that various
proportions of vehicles fail the inspection were analyzed also
using the composite data with particular emphasis on the recent
EPA Short Cycle Study (Ref. 6). The analysis indicated the
following could be expected for a statewide program:
© Both Idle and Key Mode emission inspection, fol-
lowed by emission-oriented maintenance of failed
vehicles, will result in reductions of HC and CO.
If implemented on a statewide basis, the resulting
change in HC and CO emitted by light-duty passenger
vehicles (roughly 1.2 million) will be as shown
in Table 4-3.
The emission reductions (percentages) are based
on establishing emission limits such that 30 per-
cent of inspected vehicles will require mainte-
nance.. In accordance with the EPA recommendations,
a 50 percent degradation factor has been included
(Ref. 7). Vehicle population, annual growth,
model-year distribution, and vehicle mileage as a
function of age were varied to reflect historical
federal and State trends.
e The EPA Short Cycle Project (Ref. 6) concluded that
emission reductions realized from 50 percent rejec-
tion would not be much higher than from a 30 per-
cent rejection for either Idle or Key Mode inspec-
tion and maintenance. As a matter of interest, the
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Short Cycle Project results are those cited in the
EPA Implementation Plan requirements (Ref. 7).
® The effectiveness of an inspection-and-maintenance
concept may be enhanced by decreasing the inspec-
tion interval. This, however, is related to vehi-
cle emission deterioration with time and/or mile-
age. As noted earlier, the EPA currently suggests
a straight-line, 50 percent degradation following
maintenance (Ref. 7). More definitive deteriora-
tion factors may be forthcoming from a study cur-
rently in progress by the Colorado APCD, the
results of which are due in June, 1974. As part
of a previously completed study (Ref. 4), Olson
Laboratories evaluated 552 vehicles which were
serviced and retested approximately three to eight
months following the respective servicing. Results
were somewhat inconclusive due to the limited
operating time and the fairly wide scatter of
data points. However, using the least-squares
method to linearize the plots, the results indi-
cated that for 10,000 miles, the expected degra-
dation would be 25 percent for HC and 44 percent
for CO, with NO^ decreasing by 17 percent.
Olson Laboratories currently is conducting a degradation study
that involves 432 vehicles. The program will be conducted over
18 months; and each vehicle will have its exhaust emissions
sampled once every three months. The vehicle fleet will be
comprised of 1968 to 1974 model years equally divided into
three control groups. Results of this study will be available
in 1975.
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High Altitude Emission Inspection and Maintenance — Volume II of
this report describes the pilot program which was conducted to
evaluate the costs and effectiveness of vehicle Idle emission testing
coupled with related maintenance is performed in the Denver area.
The program involved 300 sample vehicles which were tested ini-
tially by Automotive Testing Laboratories (ATL) to establish the
emission baseline profile. Vehicles were then dispatched to one
of ten service stations, independent garages, or manufacturers'
dealers having pre-trained technicians. Using the inspection
procedures similar to those in Appendix J, the service represen-
tatives performed the test procedures and the necessary maintenance
as required. A post-maintenance emission test was then performed
by ATL to establish the changes in baseline profile.
The following summary observations were noted during the test
program. For more detailed information, the reader should refer
to volume II.
® Emission reductions of HC, CO and NOx are improved
with increasing failure rates, as shown below.
Rejection Rate
(Percent)
Emission Reduction (Percent)
HC CO NOx
20
30
40
50
60
7.6
10.5
11.2
12.7
13 .2
3 . 5
5.5
6.8
8.3
9.2
0.7
1.1
1.4
1.2
1.8
9 Inspector training was adequate but could be im-
proved in areas such as knowledge of emission control
system concepts and necessity for proper data recording
and forwarding.
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Emission test data correlation between the control
laboratory (ATL) and the service stations indicated
the need for improvement in correlatable emission
measurements between similar instrumentation.
In general, emission limits established to fail or
reject a given proportion of inspected vehicles
should yield the desired rejection rate. Factors
that tend to cause deviations from the desired
rate of failures are: (1) expected statistical
variations in vehicle emissions based on fleet
sample size; (2) instrumentation calibration and
correlation to laboratory standards; and (3) in-
spection personnel wort habits as influenced by
training, experience and motivation.
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4.2.3 Inspection Fee and Maintenance Cost Estimates
Two major costs to the vehicle owner are the vehicle emission
inspection fee and vehicle repair and service costs to meet
the State-established emission standards. The inspection fee
may be estimated by using standard labor rates, as in a
privately-operated service facility, or by allocating the cost
per vehicle, as in a State-operated inspection facility.
In the previous study for the State of Colorado, it was deter-
mined that the following inspection fees could be expected in
State-operated, emissions-only, inspection facilities: Idle,
$2.10 per annual inspection; Key Mode, $2.67 per annual
inspection (Ref. 5). For the inspections to be performed by
licensed, privately-operated inspection facilities, the Idle
inspection fee would be $5.45 and Key Mode would be $8.91 for
an annual inspection. These fees for private facilities included
all costs — direct labor, overhead and State administration.
The latter cost would be similar in nature to the current com-
pliance sticker cost ($0.25), but would be relatively higher.
Costs incurred by the vehicle owner for maintenance to satisfy
emission standards will vary according to vehicle size, state
of repair, accumulated mileage, and previous maintenance prac-
tices. Many investigations have been made of the associated
factors of various directed-maintenance activities to determine
the more cost-effective vehicle service/repair procedures,
emission reductions, and owner costs (Refs. 4; 5; 6; 7; 8).
Due to the wide-ranging objectives of these studies and others,
plus the different time periods and locations where these inves-
tigations were conducted, placing a firm cost estimate on owner
costs is difficult. However, deriving a range of values for
vehicle classes is possible. Listed below are the expected
owner costs for vehicle maintenance. Note that these are cost
-------
ranges for typical vehicles. Vehicles requiring minor adjust-
ments may incur servicing costs of $5 to $10, whereas some
vehicles requiring major work can expect costs of $100 to $150.
EXPECTED VEHICLE MAINTENANCE COSTS
Inspection Pre-1968 1968 to 1972
Idle $25-34 $17-36
Key Mode 17-36 13-30
As part of the previous study (Ref. 5), 288 dealers were queried
on several aspects of vehicle maintenance practices and costs.
These are listed below in Table 4-4.
Table 4-4. SURVEY RESULTS OF MAINTENANCE
COST ESTIMATES
Action
Range
(Dollars)
Minor Engine Idle Adjustments
5- 8
Major Electrical Tune-Up
(plugs, points, condenser, idle
adjustment)
15-35
Minor Carburetion
(air filter replacement, PCV,
choke adjustment)
4- 8
Carburetor Modification
(jet change, float adjustment)
7-13
Major Carburetion
(overhaul or replacement)
40-47
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Inspection Costs Incurred During Pilot Test Program — Volume II
of this report details the inspection and maintenance costs
actually expended during the 300-car pilot test program. To
perform the Idle emission test, the service stations charged an
average of $4.05 per vehicle. The inspection charges by indi-
vidual station ranged between a low of $1.50 per vehicle to a
high of $6.00 per vehicle.
For vehicles receiving maintenance and repair, the average cost
was $10.57 per vehicle. The range of average maintenance cost
by individual stations varied from a low of $2.53 per vehicle to
a high of $14.25 per vehicle.
The inspection costs are relatively consistent with findings
noted in this study and others. However, the maintenance costs
appear to be relatively low as compared with those noted above
which reflect the composite of several similar experimental
investigations. When viewed in light of the data presented in
Table 4-4, it is reasonable to assume that the majority of ser-
viced vehicles received minor engine idle adjustments and/or minor
carburetion adjustments and parts replacement.
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4.3
VEHICLE RETROFIT AND MODIFICATION
Vehicle exhaust emissions may be reduced by the installation of
selected retrofit devices and/or engine modifications. The
Federal EPA evaluated over 60 retrofit devices during a recent
study (Ref. 9). The devices and modifications were tested on
previously uncontrolled vehicles (pre-1966 models) with emission
testing done near sea level conditions. Consequently, further
testing was recommended during the earlier Colorado study
(Ref. 5) to validate the findings at higher vehicle-operating
altitudes and to extend the investigation to include controlled
vehicles.
4.3.1 Retrofit Effectiveness Analysis
The EPA study (Ref. 9) concluded that for previously uncontrolled
vehicles, exhaust emission may be reduced by retrofit devices
and/or engine modifications. In general, the more sophisticated
approaches prove to be highly effective with correspondingly
higher vehicle-owner costs. Several approaches exhibited
relatively good effectiveness measures (emission reduction) and
reasonable owner costs. These retrofit approaches are:
• Ignition timing modification with lean idle
adjustment
• Exhaust gas recirculation (EGR)
• Vacuum advance disconnect (VAD)
• EGR combined with VAD
For a statewide implementation of retrofit device installation
on pre-1968 automobiles only, the emission reduction estimates
would range between 1.5 to 2.5 percent in HC during 1976 down
-------
to 0.5 to 0.9 percent in 1982. Similarly for CO, the estimated
reductions would be 3.8 to 5.6 percent in 1976 down to 1.5 to
2.2 percent in 1982. These reductions include a 50 percent
degradation factor. Without degradation, the reductions
essentially would be twice as much. These reductions are based
on the expected total vehicle population and model year distri-
bution anticipated during the future years. Consequently,
the effectiveness initially is small because of the quantity
of pre-1968 vehicles in operation. Also, the emission reduc-
tions realized in succeeding years decreases further because of
the rapid attrition of vehicles after about 6 to 7 years of
model introduction. As an example, historical data have shown
that roughly 93 percent of a particular model are still regis-
tered 7 years after production. However, only 47 percent are
in operation 3 years later (after 10 years), and 17 percent
after 13 years (Ref. 10).
The effectiveness of a retrofit program may be enhanced consid-
erably if the remaining vehicles, 1968 and newer, could be similar
equipped. Alternative methods for these newer vehicles were
evaluated and discussed in other volumes of this report.
In selecting the approaches for vehicle retrofit, several
factors contribute toward establishing technical and economic
feasibility. The EPA study previously cited (Ref. 9) identified
the following:
o~ Emission reduction effectiveness — The capability
to reduce vehicle emissions of HC, CO and NO for
x
various model years.
® Driveability and safety — Effect on vehicle per-
formance characteristics such as starting, idling,
acceleration, and fuel economy; and effects or
presence of safety hazards to vehicles or occupants
due to device installation.
-------
• Reliability — The calculated mean-miles-before-
partial or total failure of the retrofit device
as a function of vehicle cumulative mileage.
• Maintainability — A measure of the amount of main-
tenance required to sustain desired performance of
the device, as stated in terms of periodic preven-
tive maintenance and corrective maintenance labor
and materials.
• Installation requirements - Defined in terms of
special equipment, technical skills, and expended
time necessary to complete the installation and
checkout of the device.
« Motorist costs — Stated in terms of initial cost
(acquisition and installation) and recurring cost
(maintenance and performance penalties).
4.3.2 High Altitude Retrofits and Engine Modifications
Volume II of this final report describes the pilot program to
assess the effectiveness of several emission control strategies
involving vehicle retrofitting and engine modifications. Fifty
vehicles previously cycled through the Idle inspection and main-
tenance test program were selected to represent a cross-section
of the more popular vehicles. The following vehicle modifications
were selected for evaluation:
-------
Model Year
Generic Description Vehicles Modified
Catalytic Converter
LPG Fuel System
Air Bleed
Carburetor Float Bowl
Pressure Regulation
Air Bleed with Exhaust
Gas Recirculation (EGR)
EGR
Air Bleed with vacuum Spark
Advance Disconnect (VSAD)
EGR with VSAD
1968-1972
1968-1972
1968-1972
1968-1972
1964-1972
1968-1972
1964-1967
1964-1967
The sample vehicles were inspected, malfunctions corrected, mar-
ginal parts replaced, and engines adjusted to meet manufacturers'
specifications. Retrofit devices were installed by their re-
spective representatives after which emission measurements were
made. Driveability testing and performance assessment followed
the procedures described in Volume II. Results of the evaluation
phase also are presented in Volume II. A summary of the findings
are extracted and listed below:
© A catalytic converter system requires a relatively
large amount of installation time and effort if
the vehicle is not previously equipped with air pump.
The expected cost range is $55 to $155 per vehicle.
Roughly 60 percent of 1968 to 1970 vehicles can be
modified with these systems, as well as about 75
percent of the 1971 vehicles, and essentially all
newer vehicles. Converters require that the ve-
hicle use low lead or non-leaded gasoline. Emission
reductions are on the order of 72 percent for HC,
84 percent for CO, and an expected increase in NO _ of
3 percent.
-------
LPG systems require the installation of a supple-
mental fuel tank especially designed for the higher
vapor pressure experienced by LP gas; and the car-
buretor must be replaced with one designed for the
LPG. System suppliers believe that conversion of
fleet vehicles having high utilization (about 25,000
miles per year) would be most feasible. Installed
cost is estimated to be about $650 per vehicle,
highest of all retrofit systems evaluated. Emission
reductions expected are 41 percent for HC and 54 per-
cent for CO with a nominal 4 percent increase in NOx.
Air Bleed systems can be installed on nearly all
light-duty vehicles with few exceptions. It was the
least costly retrofit system evaluated, having an
estimated installed cost of $20 per vehicle. Emis-
sion reductions expected are 18 percent for HC, and
42 percent for CO, whereas NOx i-s expected to in-
crease by 24 percent.
Carburetor Float Bowl Pressure Regulation systems
can be installed on all light-duty vehicles with
few exceptions. The estimated installed cost is
$24 per vehicle. The emission reductions are es-
timated to be 18 percent for HC and 30 percent for
CO with an expected increase of 23 percent for NOx.
Air Bleed with EGR systems can be installed on all
1964 to 1972 vehicles except those equipped with fuel
injection or multiple carburetors. The installed
cost is expected to be about $35 per vehicle. For
the 1964 to 1967 vehicles, the emission reductions
would be 22 percent for HC, 21 percent for CO, and
25 percent for NOx. Similarly, for the 1968 to 1972
-------
vehicles, the reductions would be 17 percent for
HC, 48 percent for CO, and 29 percent for N0X.
® EGR systems can be installed on all vehicles of the
model years 1964-1972 except those with special
carburetion systems, as noted above. The average
installed cost would be $32 per vehicle. The es-
timated average emission reductions would be
seven percent for HC, two percent for CO, and 43
percent for NOjr. Additionally, a relatively large
penalty on the order of a nine percent decrease in
fuel economy may be experienced.
e Air Bleed with VSAD systems may be installed on all
1964 to 197 2 vehicles except those not equipped
with vacuum spark advance. The expected installed
cost would be $25 per vehicle. The emission re-
ductions would be about 19 percent for HC, nine
percent for CO, and 47 percent for NOx. A fuel
economy decrease of about 8 percent may be expected.
© EGR with VSAD systems may be installed on all 1964
to 197 2 vehicles except those not equipped with vacuum
spark advance. The installed cost would be $25 per
vehicle, on the average. Expected emission reduc-
tions would be about 26 percent for HC, 11 percent
for CO, and 28 percent for NO .
X
4.3.3 High Altitude Manufacturers' Kits
As described in Volume II of this report, 100 of the 300 vehicles
previously processed through the Idle inspection phase were selec-
ted to be modified with kits supplied by the domestic vehicle
manufacturers. Only 1968 to 1973 vehicles were used during this
-------
evaluation. The kits included various carburetor and distributor
replacement parts. Installation procedures also included re-
adjusting ignition timing and idle adjustments. See Volume II
for specifics on altitude modification kits. The vehicle test
sequence was the same as that followed for the retrofit vehicle
sample. The observations and findings as detailed in Volume II
are summarized below.
• High altitude kits provided by General Motors, Ford,
and American Motors were equally applicable to all
of their respective 1968 to 1973 models, with few
exceptions. Kits provided by Chrysler Corporation,
however, were limited to vehicles equipped with
Carter two-venturii carburetors only.
• No special training of installers was required by
manufacturers, nor were any installation procedures
or guidelines included with the kits. Several
vehicle owner complaints on vehicle operation sub-
sequent to modification could be attributed to
contamination of carburetor choke and linkages, and
distributor mechanisms. Additional sources of dis-
satisfaction were attributed to related settings,
adjustments or parts which were marginal initially
and were negatively affected by the modifications
or by the modification process.
• The high altitude kits required from 30 to 50
minutes for installation. The parts cost from
$0.30 to $3.80 depending on vehicle manufacturer
and type. For this pilot program, the average cost
to modify the vehicles ranged from $3.90 to $13.60
installed. It is expected that these costs would
be relatively higher if installment was required
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for the public sector in general without more spe-
cific, detailed instructional procedures.
The American Motor's high altitude kits, as applied
to a sample of four vehicles, included a change in
the metering jet, an advance in ignition timing,
and general idle adjustments. The kits resulted in
increases of 9 percent in HC, 12 percent in CO, and
17 percent in N0X.
^The Ford Motor Company kits, as applied to a sample
of 28 Fords and eight Mercurys, included changes
in fuel metering jets and power valve assemblies,
an advance in ignition timing, a modification to
the choke setting, and idle adjustments. For the 28
Fords that were modified, the emission reductions
were 0.5 percent in HC and 8 percent in CO, with an
increase of 20 percent in N0X. Similarly, for the
eight Mercurys, the reductions were 2.5 percent in
HC and 13.5 percent in CO, and an increase of four
percent in N0X.
The General Motors kits, as applied to 48 vehicles,
included recalibration of the distributor vacuum
advance, modification to lean power enrichment
springs, and general idle adjustments. In general,
the kits tended to increase HC emissions by six to
eight percent, decreased CO emissions by three to
18 percent, and increase NOv by 19 to 23 percent.
* X
A notable exception were the two modified Cadillacs
which exhibited an HC increase of 49 percent, a
CO reduction of 23 percent, and an NO increase of
139 percent.
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• The Chrysler Corporation kits, as applied to 15
vehicles, included a change to leaner fuel metering
jets, a change in fuel mixture enrichment springs,
an advance in ignition timing and general idle ad-
justments. In general, the modifications to the
Plymouths and Dodges resulted in reductions of HC
of 28 to 33 percent, 54 to 60 percent reduction in
CO, and increases of 80 to 98 percent in N0X. The
single Chrysler in the sample exhibited an increase
of 77 percent in HC, a decrease of six percent in CO,
and an increase of 40 percent in NO after modifi-
cation.
4.3.4 High Altitude Modified Engine Tuning
Volume II describes the experimental program to assess the effec-
tiveness of various engine parameter adjustments as performed
individually and in combinations. Of the 300-vehicle sample,
a subset of 25 were selected for this assessment. The four
basic engine variables related to vehicle emissions selected for
evaluation were as listed below:
• Vacuume choke kick which was set leaner than
manufacturer's specification.
• Basic ignition timing which was advanced eight de-
grees from manufacturer's specification.
• Idle air/fuel mixture which was set leaner than
manufacturer's specification as expressed in a
decrease of idle speed by 200 rpm. The drop in
idle rpm caused by leaning the air/fuel mixture
was recovered by adjusting the idle speed screw.
-------
© Basic idle speed which was adjusted for net increase
of 200 rpm beyond manufacturer's specification.
The variables above are not independent. Because of known inter-
actions, ATL developed an orderly sequence of adjustments. A
set of eight sequences were determined; and the 25 vehicles were
exposed to each of these sequences. The order in which each of
these vehicles were sequenced, however, was selected at random.
Results of the evaluation indicated the following:
© In general, the four basic engine variables, as
modified individually, have little effect (about
one percent or less change) on HC and N0X. How-
ever, CO reductions on the order of 13-22 percent
are achievable for each basic modification.
© Taken in combinations of two basic modifications,
the results appear to be similar to those taken
individually. Of the six combinations of two, HC
changes were less than one percent increase or
decrease, CO reductions ranged between 15 and 24
percent, and NO increased between 0.9 and 1.3 per-
cent.
9 These engine modifications in general led to some
noticeable deterioration in driveability and per-
formance .
• The costs associated with these modifications were
not ascertained. Presumably they would be considered
as normal labor incurred during engine tune up with
no additional charges.
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4.3.5
High Altitude Mandatory Engine Maintenance
A total of 158 vehicles from the 300-vehicle sample were used to
evaluate this emission control concept. As described in Volume
II of this report, the mandatory maintenance concept involves the
following actions on all vehicles:
9 Removal and replacement of spark plugs, distributor
points and condenser, and carburetor air filter
element.
• Adjustment of distributor dwell angle, ignition
timing, idle speed rpm, and carburetor idle air/fuel
mixture.
In a mandatory maintenance program, each of the above actions would
be performed. However, during the actual experimental phase,
only those items diagnosed to be marginal, malfunctioning, or
misadjusted were corrected. It was assumed by the investigators
that the replacement of acceptable parts would have minimal
effects on the overall vehicle emissions.
• The estimated labor hours for mandatory maintenance,
as determined from published information, range from
1.6 to 2.8 hours depending on vehicle make and num-
ber of engine cylinders. Based on existing rate of
$12 per hour flat rate, the labor costs range from
$19 to $34 per vehicle. Replacement parts costs
range from $9 to $25. Total maintenance costs range
from $33 to $59 per vehicle.
• For the fleet of 158 vehicles receiving mandatory
maintenance, the fleet average emissions were re-
duced 19 percent for HC, nine percent for CO and
eight percent for N0X.
-------
® Reliability — The calculated mean-miles-before-
partial or total failure of the retrofit device
as a function of vehicle cumulative mileage.
o Maintainability — A measure of the amount of
maintenance required to sustain desired perfor-
mance of the device, as stated in terms of periodic
preventive maintenance and corrective maintenance
labor and materials.
© Installation requirements — Defined in terms of
special equipment, technical skills, and expended
time necessary to complete the installation and
checkout of the device.
9 Motorist costs — Stated in terms of initial cost
(acquisition and installation) and recurring cost
(maintenance and performance penalties).
4.4 DATA AND INFORMATION PROCESSING
Data and the information derived from it are essential for both
technical and administrative purposes. Technically, they are
required to establish whether a vehicle satisfies the safety
inspection standards and/or the emission standards. Administra-
tively, the information is necessary to evaluate the effective-
ness of the inspection program.
To satisfy these information requirements, one basic source of
data exists — the test vehicle. Its data characteristics are
grouped and identified as follows:
-------
Administrative
e Vehicle owner name, address
• Schedule — last inspection, next inspection
• Vehicle registration number, liceftse plates
Technical
o Model year and make
o Engine size and class
® Transmission class (manual, automatic)
e Mileage — last test
© Emission control type — engine modification, air
injection, EGR, VAD
® Emission profile — last pass levels
• Service brakes — pass, fail
• Steering system — pass, fail
© Suspension system — pass, fail
® Tires — pass, fail
• Wheel assemblies — pass, fail
• Lighting and electrical systems — pass, fail
• Glazing — pass, fail
• Body exterior — pass, fail
• Exhaust system — pass, fail
At the inspection facility, acquired test data must be compared
against predetermined emission limits to determine whether the
inspected vehicle passes the test or requires some corrective
measures. The method by which this determination is made is
dependent on the sophistication of the data processing capa-
bilities incorporated in the facility. Consideration also must
be given to any subsequent data analysis and information retrieval
required at State program offices.
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4.4.1 Manual System
In a manually operated data processing system that would be
typical of private garage operation, the technician notes and
records test data from display meters. Referencing a set of
tables or calibration charts, the technician then can ascertain
whether the test vehicle emission levels comply with the appro-
priate limits as established for the particular model year, make,
engine size, and emission control systems. Comparative results
are noted in the inspection form, along with the decision (pass,
fail), and next scheduled inspection date.
For vehicle safety inspection, the existing data forms may be
used. However, if emissions inspection will be performed in
conjunction with safety inspection, a new form would be required.
To facilitate program monitoring, surveillance and appraisal,
the new form should include the items identified earlier, as a
minimum. The items may have further vehicle component descrip-
tions to permit more detailed analysis of failure trends by
vehicle system, component, manufacturer, model year or period.
Results of the analysis could be used to validate initial
inspection standards, propose revised standards for existing
vehicles based on program objectives, and establish initial
standards for current production models based on historical data.
Appendix K includes copies of inspection forms that are manually
completed by inspecting personnel. One format used in the Wash-
ington, D.C., facility requires the inspector to signify failed
items by punching the appropriate block. The form is a foldover
type with both sides printed. When the form is folded over and
punched, one half is given to the vehicle owner; and the other
duplicate half is kept by the inspecting facility. At the in-
specting facility, the inspection data is transferred from the
punched card to the data processing system via a keyboard oper-
-------
ator. In addition to safety and emissions inspection data, the
D. C. form also includes information to denote whether the sub-
ject vehicle was previously involved in a traffic accident or
was a manufacturer's recall.
Another inspection form included in Appendix K is that used in
Ontario, Canada by the Department of Transportation. The form
is completed in duplicates by the inspector marking those items
found to be in non-compliance. As completed in governmental
inspection stations, the original is issued to the motorist,
and the copy is retained at the inspecting station.
4.4.2 Automated Systems
Some human factors consideration affect the data and information
processing functions. The operator can degrade the system
performance by incorrectly interpreting displays, by observing
or implementing test procedures in an untimely manner, or by
recording incorrect data.
In order to reduce operator stress, provide the most rapid data
analysis and achieve lower error rate, some data and information
processing functions might be automated. However, the func-
tions should be evaluated in a wider perspective. That is,
the inspection station data processing functions, together with
the overall program management requirements, need to be analyzed
as a whole to realize an economical and efficient implementation.
In an automated data processing system, typical of a state-
operated facility the test measurements are combined with
inspection vehicle identification data; and a pass-fail deci-
sion is generated based on established limits for a specific
vehicle-engine class. Functions which also may be automated
-------
are printed records and vehicle scheduling. The capability
of compiling emission and safety inspection data for analysis
of program effectiveness could be included.
Appendix K includes a copy of the inspection form developed for
the inspection facility that is to be operated for the New York
City Taxi and Limousine Commission. The form is an example
of a document to be completed by semi-automated means within a
government-operated facility. Visual observations and decisions
by inspectors will be input manually to the facility data pro-
cessing system. Emission testing and speedometer-taximeter
checking will be automated by interfacing with the on-line com-
puter. Data 'comparison and interpretation and forms completion
also are performed by the facility computer.
4.5 STATE PROGRAM ADMINISTRATION AND MANAGEMENT
Administration and management of a statewide emission and safety
inspection program will include initial scheduling of vehicles,
maintenance of records, establishment and review of emission
limits, data analysis to determine the effectiveness of the
inspection program, evaluation of current and future equipment
needs, and provision for future analysis and development.
Where privately-operated, licensed facilities are needed to
perform emission inspection and/or maintenance, program management
functions include establishing qualification criteria, evaluating
candidates and certifying and licensing qualified parties.
In order to assure uniform performance of vehicle inspection,
the program management must generate the required test specifi-
cations and procedures and provide for the necessary orientation
-------
and training sessions for test and maintenance personnel.
Classes should be conducted at the outset of the program and
throughout the program life to accommodate changing personnel,
additional facilities and advancing technology.
The Program Manager's office must issue approved test procedures
to all participating facilities, continually review the test
results, and upgrade and refine the procedures as required to
assure uniform and repeatable inspection results and to meet
new standards established by the Air Pollution Control Commis-
sion and/or the Motor Vehicle Division.
4.5.1 Vehicle Inspection Scheduling Functions
Each vehicle is required to be safety inspected twice in each
calendar year at 6 month intervals. The Certificate of Com-
pliance expires on the last day of the sixth month after the
month of inspection (Ref. 2).
At the outset of vehicle emission testing, an Inspection Notifi-
cation form should be distributed to registered vehicle owners.
The notification package should include an indoctrination
pamphlet that briefly describes the program objectives, emis-
sion standards, inspection procedures, recommended maintenance,
inspection fee, and other factors necessary to inform and edu-
cate the recipient. In addition, the mass communication media
should be utilized as appropriate.
Inspection-completion summaries would be prepared by inspection
facilities and forwarded to the Program Office. At the Program
Manager's office, certification would be confirmed, delinquent
vehicles would be identified, and a delinquency list generated
and maintained. A delinquency form would be distributed to
the registered vehicle owner.
-------
Alternatively, enforcement may be instituted similar to the
existing safety inspection program by the removal and/or denial
of compliance stickers. All new registration and renewal
registration applicants must present proof of compliance.
Present knowledge of vehicle emission profiles as a function
of cumulative mileage and/or time does not provide a definite
indication as to the desired or opportune inspection interval.
The EPA, in its guidelines for air quality implementation plans,
acknowledges this deficiency (Ref. 7). Consequently, it suggests
a straight-line degradation factor which assumes that post-
maintenance emission levels deteriorate to pre-maintenance
levels on a linear basis over a 12 month period. As previously
noted, the California Air Resources Board currently is conducting
an 18 month investigation to resolve questions pertinent to
emission degradation. Similarly, the Colorado Air Pollution
Control Division presently is investigating emission deteriora-
tion for vehicles operating at higher altitudes. Results of
these studies may be helpful in establishing the vehicle emis-
sion inspection interval.
While it may be convenient to have a vehicle inspected for both
safety and emissions compliance during a single visit, existing
data does not justify a twice-a-year emissions inspection.
In view of the expected increase in the vehicle owner's inspec-
tion fee to test for both safety and emission compliance, and
the lack of data substantiating increased effectiveness (more
emission reductions), it is recommended that emissions be
inspected once a year until such time as study results prove
conclusively that twice-a-year emission inspections are more
cost effective.
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4.5.2 Program indoctrination and Public Relations
The indoctrination and training of inspection personnel should
be augmented with a general familiarization program for the
total population. Public information generated for communi-
cation media should be prepared carefully to explain fully the
program objectives and operations. The results of the public
opinion surveys described in Section 6 should be helpful in
developing such information for release to the general public.
The City of Chicago currently is inspecting vehicles using the
Idle test procedures. Preparatory to inspecting the first
vehicle, the evaluation and analysis of pertinent factors and
considerations were required. This Phase I investigation was
conducted for the Chicago Department of Public Works and the
Department of Environmental Control (Ref. 11). One of the
recommended practices was to distribute brochures designed to
educate the motorist. Summarized below are the suggested con-
tents of a brochure as modified to include both safety and
emissions inspection.
® Reasons for vehicle safety inspection — Reduce
traffic accidents, damage, injuries and fatalities.
o Reasons for vehicle emission inspection — Identify
major vehicle emission pollutants and relate to
air quality.
e Items to be safety inspected, and method — Brakes,
steering, suspension, tires, wheel assemblies,
lighting, glazing, exhaust system, undercarriage,
and exterior body.
• Emission inspection standards and procedures —
List of the emission standards and description of
the inspection procedure.
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© Corrective maintenance — Identification of probable
causes for inspection failure, methods of insuring a
well-maintained vehicle for safer operations and
lower emissions.
© Reinspection required — Procedures to receive
Certificate of Compliance, allotted time, enforce-
ment and penalties.
0 Consumer protection plans — Licensed facilities,
certified inspectors, posted inspection fees,
posted labor rates, procedures for filing complaints.
As the program progresses, the State management office should
evaluate inspection data and advise the public of the effec-
tiveness and benefits resulting from the emission and safety
inspection program. The public will be more responsive to the
implementation program when it is aware of its contributions.
The data collected on safety and emissions-inspected vehicles
should be evaluated to identify high incidences of failure, to
determine failure trends, to identify failures common to a
model year or manufacturer, and to reveal other information that
may be used to enhance traffic safety and reduce air pollution.
In order to increase program effectiveness in terms of emission
reduction and accident prevention, public support and coopera-
tion should be enlisted by making the motorists aware of the
problems, the solutions, and their individual roles in each.
Toward this end, the collection, analysis, interpretation, and
presentation of program data and information are essential.
4.5.3 Inspection Standards
Emission limits are established as a function of vehicle model
year in order to accept or reject a fixed percentage of all
-------
tested vehicles within a specific test concept to achieve a
desired level of emission reduction. These limits necessarily
would consider the resultant impact of the applicable air
quality standards and strategy. During the course of the
statewide implementation, continual evaluation of test results
will be necessary in order to assure that the desired effec-
tiveness is being achieved. Any required changes will be
reflected in the test procedures.
As newer emission-controlled vehicles enter the market,
tighter inspection limits may be required for these vehicles
to reflect the stricter federal or State emission standards.
Additionally, as retrofit devices and/or vehicle modifica-
tions are approved for installation, the applicable emission
limits will be modified to reflect the lower allowable levels.
Vehicle safety standards are established for new production
vehicles by the U.S. Department of Transportation (DoT). In-
use vehicle standards recently were issued by the DoT to be
used as guidelines for state programs (Ref. 1). As currently
promulgated, the federal standards do not include items
covered by the Colorado standards (Ref. 2). When newer
federal standards are issued on these remaining items, the
Colorado standards should be reviewed and modified as appro-
priate .
4.5.4 Inspection Equipment
The Program Office should continually maintain cognizance of
the current status of test equipment technology to assure
that equipment used at the inspection facilities is current
and satisfies changing test requirements. As future emission
requirements become more stringent and sampling methods are
changed, the testing requirement may become correspondingly
-------
more precise. These needs should be anticipated by the Program
Office.
Current safety inspection standards in Colorado are more exten-
sive than federal requirements. As such, it is doubtful that
the equipment required to conduct safety inspections during
future years will change much. However, the Program Office
should remain aware continuously of new developments in inspec-
tion techniques and equipment.
The Program Office should be in a position to recommend removal
of obsolete equipment and the substitution of newer, approved
units whenever appropriate to maintain the desired level of
program effectiveness. Accordingly, the responsible State
agency must be appraising continuously all new emissions and
safety inspection equipment, updating inspection procedures,
and revising equipment certification criteria.
4.5.5 Inspection Personnel
The primary duties of inspection personnel are to: 1) conduct
inspections and tests; 2) perform data and information pro-
cessing tasks; and 3) operate and maintain station equipment
and instrumentation. In addition, they would be required to
meet with the vehicle owners, discuss test results, and recom-
mend corrective measures.
Training — To assure uniformity in performance and to achieve
the desired program objectives, some form of initial and sus-
taining training program would be required. The schedule may
include classroom instruction, laboratory demonstrations, and
on-the-job training (OJT).
Training classes could be conducted in existing public education
facilities. Laboratory classes could meet in vocational schools
-------
equipped with the required equipment, in private independent
garages or in new-car dealers' repair shops similarly equipped.
On-going OJT necessary to incorporate new inspection procedures
and instrumentation would be accomplished most easily at the
respective inspection stations.
Qualifications and Certifications — Vehicle safety inspectors
must satisfy the requirements specified in the Rules and Regu-
lations of Colorado (Ref. 2). The previous study for Colorado
on vehicle emission inspection identified the qualifications
and training curriculum for vehicle emissions inspectors
(Ref. 5). These may serve as initial guidelines until the pro-
posed Colorado State University training program for inspectors
is implemented.
4.6 COST ANALYSIS
For the previous Colorado study of vehicle emission inspection
and control (Ref. 5), a detailed cost analysis model was devel-
oped that provided a framework for evaluating the program costs
associated with each inspection alternative. This model was
designed to provide expected aggregate cost magnitudes for the
various program areas throughout the desired program lifetime
for each alternative considered. Since they will vary both in
cost and expected methods of implementation and administration,
the cost model did not provide a cost accounting treatment of
required program expenditures; it was simply a tool that
allowed cost items to be identified and analyzed readily.
Each of the alternative inspection programs evaluated involved
an extremely large number of fixed and variable cost items.
Personnel wages, building costs, maintenance, and equipment and
installation costs were evaluated systematically for each alter-
native such that the total cost of each inspection concept was
assessed.
-------
Life-cycle costing assured that required resources were system-
atically considered, assisted in the analytical process, facil-
itated data acquisition and mathematical computation, and
indicated areas of critical resource requirements.
The life-cycle cost model categorized cost elements into major
sub-models of research and development, acquisition and invest-
ment, and operations and maintenance.
The research and development category included all costs nec-
essary to conceive, design, develop, and document a total
program capable of satisfying the identified goals and objec-
tives. For each of the program alternatives evaluated, this
cost category identified and quantified the expenditures nec-
essary to finalize the concept to the point of implementation.
Specific equipment, personnel, facilities, support management
procedures, and other considerations were costed to assure
complete coverage of resources.
The acquisition and investment category included all the
resources and costs to be incurred in the process of initial
program implementation. The resource elements included facil-
ities, instrumentation, and manpower and their associated func-
tional elements including certification, indoctrination and
initial training. This category included those expenditures
that are of a non-research and development and non-recurring
nature associated with the initial acquisition and start-up
of the program.
The operation-and-maintenance category included all of those
expenditures necessary to operate and maintain the inspection
facilities, and to manage the overall program. Cost elements
included expenses such as personnel wages and salaries, facil-
ities upkeep, sustaining or replacement training, and facility
recertification. This category included all recurring expendi-
tures for the total program.
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4.6.1 Vehicle Emission Inspection Program Cost
The cost analysis for the Colorado study was directed primarily
at comparing program costs for vehicle emission inspection as
performed in State-operated and privately-operated, licensed
facilities. Listed in Table 4-5 are the cost estimates for a
vehicle emission inspection only. See Appendix E for the cost
summaries extracted from the previous study (Ref. 5).
The annual inspection fee for emissions testing in a State-
operated facility or in a privately-owned, State-licensed
facility represents an allocation of an amortized initial
investment and annual operation costs. The fees are based on
once-a-year inspections. In the previous Colorado study, a
labor rate of $12 per hour was used; and equipment was amortized
over 5 years to calculate the fee for private garage inspection.
In addition, the costs to train the inspectors were absorbed
by the garages. Consequently, of the $5.45 estimated previously
for Idle emission inspection, the compliance sticker would cost
the station operator $0.60 for State management expenses, the
direct labor charge would be $2.60 (13 minutes inspection time
at $12 per hour), and the station overhead increase would be
$2.25 per vehicle inspected (allocated from inspector training
and new equipment purchase, maintenance, and operation expenses).
The overhead increase could be reduced as a function of initial
investments required by the station operator. For example, it
was assumed that at least two inspectors per station would
complete the suggested training curriculum. This vrould involve
roughly 80 hours per inspector or 160 hours per station. In
addition, the equipment for emission inspection included a
combination HC-CO-CC>2 analyzer for $2,650, a sampling system
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Table 4-5. PROGRAM COSTS — VEHICLE EMISSIONS INSPECTION3
Program Alternative
State
Cost
Private
Industry Cost
Total
Costs
Vehicle Owner ,
Allocated Cost
Initial Investment
Idle — State Operated
$2,172,000
None
$ 2,172,000
$ 1.67
Privately Operated
298,000
$ 7,513,000
7,811,000
6.00
Key Mode — State Operated
3,333,000
None
3,333,000
2.56
Privately Operated
351,000
15,876,000
16,227,000
12.48
Annual Operation
Idle — State Operated
2,226,000
None
2,226,000
1.71
Privately Operated
739,000
6,190,000
6,929,000
5.33
Key Mode — State Operated
2,770,000
None
2,770,000
2.13
Privately Operated
909,000
9,536,000
10,445,000
8.03
Annual Inspection Fee
Idle — State Operated
$2.10
None
$2.10
2.10
Privately Operated
0.60
$4.85
5.45
5.45
Key Mode — State Operated
2 .67
None
2.67
2.67
Privately Operated
0.74
8.17
8.91
8.91
aExtracted from "Vehicle Emission Inspection and Control Program," Olson Laboratories,
Inc., (Ref. 5) .
Id
-------
for $1,200, an optional NO2 analyzer for $2,800 and a frame and
assembly to contain the total system for $500. Due to recent
advances in instrumentation and manufacturing, the total system
cost of $7,150 may be reduced to about $1,500 to $2,500, without
measuring NO . Thus by reducing the inspector training require-
ments and the instrumentation cost, the overhead cost increase
may be lowered. The result would be a lowering in the inspection
fee charged the motorist to about $4 per inspection ($2.60
labor plus $.80 overhead plus $0.60 State management).
4.6.2 Integrated Safety-Emission Inspection Program Cost
The previous discussions have addressed tha question of how much
vehicle emissions inspection would cost in State and privately
operated facilities. Earlier, the cost was estimated for in-
specting safety-related vehicle components in existing licensed
inspection stations. A logical extension to the investigation
is to determine the approximate cost to perform both safety and
emissions inspection in State-operated facilities and licensed
private stations.
Appendix F includes the analysis of the costs associated with
an integrated safety-emissions inspection program. For the
State-operated facilities, the cost analysis deals primarily
with the construction and operation of new facilities. Thus
the concern is with the relative magnitude of program cost
elements. However for inspection in private stations, the
emphasis is with differential cost. That is, since safety
inspection currently is being performed in these facilities,
then the concern is with the additional cost incurred to provide
emission inspection in conjunction with safety inspection.
Tabel 4-6 shows the cost analysis summary of a program involving
both safety and emissions inspection. The analysis assumes that
all of the 4,200 privately-operated, safety inspection stations
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Table 4-6. PROGRAM COSTS - VEHICLE EMISSIONS AND SAFETY INSPECTION3
Program Alternative
State
Cost
Private
Industry Cost
Total
Costs
Vehicle Owner
Allocated Costs
Initial Investment
State Operated
Privately Operated
$11,043,000
None
None
$14,868,000
$11,043,000
14,868,000
$ 8.49£
11.44
Annual Operation
State Operated
Privately Operated
9,848,000
1,723,000
None
3,318,000
9,848,000
5,041,000
7.58?
3.88
Annual Inspection Fee
State Operated
Privately Operated
$8.30
1.33
None
$4.40
$8.30
5.73
8.30^
5.73d
Semi-Annual Inspection Fee
State Operated
Privately Operated
4.15
0.67
None
4.40
4.15
5.07
4-15S
5.07
aSee Appendix F, Integrated Safety-Emissions Program Cost.
¦y_
Assume 1.3 million registered passenger vehicles.
°Includes amortized initial investment cost at 6 percent over 20 years.
-------
would be upgraded to perform Idle emission inspections. For the
State-operated alternative, 66 new fixed-site facilities would
be constructued, equipped, and staffed. In addition, 23 mobile
units would be purchased. The vehicle-owner-allocated costs
are shown for comparative purposes only. The vehicle-owner
inspection fees assume that the initial investments for the
State would be amortized; thus, the annual operating cost
shown in the table is increased by the uniform annual payments
on the investments. Conversely, for the privately-operated
stations, the equipment purchase price is amortized over 5 years,
while the personnel training costs are amortized over 3 years,
an employment period assumed to be typical for mechanics.
For annual inspection, the privately-operated stations would
charge less than the State. However, for semi-annual inspec-
tions, the State would charge less. The primary reason is that
with more frequent inspections, the fixed capability of State
facilities is utilized efficiently. With privately-operated
stations, the fee is established on labor and overhead; and
increasing the frequency of inspection would not decrease the
inspection fee, other than the allocated State management
expenses, which would be halved.
The direct cost difference to the vehicle owner is $0.92 per
visit on a semi-annual basis. However, factors such as owner
convenience, distance travelled, and confidence in test results
must be assessed to select one alternative over the other. For
example, there would be only 66 fixed State-operated stations.
This disparity is somewhat diminished by the 23 mobile units
operated by the State. Relative to working hours, the private
stations would have longer operating hours and more working
days compared with State facilities.
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SECTION 5
PUBLIC OPINION SURVEYS
This Section reviews and summarizes three public opinion surveys
conducted in Colorado during 1972. These surveys were designed
to ascertain public response to questions concerned with air
pollution in general and motor vehicle emission reduction in
particular.
Public attitudes and sentiments on specific issues are presented
to facilitate policy decisions. Areas requiring public indoctri-
nation to alleviate misunderstandings or to allay unfounded
fears are identified. Topics requiring further investigations
to better define public response are also included.
5.1 SURVEY DESCRIPTIONS
Three recent public opinion surveys conducted in Colorado were
reviewed for this report. These surveys are described below:
© Northrop Corporation/Olson Laboratories, Inc. —
Survey performed as part of a study for the Colo-
rado Department of Health in September 1972.
Opinion Research of California designed the ques-
tionnaire, selected the sample size (267 rural
residents, 450 urban residents), conducted the
interviews by telephone and in house, compiled the
data, analyzed and interpreted the results (Ref. 5).
® TRW Report — Survey performed for the EPA, Region VI
-------
selected the sample from the residents of the
Denver-metropolitan area to be representative of
the area in terms of income level and age. Data
analysis is based on 204 replies (Ref. 12).
« Alire and Clark Report — Survey performed as a
part of a student research paper presented to
Dr. R. Beatty, University of Colorado in Boulder.
The survey was completed in 1972 and involved a
sample of 100 respondents selected on a non-random
basis from the Denver Metropolitan Telephone
Directory (Ref. 13).
The Colorado Air Pollution Control Division also provided a
copy of a study performed by Stanley Jones, Institute of Behav-
ioral Science, University of Colorado. This report, "Public
Response to Air Pollution in the Denver Area," did not involve
any public interviewing (Ref. 4). It is a review of other
surveys conducted, including the three identified earlier.
Accordingly, that study does not provide additional information
on Colorado residents. However, the study does identify areas
warranting further research. These, along with others, will
be discussed in subsequent paragraphs at the conclusion of this
section.
5.1.1 Demographic Considerations
Table 5-1 lists the characteristics of the survey sample for
each of the three reports being considered. It is recognized
that sample selection procedures differ according to project
objectives and economic and schedule constraints. However, it
is interesting to note that similarity in sample characteristics
occurs in spite of these differences.
-------
Table 5-1. DEMOGRAPHIC CHARACTERISTICS
Characteristics
Northrop
and ORC
TRW and
CMP
Alire and
Clark
Sample Size
717
204
100
(Percent)
Male Respondents
44
Not
Determined
54
Female Respondents
56
Not
Determined
46
Education
Not
Determined
Not Determined
12 years
22
High School
Graduate
29
Some College
27
College Graduate
14
Post College
7
Family Income
<$5, 000
$ 5,000 to $ 8,000
13.7
15.9
1
35
Not Determined
$ 8,000 to $10,000
18.9
j
46
$10,000 to $15,000
24. 5
J
>$15,000
23 .3
f
19
Unknown
4.6
i
Vehicles Owned
0
—
2
1
2
3
4
30
48
14
5
,
30
50
All Respon-
dents Owned
At Least One
Vehicle
*
5
1
18
>5
2
)
-------
5.2
OPINIONS ON AIR POLLUTION
Colorado residents were queried as to their perception of the
seriousness of the air pollution problem, their awareness of
the fflajor edhtiributbrS to the problerti, and their appraisal of
efforts to control or eliminate the problem. Each survey
addressed these areas in a differing manner, as noted below.
5.2.1 The Extent of Air Pollution
Both the TRW and the Alire-Clark (AC) reports concentrated
their sampling in the Denver-metropolitan area. Of the AC
sample, only one respondent felt that Denver does not have
an air pollution problem. Of those stating that a problem
exists, 46 percent judge it to be extremely serious; and
53 percent, moderately serious. Similarly, in the TRW report,
39 percent of the respondents think the Denver air pollution
problem is very serious; 30 percent, serious; and another
24 percent, slightly serious. Due to the different scaling
or weighting of the responses, a definite percentage cannot
be determined from these two reports. However, it may be
concluded that over 39 percent of the Denver-area residents
feel that the City's air pollution problem is very serious,
with another 53 percent believing the problem to be serious
br 3 lightly letiouft.
The Northrop/Olson survey conducted by Opinion Research of
California (ORC) sampled the total State. In this survey,
61 percent of the sample feel that air pollution is a very
serious problem; and 34 percent, somewhat serious. On an
area-wide basis, 55 percent of the rural residents feel that
the problem is very serious compared with 62 percent of the
urban residents.
-------
5.2.2
Causes of Air Pollution
The ORC survey attempted to determine the residents' awareness
of the causes for air pollution. Respondents were asked to
idefifcifty the major cause for the Colorado air pollution problem.
Within the urban sector, 7 5 percent believe automobiles are
the major cause whereas 61 percent of rural respondents suggested
this. Of the total respondents, 29 percent thought the factories
and industry are the major cause, 8 percent felt that trucks are
responsible, and 19 percent suggested other sources such as
aircraft, public service plants, buses, and steel and saw mills.
The other two surveys did not question the respondents on the
causes for air pollution in Colorado. Therefore, no comparisons
of responses can be made between the surveys on this subject.
5.2.3 Efforts to Control Air Pollution
The Denver-area respondents in the AC study were almost unani-
mously (95 percent) in favor of increased efforts to control air
pollution. Of those in favor, 54 percent felt the increase
should be great, 27 percent felt the increase should be moderate,
4 percent thought a slight increase would be sufficient, and
5 percent were uncertain as to the degree of increased effort
required.
The Northrop-ORC survey question was directed toward determining
the respondents' perception of the past and present role of
governmental effort in controlling air pollution. Although
structured differently from the AC survey question, the responses
may be compared. For the ORC survey, 13 percent believed a
great deal of effort was being expended, 40 percent believed some
effort was being expended, and 38 percent claimed not enough
effort was being expended.
-------
The ORC report noted that respondents who think air pollution
is a very serious problem are likely to have a less favorable
image of government efforts to control air pollution than are
respondents who evince less concern with the problem. This is
evident in that whereas 38 percent of all ORC SUifVey respon-
dents (total State) felt not enough effort was being expended,
the AC survey showed that at least 58 percent felt greater
effort should be expended (all Denver-area respondents).
The TRW survey did not include this subject in its question-
naire .
5.3 OPINIONS ON VEHICLE EMISSION CONTROL, STRATEGIES
"The State of Colorado Air Pollution Control Transportation
and Land Use Plan" wa.s submitted to the Region VIII Office of
the EPA on May 25, 1973 (Ref. 15). As prepared by the Colorado
Department of Health, the plan outlines the various strategies
to be pursued by the State to meet the established Federal
Ambient Air Quality Standards by May 31, 197 5.
Basically, the implementation plan calls for two categories of
control measures, primary and secondary. These measures, as
extracted from the Plan, are listed in Table 5-2. With the
exception of a few specific alternatives applying to heavy-duty
vehicles and fleet operators, the control measures will affect
the majority of the owners of light-duty passenger vehicles.
Accordingly, the discussions to follow address those control
measures that were included in the public opinion surveys. The
analysis may indicate the likelihood of public acceptance for
the control measures proposed for implementation, along with
the expected success of public participation as definable from
the survey results.
-------
Table 5-2. CONTROL MEASURES TO ACHIEVE
FEDERAL AMBIENT AIR QUALITY STANDARDS3
Primary Stage Control Measure
1.
Citizen participation
2.
Vehicle turnover
3.
Improved mass transit
4.
Provide "Bikeways"
5.
Vehicle inspection and maintenance
6.
Vehicle retrofit
7.
Vehicle high altitude modifications
8.
Reduction of hydrocarbron evaporation losses
9.
Fleet vehicle gaseous conversion
10.
Gasoline rationing
11.
Mechanic training
Secondary Stage Control Measure
1. Staggered work hours
2. Four-day work week
3. Idle traffic control
4. Traffic-free zones
5. Establish car pooling locator service
6. Restoration of commuter rail service
7. Implement a "horsepower" tax
8. Bus maintenance and inspection
9. AQCR gas tax for use as transit funding base
10. Gaseous conversion of all public conveyances (common
carriers)
11. Heavy duty vehicle retrofit
12. Heavy duty vehicle inspection and maintenance
13. Develop peripheral parking facilities in conjunction
u/ifch transit System
14. Esfefitisiv§ bus laties established
15. Establish limited use license Pi ates by color coding
16. Through movement only streets
17. Strict enforcement of existing parking and traffic
regulations, bans on taxi cruising and special traf-
fic flow considerations at construction sites
18. Selective restriction on vehicle use during designated
months, alternate usage of public streets by last
digit of license (odd or even)
^Extracted from "The State of Colorado Air Pollution Control
Transportation and Land Use Plan," May 25, 1973.
-------
5.3.1 Citizen Participation
To achieve expected effectiveness in an emission reduction
strategy involving the vehicle owner, an active participation
of citizens may be achieved through the development of citizen
awareness and understanding of air quality and transportation
problems. Earlier discussions have noted that Colorado resi-
dents in general and Denver-area residents in particular are
quite aware of the existent air pollution problem. Additionally,
the large majority identify the automobile as the major cause
of this problem. However, it has been shown that public accep-
tance of a control strategy decreases with direct costs (money,
time, inconvenience, etc.) to the citizen. These costs will
be described in specifics as they apply to particular strategies.
The citizen participation control measure will require a coor-
dinated program of public information and education to solicit
and develop the necessary public response. Material for this
program may be extracted from these studies and other related
reports. Suggested topics are included at the end of this
section.
5.3.2 Vehicle Turnover
This emission control strategy is dependent on newer and cleaner
vehicles replacing the older vehicles due to normal attrition.
Thus, as the future vehicle population mix trends toward a
larger proportion of post-1968 vehicles, the total exhaust
emissions levels contributed by these vehicles become less.
None of the surveys being considered herein included questions
relative to whether current owners would continue to replace
their aging vehicles with newer models. The affects of the
current gasoline shortage and proposed restrictions on vehicle
speed limits and parking, coupled with the relatively poor
performance of newer vehicles, need to be considered.
-------
5.3.3 Improved Mass Transit
Total passenger vehicle miles traveled may be reduced with a
resultant decrease in emissions by providing an alternative
transportation mode in the form of mass transit. The AC survey
of Denver-area residents indicated that 79 percent would favor
taking the bus downtown, with 45 percent strongly favoring this
form of transportation. However, it was noted that of the group
who drove downtown frequently, 40 percent were opposed, with
27 percent strongly opposed to mass transit. For the infrequent
City visitor, 16 percent opposed taking the bus. When this
survey sample was asked if they would be willing to pay tax
increases of $25 to $50 per year to provide new transportation
methods in the Denver area, 54 percent responded favorably,
34 percent unfavorably.
The TRW study involving Denver-area residents attempted to
determine current utilization of mass transportation systems.
Results indicated that 87 percent of the husbands never used
these transit systems, 77 percent of the wives never used them,
and more than 90 percent of the children over 16 years old have
never used these public transportation systems. Respondents
indicated that one of the main reasons for driving was lack of
mass transit close to their residence. When asked to rank the
methods of encouraging the use of public transportation, the
methods receiving the highest ranking were: 1) more frequent
service; 2) more conveniently located stops and stations;
3) faster travel; 4) parking facilities at stops and stations;
and 5) lower fares.
The Northrop-ORC survey was not structured to evaluate mass
transit opinions.
-------
5.3.4 Provide "Bike Ways"
Another method of reducing passenger vehicle miles traveled is
to promote the increased utilization of bicycles as a mode of
transportation. None of the surveys being reviewed addressed
this emission control measure.
5.3.5 Vehicle Inspection and Maintenance
The AC survey of Denver-area residents included one question
relative to this control strategy. Respondents were asked if
they would favor or oppose vehicle exhaust inspection twice a
year. Seventy-one (71) percent would strongly favor this
proposition with another 20 percent moderately in favor.
Similarly, the TRW survey of Denver-area residents established
that 59 percent would be very much in favor of periodic inspec-
tion, with 26 percent somewhat in favor. On a statewide sample
basis, the Northrop-ORC study showed that 50 percent would
strongly favor mandatory emission inspection and 31 percent
would be somewhat in favor. This survey showed that on a
residential basis, 42 percent of rural residents would strongly
favor an inspection program compared with 52 percent or urban
residents. An additional 34 percent of rural residents would
somewhat favor the program compared with 30 percent of the
urban residents. It can be concluded that roughly 75 percent
would favor a mandatory inspection program.
Inspection Cost — The TRW study determined that 29 percent of
the respondents felt a reasonable inspection cost would be $2,
21 percent thought $5 was reasonable, whereas 18 percent favored
$1. For the Northrop-ORC study 12 percent of the respondents
believed it should be $1 or less, 34 percent thought it should
be $1.50 to $2, 8 percent felt it should be $2 to $3, and 9 per-
cent thought it should be $3 to $5. The AC survey did not ascer-
tain expected inspection cost. It appears that an inspection fee
-------
of $2 or less would receive the highest favorable response.
If the fee imposed is about $1, 50 percent would approve.
If the fee charged is about $2, then 30 percent of the respon-
dents would approve.
Inspection Station Operator — The TRW study showed that if
inspection were required, 36 percent of Denver-area residents
would prefer State-operated facilities, 8 percent would prefer
City-operated facilities, and 53 percent would favor service
stations or garages. Grouping State-operated and City-operated
facilities, then 43 percent would prefer government-operated
facilities compared with 53 percent favoring local service
stations and garages. In contrast, the Northrop-ORC survey
of the total State indicated that 42 percent would prefer
State operation and 49 percent would prefer private garages.
(There were no city-operated stations offered as an option
for this study.) Analyzing the data on a regional basis, in AQCR
Number 2 representing Metropolitan Denver, the responses were
45 percent for State operation compared with 44 percent for
private garages. Relative to residence, the GRC survey showed
that rural residents definitely favor private garages (56 per-
cent) over State facilities (34 percent), whereas urban resi-
dents are relatively divided, with 47 percent favoring private
garages and 44 percent for State operation. On the basis of
the TRW study and ORC study, it cannot be concluded as to which
the urban residents would favor. However, it appears that the
rural residents would prefer inspection by local service facil-
ities. The AC study did not address this question.
Inspection Period — The AC study showed that Denver-area res-
pondents strongly favor twice-a-year inspection (71 percent).
However, the survey did not attempt to establish what inspec-
tion period would be preferable since that was the only question
asked relative to periodic inspection. In a similar vein, the
-------
TRW study asked questions relative to annual vehicle inspection,
but no questions were included to determine periods preferred.
The Northrop-ORC study showed that 59 percent of the respondents
would prefer twice-a-year inspection and 27 percent would favor
once^a^yeart
Other Factors Related to Inspection and Maintenance — Many other
factors must be considered in the implementation of an inspec-
tion and maintenance program. Factors such as driving distance
to facilities, vehicle owner maintenance costs, and program
compliance and penalties all affect public acceptability of
proposed control measures. Because the Northrop-ORC survey
was the only study structured to determine public opinion of
these specific items, no comparative analysis can be performed.
However, these considerations are of significant importance
to the proposed emission control strategies, and as such are
summarized below:
o Driving distance to inspection station — A driving
distance of 5 miles or less was preferred by 47 per-
cent of the urban residents; whereas, 44 percent
of the rural residents thought 10 miles or less
would be reasonable. In general, the rural resi-
dents will be more tolerant to longer driving
&i&iaftees eueh aa 15 to 30 miles,
• Emission-oriented maintenance — Of the respondents
surveyed, 61 percent claimed that their vehicle's
emission control devices were never checked.
Respondents, in general, did not know how much a
tune-up should cost. The largest response (12 per-
cent) believed the cost should be between $20 to
$30. The estimates ranged from $10 to $100, with
35 percent of the respondents unable to offer a
cost figure.
-------
Not surprisingly, when respondents were asked what
they believed would be the maintenance cost to
meet emission inspection limits, 78 percent did
not know what a realistic amount should be to
correct vehicle failure. At least 60 percent
agreed that it would be reasonable to be required
to spend $50 to $150 every 2 to 3 years to pass
vehicle emission inspection.
Inspection compliance — Respondents were asked to
identify methods of paying for necessary vehicle
repairs to attain inspection compliance. The
most frequent responses were that failed vehicles
should be kept off the road until repaired (30 per-
cent) and that State or other governmental financial
aid should be provided (28 percent). However, when
asked whether the State should pay for all costs
for those unable to pay repair charges, 54 percent
said the State should not, whereas 43 percent
agreed. If financial assistance is not provided,
66 percent said the vehicle should be banned from
highway use until repaired, while 9 percent thought
these vehicles should be exempted.
Enforcement penalties — For violating the program
requirements, 32 percent of the interviewees believed
a monetary fine should be imposed ranging from $5
to $50. Another 18 percent thought a warning coupled
with a monetary fine, suspended driver's license,
license plate removal, or car removal from the
highway would be warranted. Other penalites sug-
gested included non-renewal of registration, judi-
cial decision, and deduction of points from driver's
license.
-------
Factors Related to Safety Inspection — Several questions related
specifically to vehicle safety inspection also were asked to
establish its public acceptability and to identify areas that
may require modification. These questions are summarized below:
• Approval of current safety program — Almost all
respondents (94 percent) indicated an approval
of the existing program, with 79 percent expressing
strong approval.
9 Safety inspection period — The overwhelming majority,
84 percent, believe that safety inspection should
be performed twice a year as compared with 15 per-
cent favoring once-a-year inspection.
• Safety inspection cost — The opinions were rela-
tively divided as to whether the motorist would be
willing to pay $5 to $7 annually to assure a more
thorough inspection and better enforcement. As a
group, 50.6 percent were in favor and 47.4 percent
were opposed.
• Inspections by State or private station — The
large majority, 71 percent, believe the private
sector should continue the safety inspections
rather than the State.
• Distance traveled to safety inspection station —
The vast majority of urban residents (75 percent)
travel less than 5 miles to have their vehicles
inspected. For the rural residents, approximately
57 percent travel 5 miles of less.
-------
5.3.6
Vehicle Retrofit
The AC study showed that vehicle owner interest in reducing
pollution from cars decreased with increasing owner cost. Of
the respondents surveyed, 95 percent were ifi f avoir of $iO~pef-
year costs incurred for changes made to their car to effect
lower pollution. This favorable response decreased to 74 per-
cent when the costs were $20 per year, and decreased further
to 53 percent with costs of $50 per year. The report does not
indicate what these changes to the vehicles would be nor what
the costs are for on an annual basis. However, the results are
discussed here because any changes made to vehicles after they
are manufactured become retrofit systems by definition.
The TRW survey asked the respondents whether they would favor
a law requiring retrofitting vehicles with emission control
equipment costing $200 per car; 10 percent were very much in
favor, 21 percent were somewhat in favor, 15 percent somewhat
against, and 54 percent strongly against. However, if the cost
were reduced to $50 per car, 50 percent would strongly favor
the law, 23 percent would be somewhat in favor, 11 percent would
be somewhat opposed, and 15 percent still strongly opposed.
The Northrop-ORC study did not include a specific question on
retrofit system installation. However, the respondents were
queried as to whether all vehicles, regardless of age, should
be required to have emission control devices installed. In
response, 41 percent strongly agreed, 24 percent tended to
agree, 17 percent tended to disagree, and 14 percent strongly
disagreed with mandatory installation of emission control
devices.
From the results of the three surveys, it may be concluded that
vehicle retrofit systems are acceptable to the public as a means
of emission control. The degree of public acceptance will be
-------
highly dependent on the vehicle owner costs. However, ether
factors such as vehicle performance, driveability, and fuel
economy as affected by the retrofit systems were not addressed
in the questionnaires and will undoubtedly influence public
acceptance.
5.3.7 Vehicle High-Altitude Modifications
These vehicle modifications directed toward increasing fuel
consumption efficiency at high altitude would be installed on
a retrofit basis, similar to that described earlier. No further
discussion of public opinion is provided on this issue. However,
if included as part of a survey, the public response to this
type of vehicle modification would most likely be highly favor-
able in view of the expected! installation cost of $20 to $35,
the increased fuel consumption efficiency, and the improved
vehicle performance (Ref. 15) .
5.3.8 Gasoline Rationing
Vehicle emissions may be decreased directly by limiting gaso-
line availability. The direct reduction of vehicle miles
traveled may have severe socio-economic impact on the public.
The TRW survey of Denver-metropolitan-area residents indicated
that 71 percent find gasoline rationing to be very unaccept-
able with another 13 percent finding it somewhat unacceptable.
Neither the AC study nor the Northrop-ORC study addressed this
method of emission reduction.
5.3.9 Staggered Work Hours
As a means toward relieving traffic congestion, staggered working
hours have been considered. The TRW study results indicate that
33 percent were very much in favor of such a plan, 31 percent
-------
somewhat in favor, 16 percent were indifferent, 12 percent were
somewhat opposed, and 8 percent very much opposed.
Like the TRW study, the AC study sampled only Denver-area resi-
dents, thus providing a direct comparison. In their study, the
AC team noted that 9 of 15 (60 percent) who worked in downtown
Denver would strongly favor staggered work hours with another
3 moderately favoring the idea. Since only 15 of the 100 AC
respondents worked in the downtown area and consequently would
be directly affected by staggered work hours, the AC study noted
that their results must be termed inconclusive. The Northrop-
ORC study was not developed t:o address this issue.
Based on the limited sample response of the AC study, and
augmented with the larger sample size of the TRW study, it may
be concluded that the majority of Denver-area residents would
be receptive to staggered working hours as a method of reducing
vehicle emissions.
5.3.10 Passenger Vehicles Traffic Reduction
The AC study determined that 58 percent of Denver-area residents
would strongly favor reducing downtown traffic as a way of
reducing pollution with another 16 percent somewhat in favor.
If a cost of $5 was incurred for each trip to the downtown
area, then 44 percent would be strongly opposed with 13 percent
somewhat opposed.
Passenger vehicle traffic into the central business district
(CBD) may be curtailed by imposing tolls on exit ramps of major
freeways and expressways. The TRW study showed that 59 percent
of Denver-area residents thought this very unacceptable with
19 percent finding it to be somewhat unacceptable. Their atti-
tudes would not change if the tolls were imposed only during
heavy traffic.
-------
Other methods of reducing passenger vehicle traffic are to
prohibit traffic and parking or to impose parking taxes in the
CBD. According to the TRW study, at least 63 percent of the
Denver-area residents would favor prohibiting traffic and
parking in the CBD; 33 percent of the respondents thought this
\
was very acceptable and the other 30 percent somewhat acceptable.
If a tax were imposed for all-day parking in the CBD, the res-
pondents were divided with 45 percent believing it to be accept-
able. A large proportion of the respondents, however, found it
to be very unacceptable (30 percent). If the taxes were col-
lected for CBD parking regardless of the duration (1 hour or
all day) then 42 percent of the respondents found this very
unacceptable and 18 percent somewhat unacceptable.
The TRW study indicated that the restriction of non-essential
automobile travel during periods of high air pollution would be
somewhat unacceptable. If special license plates or vehicle
stickers were necessary to implement this type of emission
control, 37 percent would find this very unacceptable and
12 percent somewhat unacceptable. Conversely, 13 percent
believe this method to be very acceptable and 28 percent some-
what acceptable.
5.3.11 Car Pools
The TRW survey of Denver-metropolitan residents indicated that
6 percent travel to and from work in a car pool, 19 percent
are very interested in the idea, 31 percent somewhat interested,
33 percent not at all interested and 11 percent do not travel
to and from work by car. When the sample respondents were
asked how difficult it would be to get into a car pool if neces-
sary to reduce vehicle traffic, 31 percent said it would be
extremely difficult, 11 percent said very difficult, and 28 per-
cent said somewhat difficult. At least 23 percent said it would
be easy to get into a car pool.
-------
5.3.12 Increasing Traffic Flow
Decreasing the amount of vehicle operating time will result in
a corresponding decrease in vehicle emissions. In addition,
since emission levels are typically higher at lower operating
speeds, then an effective method is to increase the movement
of CBD traffic.
Freeways, Expressways, and Major Arterials — The TRW study
determined that 62 percent would favor converting some of the
existing lanes of major expressways and streets into "bus
only" and "car pool only" lanes. Slightly more than one-third
(3 5 percent) thought the concept very acceptable and 27 per-
cent somewhat acceptable.
The AC survey of Denver residents indicated a definite opposi-
tion to building more freeways in the Denver area. Of the
56 percent in opposition, 2 percent were slightly opposed,
19 percent moderately opposed, 35 percent were strongly opposed,
and 10 percent undecided. Support for more freeways was expres-
sed by 34 percent of the respondents.
Traffic Control — The AC survey showed that residents are
opposed to increasing the traffic speed on major Denver streets;
5 percent were slightly opposed, 16 percent moderately opposed,
43 percent strongly opposed, 12 percent undecided, and, to
some degree, 23 percent were in favor of increasing traffic
speed.
The TRW survey included other methods of effecting better traf-
fic movement. These control measures are listed in Table 5-3.
Neither the AC survey nor the Northrop-ORC survey included
questions of this nature, thus no comparable data are avail-
able .
-------
Table 5-3. TRAFFIC CONTROL CONCEPTS3
Public Opinion (Percent)
Very
Effective
Somewhat
Effective
Not
Effective
Would
Increase
Congestion
Prohibit parking, loading and
unloading on busy streets
49
43
6
2
Increase the number of one-way
streets
28
54
17
1
Establish reversible lanes on busy
streets to be used during rush
hours
20
43
17
20
Prohibit turns at busy intersections
during rush hours
38
34
18
9
Widen major streets
40
38
18
5
Widen major streets at intersections
only
7
44
35
14
Provide pedestrian underpasses and/or
overpasses
43
38
18
1
Improve timing of traffic signals
68
28
5
0
Increase the number and frequency of
radio traffic reports
13
60
26
2
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The public believes that improving the timing of traffic
signals would be very effective in increasing traffic flow.
Another widely acceptable concept would be prohibiting the
parking, loading, and unloading of vehicles on busy streets.
The public appears to support the concept that providing
pedestrian underpasses and/or overpasses would also be effec-
tive in removing another source of traffic impediment.
5.4 FUTURE PUBLIC INDOCTRINATION REQUIREMENTS
The Colorado implementation plan to achieve the 197 5 ambient
air quality standards "calls for a significant change in atti-
tude and life style on the part of most residents of the
Metropolitan Region" (Ref. 15). To realize the expected
effectiveness of the plan, a coordinated program of public
information and education would be essential. The survey
results described previously will provide some of the topics
for this indoctrination program. Other subjects need to be
further evaluated prior to inclusion in an information program.
Listed below are topics to be considered for a public informa-
tion and education program.
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• Sources of vehicle emission — Identify major
sources of vehicle emissions with corresponding
proportions.
• Vehicle ehtission controls — identify d£
controls installed and initial year of implemen-
tation.
• Emission levels of uncontrolled and controlled
vehicles — Identify the differences as a function
of model year.
9 Emission levels as a function of vehicle oper-
ation — Describe emissions during idle, low
cruise, high cruise, hot soak, and diurnals.
• Emission levels as a function of periodic mainte-
nance — Describe the effects of proper maintenance
on vehicle emissions.
• Vehicle owner costs — Describe typical periodic
maintenance activities and associated costs;
describe typical costs to own and operate a
passenger vehicle.
• Vehicle retrofit systems — Describe reasons for
retrofit systems, the effectiveness in emission
control, the effects of vehicle performance and
fuel economy, the cost for installed systems,
the maintenance requirements.
• Efforts to control vehicle emission — Describe
present and future control measures implemented
by manufacturers, government agencies.
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e Information sources and availability — Identify
the State of Colorado departments from which
further information can be obtained; identify the
federal sources of publications, and manufacturers
and organizations involved in reducing vehicular
emissions.
5.4.1 Public Information and Dissemination
The information and education program may be organized by the
Public Information Officers of the Departments of Health and
Revenue. News releases to local newspapers throughout the State
would be the least costly method of reaching the majority of
vehicle owners. Periodic interviews by newspapers of responsible
departmental directors and supervisors within the Health and Revenue
departments should go into greater detail on the implementation
plans for vehicle inspection, engine modifications and retrofitting.
Lectures presented by these responsible individuals to various
special interest groups will assist in informing those who have
concern with the environment and who have influence on their
peers. These groups include energy conservation, environmental
and ecology groups, Audubon Society, Historical Society, and
League of Women Voters. Additionally, meetings of this type
usually are covered by the newspapers. Radio and television an-
nouncements are costly unless included as part of the news cover-
age. Special movie films developed for loans to academic insti-
tutions and previously mentioned special interest groups may be
costly as far as initial investment in time, effort, and materials
are concerned. However, the films may be duplicated for wide
dissemination without recurring expenditures.
A private consulting firm specializing in public information
programs and/or advertising may be contracted with to provide
assistance and guidance. The contractor may be employed to work
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with the appropriate state departments and agencies to devise an
overall plan which the State itself would follow. The overall
plan would include (1) definition of information program objec-
tives; (2) identification of the communication media to be used;
(3) allocation of subject matters discussed as a function of each
medium; (4) allocation of budget for each medium; (5) responsible
state agency for interfacing with each medium; (6) selection of
individuals to be responsible for discussing each subject matter;
(7) identification of special interest groups and individual con-
tacts; and (8) development of master schedule and milestones.
5.5 FURTHER INVESTIGATIONS REQUIRED
The effectiveness of the Colorado 1975 Implementation Plan is
highly dependent on the cooperation, support and active partici-
pation of the vehicle owners and users. Without their support
and compliance, the State's goals of achieving the desired air
quality standards by 1975 will not be met. The public informa-
tion and education program designed to communicate the objec-
tives of the implementation program and the roles of residents
will do much to assure the success of the plan.
Assuming this public information program is initiated in the
immediate future, then further opinion surveys may be directed
toward ascertaining the effectiveness of the education program,
defining areas requiring further presentations via mass communi-
cation medias, and determining whether the public's views on
specific issues (e.g., mass transit, limited access to the CBD,
retrofit systems, inspection and maintenance) have changed as
a result of the public information program.
5.5.1 Opinions of Business and Community Leaders
A survey should be made of business leaders, community leaders,
educational institutions, special interest groups (environmental
protection, energy conservation, Audubon Society, historical so-
cieties) , legislators, and others to determine their level of
concern with air pollution, methods to improve
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the CBD, the effects on local businesses as a function of
proposed emission control measures, the evaluation of past
efforts to reduce and control vehicle emissions, the likeli-
hood of enacting specific control programs, and their estimate
of public acceptance of these measures. Because of their
relative position in the socio-economic structure of the
society, these individuals will be influential in modifying
and/or expressing the attitudes of their peers.
5.5.2 Vehicle Purchasing Trends
Several questions remain to be resolved relative to the emis-
sion control measures considered. As future vehicles are
designed and manufactured to meet the increasingly stringent
emission standards, vehicle owner's desires to own and operate
these newer vehicles may decrease correspondingly. Initial
purchase prices will increase as a result of federally-mandated
emission control systems; fuel consumption economy may deteri-
orate further if the current trend established since exhaust
controls were instituted continues; and vehicle performance
and driveability may continue to be relatively poor because
of the added controls implemented to meet the emission standards.
To satisfy manufacturer's warranty, various engine and emission
control systems maintenance activities must be performed. With
tfte expected jptice escalation ih labor rdtes and teplaceffient
parts, future new-car owners may anticipate much higher owner-
ship costs. These costs and performance factors may strongly
influence future vehicle purchases. Future opinion surveys
should attempt to determine the current purchasing policies of
passenger vehicle owners along with the expected future policies
as affected by increased initial costs due to emission control,
probable lower fuel economy, probable poorer performance and
driveability, higher maintenance costs, and limited fuel avail-
ability.
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5.5.3 Retrofit System Installation
A control measure currently being investigated by the State
of Colorado is vehicle emission control retrofit systems.
While the surveys analyzed herein indicated favorable response
to this option, no questions were included to determine public
acceptance if, along with emission reduction, the vehicle
owner may expect degraded vehicle performance and/or poorer
fuel economy, as well as vehicle inspection to assure satis-
factory operation. Questions of this type need to be included
in a future survey.
5.5.4 Increased Bicycle Utilization
None of the questionnaires reviewed included questions on
providing bikeways as a means of decreasing vehicle miles
traveled. While more and improved bikeways may encourage
increased utilization of bicycles, the question remains whether
current vehicle users will ride their bicycles to work and to
the stores in lieu of motorized transportation. A future
survey will be required to determine public attitudes to bet-
ter bikeways if increased taxes are involved and if vehicle
pollution is reduced by only 1 percent (Ref.15) due to increased
utilization of bicycles.
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5.5.3 Retrofit System Installation
A control measure currently being investigated by the State
of Colorado is vehicle emission control retrofit systems.
WMie fcHg SUlrveys analyzed herein indicated fcLVb table rddjpohse
to this option, no questions were included to determine public
acceptance if, along with emission reduction, the vehicle
owner may expect degraded vehicle performance and/or poorer
fuel economy, as well as vehicle inspection to assure satis-
factory operation. Questions of this type need to be included
in a future survey.
5.5.4 Increased Bicycle Utilization
None of the questionnaires reviewed included questions on
providing bikeways as a means of decreasing vehicle miles
traveled. While more and improved bikeways may encourage
increased utilization of bicycles, the question remains whether
current vehicle users will ride their bicycles to work and to
the stores in lieu of motorized transportation. A future
survey will be required to determine public attitudes to bet-
ter bikeways if increased taxes are involved and if vehicle
i
pollution is reduced by only 1 percent (Ref.15) due to increased
$£ bicycled.
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SECTION 6
VEHICLE OWNER CONSIDERATIONS
This section presents various factors that need to be considered
to assure public acceptability, to preclude unnecessary owner
expenses, to protect the owner against unfair practices, to pro-
vide the process for requesting and granting of waivers, and to
provide the process for filing complaints involving malpractice.
Each of these factors is directed toward promoting consumer
cooperation and insuring consumer protection.
The discussions are not directed toward the specific assignment
of responsibilities to either the Department of Health or Revenue.
Neither are they directed toward the creation of a new agency in
the State or the generation of additional responsibilities within
the Department of Law, Office of Consumer Affairs. As described
herein, the vehicle-owner considerations are items that may
require new legislation and additional departmental responsibili-
ties to assure an effective, viable, and publicly acceptable
emission control strategy.
6.1 PUBLIC INFORMATION DISSEMINATION
Initially, the public should be informed of the program objec-
tives, reasons for vehicle safety and emissions inspection,
estimated costs for typical repairs, owner options in obtaining
vehicle maintenance, and non-compliance penalties (see Section 5).
Vehicle owners should be advised of licensed stations and certi-
fied inspectors, posted labor rates, complaint procedures, and
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request-for-waiver procedures. Each of these items are discussed
further in the following paragraphs.
Public information should be disseminated periodically via commu-
nications media to advise owners of program effectiveness and
cases involving unfair practices and their disposition. Program
effectiveness data should reflect failure rates and trends.
6.2 LICENSED STATIONS
The current practices of the Motor Vehicle Division in qualifying
and licensing inspection stations should be continued. Additional
qualifications for Idle emission testing and servicing should be
developed and impeded. The Rules, Regulations and Requirements
for Motor Vehicle Official Inspection Stations (Ref. 2) should be
revised to include emission inspection.
Licensed station,currently display a safety inspection sign for
public information. New or modified signs should be provided
when emission inspection becomes mandatory.
6,2.1 State Certification
In order to promote program effectiveness and assure uniform in-
spection quality, the Departments of Health and Revenue should
require quarterly appraisal of all licensed stations. The cost
estimates for State program administration and management, dis-
cussed in Section 4, include the expected expenditures for teams
of State certification inspectors whose sole responsibilities
are: (1) to re-certify each licensed station four times a year,
once every three months; and (2) to investigate complaints filed
by the public.
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Additional tasks would be for the teams to sell to the station
the required compliance stickers for motorists, to collect the
inspection data compiled by the station, to resolve any problems
the station may have experienced, and to investigate and evalu-
ate observed or reported irregularities.
6.2.2 Posted Signs and Labor Rates
Licensed stations should display the Official Inspection sign in
a location that is easily visible to an approaching motorist.
The inspection license should be displayed prominently in the
office area.
Typical labor rates for safety inspection and/or emissions in-
spection should be displayed. Also, labor rates for typical
vehicle maintenance should be prominently displayed. These
would include brake adjustment, full brake replacement (four
wheels - disc or drum), partial replacement (front wheel or
back wheel), headlight alignment, wheel alignment, light bulb
replacement, engine idle speed adjust, carburetor adjustment,
ignition timing adjustment, and others. Recognizing that parts
replacement, such as for the air filter, would involve a range
of values for the part, it is recommended that either the typical
range be displayed or only labor charges be shown, with parts
charges noted as additional.
If licensed and/or certified station inspectors are required to
to be specially qualified, then the appropriate certificates
(safety, emissions) should be displayed either in the applicable
work area or in the office area where the station certificate is
displayed.
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6.3
CONSUMER PROTECTION CONSIDERATIONS
Most of the considerations discussed above could be thought of
as being oriented toward consumer protection. These included
licensed stations, periodic recertification, posted signs and
labor rates, and certified inspectors.
These areas more or less deal with the motorist prior to his
vehicle being inspected and/or serviced and repaired. Other
considerations become evident in the process of receiving the
required inspection/service and, subsequently, when paying for
the inspection or repairs.
6.3.1 Preliminary Cost Estimate
Prior to performing any repairs to a vehicle, the station should
inform the owner (or his designate) of the items requiring repair,
replacement, or adjustment, along with the associated costs.
The cost estimate should be in writing on a station form. The
motorist is not obligated to have the necessary maintenance per-
formed at the inspecting station. Cost estimates should be valid
for a limited number of days, and so specified on the station
form provided to the owner.
6.3.2 Parts Replacement
Original parts of the vehicle, when removed and replaced, should
be returned to the owner. At the owner's option, the removed
parts may be left at the station for disposal. If rebuilt,
remanufactured, or reconditioned parts are used to effect the
repair, the owner's invoice should so indicate.
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6.3.3 Consumer Complaint Procedure
Licensed stations should display a summary of the complaint pro-
cedure. If the vehicle owner is dissatisfied with the repair
and/or costs and cannot achieve a satisfactory agreement with
the station operator, he should be afforded the opportunity to
have the case arbitrated or investigated without going through
small claims court.
The posted procedure should identify the responsible State de-
partment, the appropriate mailing address, any necessary informa-
tion required, a toll-free telephone number, and business hours
and days.
6.3.4 Request-for-Waiver Procedure
Upon receipt of a preliminary cost estimate, the vehicle owner
may believe that the expenses necessary to satisfy the safety
ancl/ot: emission standards may be more than he would want to
.invest in the particular vehicle. The State should establish an
upper limit, perhaps as a function of vehicle age, beyond which
repairs are not warranted. However, effective repairs shall be
accomplished below this limit.
As an example, after receiving at least three cost estimates,
the motorist is faced with an engine repair costing $200 to $250.
The vehicle is a 1964 model with 100,000 cumulative miles and
worth $2 50 on a used-car lot. Should he be required to invest a
minimum of $200 to satisfy the emission standards? Would a more
reasonable approach include major ignition and carburetion work
costing up to $100 and achieve less-than-maximum emission reduc-
tion? In cases involving relatively large expenditures that
would be disproportionate to the market value of the subject
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vehicle, it seems that some upper limit would be warranted. How-
ever, the waiver should not be granted indefinitely. That is,
a finite waiver period should be granted, after which the repairs
are made or the vehicle is removed from highway use. Vehicles
operating under a waiver should not be resold without satisfying
the applicable inspection standard.
6.4 APPROVED EMISSION CONTROL PRACTICES
The Department of Health currently is evaluating various approaches
to reduce further total exhaust emissions. When these evaluations
are completed, the accepted practices should be disseminated to
participating licensed stations. The public information program
office should advise the public through the communications media
and through the previously described information pamphlets.
6.4.1 Retrofit Devices
Based on the Health Department's investigation results, approved
devices should be identified by type and manufacturer. Emission
reduction potential should be described along with any effects on
performance and fuel economy. Because of the many different
devices that may become available, the Department should recom-
mend a maximum installed cost.
Retrofit devices not currently evaluated by the Department may
.subsequently be submitted for qualification and approved for
installation. The department should establish the procedure for
obtaining approved status. The following information should be
considered during the qualification process.
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e Device description — a summary of theory of opera-
tion, physical description and applicabLe graphics.
o Emission reduction — test data including vehicle
sample size and description, emission baseline levels,
emission level with device installed, and identifi-
cation of recognized emission test laboratory and/or
emission measurement system and procedures used.
• Performance and fuel economy — description and data
on any driveabllity testing and fuel economy mea-
suremen ts.
e Installation procedures — description of installa-
tion procedures, identification of special equip-
ment or calibration, any special personnel training.
o Product distribution — definition of product distri-
bution policy, qualified installers.
e Owner cost — proposed cost of unit including instal-
lation and any post-insta11ation maintenance require-
ments in terms of cumulative mileage or time inter-
val, with associated costs.
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SECTION 7
LEGISLATIVE CONSIDERATIONS
This section evaluates the existing EPA policies on the modifi-
cation of vehicle engines to achieve emission reductions. The
State of Colorado, in Senate Bill 393, has empowered the Air
Pollution Control Commission to adopt rules and regulations
applicable to engine modifications. Senate Bill 2236 of the
U.S. Senate presently is being considered for enactment to
amend the Clean Air Act.. This bill provides for revised
standards for vehicles used in high altitude areas. Vehicle
modifications as they affect a manufacturer's warranty also are
evaluated in this section.
7.1 FEDERAL EPA POLICY
The EPA Office of Air Programs issued on June 8, 1972, an
Advisory Circular on engine modification for high altitude
operation (see Appendix G). Subsequently, the EPA Office of
Enforcement and General Counsel issued the Interim Tampering
Enforcement Policy on December 22, 1972 (see Appendix H). Both
of these policy statements, as they affect the Colorado vehicle
emission control strategies, are presented below.
7.1.1 Emission Control System Modifications
For vehicles or engines intended for sale at high altitudes,
the EPA Advisory Circular establishes the procedures whereby
manufacturers may request the changes. Upon EPA approval for
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modifying production vehicles or engines, field fixes would
then be allowed on current model year vehicles in the hands of
the ultimate purchaser. The procedure for obtaining EPA approval
is summarized below. Appendix G contains a copy of the EPA
Advisory Circulari
© Submit requests for emission control modifications
in accordance with 40 CFR 85.58.
o For modifications to an engine-system combination
of certified vehicle or engine, run 50,000 mile
Durability and 4,000 mile Emission Data vehicle
testing. If the modification does not alter the
configuration of the engine-system combination,
then only the 4,000 mile Emission Data vehicle
testing is required. An example of this type of
modification would be alternate carburetor cali-
bration. Durability and Emission Data testing
would be required for other modifications such as
the addition of an air pump.
• Vehicles or engines modified for high altitude
operations must be capable of demonstrating that
they meet all applicable EPA emission control
standards when tested at the EPA laboratory.
& Manufacturers are encouraged to show by compara-
tive test data the effects of the modifications
on modified and unmodified vehicles or engines
operating at high altitudes to assist the EPA in
determining the impact of these modifications on
air quality.
& Labels prescribed under 40 CFR 85.4 shall indicate
the engine tune-up specifications of the modified
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vehicle or engine for the high altitude where
the vehicle or engine is intended to be sold.
7.1.2 Interim Tampering Policy
The Clean Air Act specifically prohibits any person to remove
or render inoperative any device or element of design installed
on a vehicle or engine in compliance with the regulation prior
to its sale and delivery to the ultimate purchaser, or for any
manufacturer or dealer to remove or render inoperative such
design elements after sale and delivery to the ultimate purchaser.
The Act provides for a maximum civil penalty of $10,000 for any
person who performs any of the prohibited actions.
The Interim Policy, as included in Appendix H, states that the
EPA 1s primary objective in enforcing the statutory prohibition
of tampering is to assure unimpaired emission control of a
motor vehicle during its useful life. Part of this policy is
directed toward the after market replacement of parts relating
to or affecting emission control. However, the scope of this
section and the study in general is vehicle engine modification
and retrofit devices. On this subject, the EPA will not regard
the following acts, when performed by dealers. to constitute
violations of the Act:
<9 Use of non-original equipment, after market part
or system as an add-on, auxiliary, augmenting,
or secondary part or system, if the dealer has
a reasonable basis for knowing that such use will
not adversely affect emissions performance.
© Adjustments or alterations of a particular part or
system parameter if done for purposes of maintenance
or repair according to manufacturer's instructions.
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or if the dealer has a reasonable basis for
knowing that such action will not adversely
affect emissions performance.
A reasonable basis can be established from one of the following
condi tions:
© The dealer knows of emission tests performed in
accordance with EPA requirements which showed
that the act did not cause similar vehicles or
engines to fail to meet applicable emission
standards for their useful lives (5 years or
50,000 miles in the case of light-duty vehicles); OR
9 The part or system manufacturer represents in
writing that tests as described in the item above
have been performed with similar results; OR
9 A federal, state, or local environmental control
agency expressly represents that a reasonable basis
exists.
The EPA presumes that the permanent removal, disconnecting, or
blocking of any part of the original system installed primarily
for emission control will adversely affect emission performance.
Additionally, the prescription and appropriate publication of
any prohibited act will be deemed conclusive that such an act
will adversely affect emission performance.
Dealers who install add-on parts or retrofit devices are pro-
tected against the tampering policy if:
® The part manufacturer represents in writing that
emission tests have been performed according to
federal procedures. Test results need not have
been reported to EPA, but the parts manufacturer
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must have information available on test data,
including where, when, how and by whom tests were
conducted, should EPA request it.
o The retrofit devices were installed to reduce
emissions at the request of a state or local
environmental control agency.
Dealers who perform necessary adjustments or alterations are
protected under the following conditions:
® Adjustments or alterations are performed on parts
already on the vehicle in accordance with vehicle
manufacturer's instructions.
e Adjustments or alterations are performed as part
of altitude fixes where a reasonable basis exists,
as previously described, that such action will
not adversely affect emission performance.
7.2 COLORADO LEGISLATION
Senate Bill 393, "Concerning Air Pollution Control and Providing
for the Establishment of a Motor Vehicle Emissions Control
Program," authorizes the Air Pollution Control Commission to
accomplish the following (Ref. 16):
o Adopt regulations concerning high altitude
tuning specifications to control motor vehicle
emissions in the State. (66-31-27)
9 Adopt regulations for the proper connection and
operation of air pollution control devices installed
by the manufacturer in any motor vehicle for the
purposes of controlling vehicle emissions. (13-5-113-2c)
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© Adopt rules and regulations governing other air
pollution control devices. (13-5-113-2c)
© Adopt rules and regulations which permit or allow
for the alteration, modification, or disconnection
of manufacturer-installed air pollution control
systems or manufacturer tuning specifications on
motor vehicles for the purpose of controlling
vehicle emissions. (13-5-160)
Thus, it appears that the State has empowered the Commission
with sufficient authority to require the installation of retrofit
devices and/or to alter or modify the vehicle or engine to
affect emission reductions. In view of the EPA policy statement,
the delegated authority, coupled with the emission test data as
reported in other volumes of this report, should provide the
reasonable basis for requiring these post-delivery changes to
the vehicles.
7.3 U.S. SENATE BILL 2236
The Senate Bill 2236, as proposed on July 24, 1973, was to amend
the Clean Air Act in order to provide for revised standards for
motor vehicles and engines to be sold or used in high altitude
areas (Ref. 17). Currently being reviewed by the Committee on
Public Works, the bill directs the EPA to determine special
requirements for emission control devices and systems in high
altitude states and the maintenance thereof, and directs vehicle
and engine manufacturers to meet these standards.
As used in the bill, a high altitude state means one having a
standard metropolitan statistical area (SMSA) with an average
elevation of at least 3,000 feet above sea level.
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The bill proposes to amend the requirements on compliance testing
and certification to include amended tests and standards with
respect to high altitude vehicles and engines such that the
standards established for the nation are complied with when the
vehicle or engine is operated in a high altitude state. This
requirement is applicable to vehicles and engines manufactured
during and after model year 1976.
With respect to state standards, the bill proposes to add the
stipulation that the Clean Air Act does not preclude or deny to
any state or political subdivision thereof the right to require
that vehicles and engines licensed for use in that state be in
conformity with the standards established for the class or
classes of new motor vehicles or engines.
7.4 MANUFACTURER'S WARRANTY REQUIREMENTS
The altering, modifying, or retrofitting of vehicles and engines
such that lower emissions result appears to be legally accept-
able by the EPA in view of its interim tampering policy. For
newer model vehicles which are operating within the warranty
limitations, the issue is whether these after market emission
reduction actions would lead to an infringement or non-compliance
of warranty requirements.
A letter describing the current Colorado Health Department study
on vehicle modifications was sent to four major domestic manu-
facturers (American Motors, Chrysler Motors, Ford and General
Motors) and to three major foreign manufacturers (Volkswagen,
Toyota and Nissan). Appendix I contains a copy of the inquiry
letter, addressees and responses.
7.4.1 Emission Control System
The warranty for 1972-and-newer models states that the vehicle
is free at the time of sale from defects in material and
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workmanship which would cause the vehicle to fail to conform
with EPA regulations for a period of 5 years or 50,000 miles.
Since the warranty covers the emission control system as con-
figured during the time of sale, the addition of after market
devices wotild not affect the manufacturer's warranty. However,
if failure to conform to EPA regulations occurs subsequently,
then the Question of whether the failure was caused by a defect
existing at the time of sale or by the addition of the after
market device will have to be evaluated in terms of the EPA
Interim Tampering Enforcement Policy.
7.4.2 Parts Replacement or Modifications
For vehicles covered by existing new car warranties, the use of
a nonoriginal-equipment-manufacturer (non-OEM) part or modifi-
cation would not void the warranty. However, if the use of
such a part or modification causes failure of other OEM compo-
nents, the warranty would not cover the replacement of the
affected components.
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REFERENCES
1. "Vehicles-in-Use Inspection Standards," U.S. Department of
Transportation, NHTSA, as recorded in the Federal Register,
Vol. 38, No. 171. 5 September 1973.
2. "Rules, Regulations and Requirements for Motor Vehicle
Official Inspection Stations." State of Colorado, Department
of Revenue, Motor Vehicle Division, DR PUB 15. Effective
July 1, 1967, as amended.
3. "Motor Vehicle Safety Inspection Program Study." Olson
Laboratories, Inc. Prepared under contract agreement for
the'State of Colorado, Department of Revenue, Motor Vehicle
Division. 15 November 1972.
4. "Mandatory Vehicle Emission Inspection and Maintenance."
Northrop Corporation in association with Olson Laboratories,
Inc. Under Contract ARB 1522 with the State of California
Air Resources Board. December 1971.
5. "Vehicle Emission Inspection and Control Program."
Olson Laboratories, Inc., under contract agreement
25 May 1972, with the State of Colorado, Department of
Health. November 1972.
6. "Effectiveness of Short Emission Inspection Tests in
Reducing Emissions through Maintenance - THE SHORT CYCLE
PROJECT." Olson Laboratories, Inc., under EPA Contract
68-01-0410, for EPA Office of Air and Water Programs.
July 31, 1973.
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7. "Requirements for Preparation, Adoption, and Submittal of
Implementation Plans." EPA Transportation Control Measures,
recorded in Federal Register, Vol. 38, No. 8. 12 January 1973.
8. "A Study of Mahdatory Engine Maintenance for Reducing
Vehicle Exhaust Emissions." TRW in association with Scott
Research Laboratories, prepared for CRC and EPA, APRAC CAPE-
13-68. July 1972.
9. "Analysis of Effectiveness and Costs of Retrofit Emission
Control Systems for Used Motor Vehicles." Olson Laboratories,
Inc., prepared under EPA Contract 68-04-0038 for the U.S. EPA,
Office of Air Programs. May 1972.
10. "Automotive News Almanac Issues," 1973, 1972, 1971.
Marketing Services, Inc., Division of Crain Communications,
Inc. Detroit, Michigan.
11. "Vehicle Emission Testing Program, Final Report for the
Concept and Criteria Phase." Olson Laboratories, Inc.,
prepared under contract for the City of Chicago. February 1973.
12. "Auto Air Pollution Questionnaire, Denver Metropolitan Area."
TRW. Part of a report prepared for the EPA Region VIII,
Denver. 1972.
13. "Air Pollution Research Report." Alire, L. and Clark, D.
Student paper presented to Dr. R. Beatty, University of
Colorado, Boulder. 1972.
14. "Public Response to Air Pollution in the Denver Area."
Jones, S. University of Colorado, Institute of Behavioral
Science. 9 August 1973.
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15. "The State of Colorado Air Pollution Control Transportation
and Land Use Plan." Colorado Department of Health.
14 May 1973.
16. Colorado Senate Bill 393, "Concerning Air Pollution Control,
and Providing for the Establishment of a Motor Vehicle
Emissions Control Program, and Making an Appropriation
Therefor." 1973.
17. U.S. Senate Bill 2236, Dominick, 24 July 1973, 93 Congress,
First Session, to amend the Clean Air Act.
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APPENDIX A
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APPENDIX A
NHTSA INSPECTION STANDARDS*
Vehicle System
Function Tested
Inspection Procedure
Service Brake
Failure
lamp
indicator
Brake system
integrity
Brake pedal
Apply parking brake and turn
ignition to start, or verify
operation following manu-
facturer's method.
With engine running for pow-
er assist, brakes, and igni-
tion turned to "on" for
others, apply force of 125
pounds for 30 seconds. Note
any pedal height decrease,
and whether failure indi-
cator illuminates.
Measure distance (A) from
free pedal position to
floorboard or other object
restricting pedal travel.
Similarly, apply force to
brake pedal and measure
distance (B). Determine
percentage as (A-B)/A x 100.
Failure occur if greater
than 80 percent. Engine
must be running for power
assist brakes. Pedal
reserve check not required
for vehicles with full
power (central hydraulic)
brake systems or for brake
systems designed to operate
with greater than 80 percent
pedal travel.
~Extracted from "Vehicle In Use Inspection Standard," U.S,
NHTSA, recorded in Federal Register, Volume 38, No. 171
5 September 1973.
DoT,
-------
Vehicle System
Function Tested
Inspection Procedure
Service brake
performance
Brake hoses and
assemblies
The following thre
of at least one fr
Disc and drum
condition
Verify that tire inflation
pressure within limits recom-
mended by vehicle manufac-
turer. Perform either (a)
or (b) of the following.
a. Roller-type or drive-on
platform - test must measure
equalization. Follow test
equipment manufacturer's
specification. Left to
right brake force variance
not to exceed 20 percent for
front tests or rear tests.
b. Road test - conducted on
a level (not to exceed
+_ 1 percent grade) dry,
smooth, hard surfaced road
that is free from loose
material, oil, or grease.
Apply service brakes at ve-
hicle speed of 20 mph. Ve-
hicle shall be brought to
a stop within 25 feet or
less without leaving a
12-foot wide lane.
Visually examine hoses and
note that they are not
mounted so as to contact ve-
hicle body or chassis, and
not cracked, chafed or
flattened. Inspect through
all wheel positions from
full left to full right.
e tests require the removal
ont and one rear wheel.
Visually examine for condi-
tions within specifications
if drum is embossed with
maximum safe diameter dimen-
sion or rotor is embossed
with minimum safety thick-
ness dimension. If not em-
bossed, the drums and discs
shall be within the manufac-
facturer's specifications.
-------
Vehicle System
Function Tested
Inspection Procedure
Friction material
Struqtural and
mechanical parts
Brake Power
Unit
Vacuum hoses
Visually examine and note
that lining or pad thickness
shall not be less than one
thirty-second of an inch
over the rivet heads, or the
brake shoe on bonded linings
or pads. Linings and pads
shall not have cracks or
breaks that extend to rivet
holes except minor cracks
that do not impair attach-
ment. Linings shall be
securely attached to brake
shoes, pads shall be secure-
ly attached to shoe plates.
Visually examine backing
plates and caliper assem-
blies and note that they are
not deformed or cracked.
System parts shall not be
broken, misaligned, missing,
binding, or show evidence of
extreme wear. Automatic
adjusters and other parts
shall be assembled and in-
stalled correctly.
With engine running, visual-
ly and aurally examine hoses
and note that they are not
collapsed, abraded, broken,
improperly mounted, or
audibly leaking. Stop en-
gine and deplete residual
vacuum by applying service
brakes several times. Apply
constant 25-pound force on
brake pedal, and start en-
gine. Brake pedal should
fall slightly. This test
not applicable to vehicles
equipped with full power
brake system for which the
service brake test shall be
adequate.
-------
Vehicle System
Function Tested
Inspection Procedure
Steering Sys-
tem
System play
Linkage play
Free turning
Alignment
With engine running and
wheels in straight ahead
position, turn steering
wheel in one direction until
perceptible movement of
front wheel is noted. Arbi-
trary point on steering
wheel rim shall not move
more than value shown below
before this perceptible move-
ment is noted. If value is
exceeded there is excessive
lash or free play in steer-
ing system.
Steering Wheel Lash
Diameter (Inches) (Inches)
16 or less 2
18 2 1/4
20 2 1/2
22 2 3/4
Elevate vehicle front end to
load ball joints. Insure
that wheel bearings are cor-
rectly adjusted. Grasp
front and rear of tire and
attempt to turn tire and
wheel assembly left and
right. Free movement at
front or rear tire tread
shall not exceed one-quarter
inch.
Turn steering wheel through
limit of travel in both
directions. Feel for bind-
ing or jamming in steering
gear mechanism.
Measure toe-in and toe-out
using scuff gauge and note
that recorded value does not
indicate greater than 30 feet
per mile. If equivalent de-
vice is used, follow manu-
facturers instructions.
-------
Vehicle System
Function Tested
Inspection Procedure
Suspension
System
Power steering
system
Suspension condi-
tion
Shock absorber
condition
Tires
Tread depth
Visually examine for cracked
or slipping pump belts or
insufficient fluid in reser-
voir.
Visually examine and note
that ball joint seals shall
not be cut or cracked, struc-
tural parts shall not be
bent or damaged, stabilizer
bars shall be connected,
springs shall not be broken
or extended by spacers.
Shock absorber mountings,
shackles, and U-bolts shall
be securely attached. Rub-
ber bushings shall not be
cracked, extruded out from
or missing from suspension
joints. Radius rods shall
not be missing or damaged.
Visually examine shock
absorbers for oil leaking
from seals. Push down on
one end of vehicle, release,
and note that number of
cycles of free rocking motion
does not exceed two cycles.
Repeat procedure at other end
of vehicle.
Visually examine each tire
tread and note that tread
shall not be less than two
thirty-seconds of an inch
deep. Passenger car tires
have tread depth indicators
which become exposed when
tread depth is less than two
thirty-seconds of an inch.
Inspect for indicators in any
two adjacent major grooves at
three locations spaced
approximately equally around
outside of tire. For other
than passenger cars, it may
be necessary to use tread
gauge.
-------
Vehicle System
Function Tested
Inspection Procedure
Type
Visually examine for major
mismatch in nominal size,
construction, and profile
between tires on same axle,
or for major deviation from
manufacturer's recommenda-
tion (for 1968 and newer
vehicles see glove box
placard).
General condi-
tions
Visually examine and note
that tires shall be free
from chunking, bumps, knots,
or bulges evidencing cord,
ply, or tread separation
from the casing or other
adjacent materials.
Wheel Assem-
blies
Wheel integrity
Visually examine and note
that tire rim, wheel disc,
or spider shall not have
visible cracks, elongated
bolt holes, or indication
of repair by welding.
Deformation
Using runout indicator gauge
and suitable stand, measure
lateral and radial runout of
rim bead through one full
wheel revolution. Runout
shall not exceed three
thirty-seconds of an inch.
Mounting
Check wheel retention by
noting that all wheel nuts
and bolts are in place and
tight.
-------
APPENDIX B
DRAFT OF RECOMMENDED INSPECTION PROCEDURE,
-------
INSPECTION PROCEDURE, EQUIPMENT,
AND REJECTION LIMITS
STATE OF COLORADO
DEPARTMENT OF REVENUE
MOTOR VEHICLE DIVISION
B- 2
-------
Revisions affecting this document:
Change Date
Pages
Remarks
1
:
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CONTENTS
Section Page
I Wheels and Tires
II Steering, Alignment and Suspension
Ill Brakes
IV Lighting and Electrical Systems
V Vehicle Glazing
VI Body and Sheet Metal . .
VII Exhaust and Fuel Systems
-------
SECTION I
WHEELS AND TIRES
Reference is made to the additional wheel and ti-e information shown in Figures 1
and 2 for visual aid in determining tire wear. This inspection is visual.
Procedure
Equipment
Reject Vehicle
A. Inspect for tire
wear
I. Tires without
tread wear
indicators
2. Tires with
tread wear
indicators
3. Inspect for
cord exposure
B. Inspect for tread
cuts, snags, or
sidewall cracks
C. Inspect for bumps,
bulges, or knots
D. Inspect for re-
grooved or recut
tires
E. Inspect for mis-
matching of tires
F. Inspect for tire
size
Tread depth
measuring
gauge
A. Reject as follows:
1. If tire is worn so that less than 2/32
inch tread remains when measured in any
two adjacent major grooves at three lo-
cations spaced approximately equally
around outside of tire (Figure 2(c))
2. If tire is worn so that the tread wear
indicators contact the road in any two
adjacent major grooves at three loca-
tions spaced approximately equally
around outside of tire (Figure 2(a))
3. If tire has a worn spot that exposes the
cord through the tread
B. If tire has tread cuts, snags, or sidewall
cracks in excess of 1 inch in any direction,
and deep enough to expose cords
C. If tire has visible bumps, bulges, or knots
indicating partial failure or separation of
the tire structure
D. If tire has been regrooved or recut below
original groove depth, except special tires
which have under tread rubber for this pur-
pose and can be identified as such
E. If tires are not same type or size on one
side of vehicle as on other (difference in
brand or tread .ire not cause for rejection)
F. If tires are smaller than manufacturer's
specified minimum or larger than specified
maximum
-------
Procedure
Equipment
Reject Vehicle
G.
Inspect wheel
bolts, nuts or
lugs
G.
If wheel bolts, nuts, studs, or lugs are
loose, missing, or damaged
H.
Inspect for wheel
damage
H.
If any part of wheel ia bent, cracked, re-
welded, or damaged so as to affect safe
operation of vehicle
I.
Visually inspect
for restricted
usage marking on
tire (reclassi-
fied tires)
I.
If tire is marked "for farm use only,"
"off-highway use only," "for racing use
only," etc.
J.
Front tire and
wheel runout
Portable
gauge to
measure
play
J.
If runout is greater than 1/4" (measured
as indicated in Figure 2(b))
GROOVE
SIDEWAll
Definitions
RIM - A metal support for a tire or a tire and tube assembly upon which
the tire beads are seated.
BEAD - That part of the tire made of steel wires wrapped or reinforced
by ply cords: that is, shaped to fit the rim.
SIDEWALL - That portion of the tire between tread and bead.
CORD - The strands forming the plies in the tire.
PLY - A layer of rubber-coated parallel cords.
TREAD - That portion of the tire that comes into contact with the road.
TREAD RIB - The tread section running circumferentially around the tire.
GROOVE - The space between two adjacent tread ribs.
BELT - A layer or layers made of fabric or other material located under
the tread area.
Figure 1. TIRE CONSTRUCTION
-------
(b)
(c)
Figure 2. TliiE TREAD DEPTH GAUGE WEAR INDICATOR
-------
SECTION II
STEERING ALIGNMENT'AND SUSPENSION
The steering system of the vehicle must be inspected to determine if excessive
wear and/or maladjustment of the linkage and/or steering gear exists. The vehicle
must be on a dry surface. On vehicles equipped with power steering, the engine
must be running and the fluid level and belt tension must be adequate before testing.
Procedure
Equipment
Reject Vehicle
A, Lash or Free Play - With
road wheels in straight-
ahead position, turn
steering wheel until
turning motion can be
observed at road wheels;
measure lash
A. If more than 2 inches of
total movement at steering
wheel rim is encountered
before front road wheels
move
B. Travel - Lift one front
wheel off surface; turn
steering wheel through a
full right and left turn
and feel for binding or
jamming conditions
Floor jack
B. If front wheels are incapa-
ble of being turned to
right and left steering
stops without binding or
interference
LINKAGE AND RELATED PARTS - The steering system and related linkage and parts must
be inspected to determine possible wear or damage to all points.
WHEEL BEARINGS - Wheel bearings out of adjustment can cause wander, erratic front
brake action, and noise due to interference of parts.
C. Wheel Bearings - With
front end of vehicle
lifted properly, grasp
front tire top and bot-
tom, rock it in and out,
and record movement; to
verify that any loose-
ness detected is in wheel
bearing, notice relative
movement between brake
drum or disc and backing
plate or splash shield
(Figure 4)
Floor jacks or hoist;
lift to load ball
joints
1. Spring or torsion
bar on lower arm,
hoist at frame
(Figure 3)
2. Spring or torsion
bar on upper arm,
hoist at lower arm
close to ball
joint (Figure 5)
C. If relative movement between
drum and backing plate is
excessive (more than 1/8-
inch measured at outer cir-
cumference of tire)
(NOTE - Wheel bearing play can be eliminated by applying service brakes)
-------
77T77777777777777777
r~K
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II M
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T77777777777//V7777777777777777',
Figure 4
Figure 5
Procedure
Equipment
Reject Vehicle
LINKAGE PLAY - Excessive free play causes wheel shimmy, erratic brake action, and
steering control problems. Make sure any looseness detected is not wheel bearing
free play.
SPRING OR TORSION BAR HEIGHT - Optimum front spring height is established as part
of the overall design of front wheel alignment angles.
D. Steering Linkage Play -
With front end lifted
properly, grasp front and
rear of tire and attempt
to turn assembly right
and left; record movement
at extreme front or rear
of tire (Figure 6)
Follow procedure C for
correct lifting.
Brakes should be ap-
plied during inspec-
tion either by
another person or by
use of a portable
D. If measurement is found to
be in excess of:
WheeIs
1/4 inch - 16 inches or less
3/8 inch - 17 and 18 inches
1/2 - over 18 inches
-------
Figure 6
Figure 7
Procedure
Equipment
Reject Vehicle
brake depressor to
eliminate wheel bear-
ing play
Portable gauge to
measure play
FRONT WHEEL ALIGNMENT - There are five basic factors which are the foundation to
front wheel alignment: caster, camber, toe-in, steering axis inclination, and
toe-out in turns. All are mechanically adjustable except steering axis inclina-
tion and toe-out on turns. Overall front wheel alignment can be somewhat grossly
indicated by measurement of front wheel toe. Excessive toe-in or toe-out is a
general indication that a complete check should be made of all front wheel align-
ment factors.
Drive-on sideslip
indicator
E. Toe (In-Out) (Figure 7) -
With wheels held in a
straight-ahead position,
drive vehicle slowly over
measuring device; record
results
BALL JOINTS MUST BE UNLOADED FOR INSPECTION.
E. If slideslip (or'scuff) is
found to be in excess of 30
feet per mile
Where caster, camber, or
toe-in are so excessively
out of adjustment as to be
apparent visually
NOTE: "Vertical" movement of ball joints is referred to in some shop manuals as
"axial" movement.
F. Ball Joint Wear - With
front end of vehicle
lifted properly and front
wheel bearing adjusted
properly:
Dial indicator, swivel
and stand; floor jack
safety stand; lift ve-
hicle to unload ball
joints
F. If ball joint movement is in
excess of manufacturers'
specifications shown in Fig-
ures 10 and 11
-------
Procedure
Equipment
Reject Vehicle
Attach dial indicator
1. Spring or torsion
If the ball joint seals are
to lower control arm
bar on lower arm,
cut, torn, or otherwise
(Figure 8) to accurately
lift vehicle at
damaged
measure horizontal or
lower arm (Figure
vertical movement be-
9)} position stand
tween ball joint and its
as far outboard as
socket
possible
Grasp tire and wheel as-
sembly at 11 and 5
o'clock positions on
tire; check movement of
the wheel by moving top
and bottom of tire in and
out, using sufficient
hand load to take any
clearance, but not in ex-
cess to deform tire or
suspension; repeat oper-
ation at 1 and 7 o'clock
positions.
(NOTE - Measure tolerances as indicated in Figures 12(a) and 13(a))
Position a pry bar under
front tire and wheel, and
with a lifting motion
move wheel (using suffi-
cient loading to take up
any clearance) up and
down; observe movement
shown on dial indicator
Spring or tors.ion
bar on upper arm,
lift vehicle at
front crossmember
(Figure 14); wheel
and lower support
arm must be free
(NOTE - Measure tolerances as indicated in Figures 12(b) and 13(b)
-------
BALL JOINTS - MANUFACTURER'S TOLERANCES
LOWER BALL JOINT
Vertical Movement
Horizontal Movement
WITH SPRING OR TORSION BAR ON LOWER ARM
Hoist vehicle at lover am as shown to
unload ball joints.
1. Install floor stands under both RH and
LH lower control arms, outboard as far
as possible. Car must be stable.
2. Upper arm must be free from rubber
fcu.T.por.
3. tohtiel hearings must be properly adjuetad.
4. Check ball joints according to chart.
Replace if
movement ex
fh
i
rt =
_ uax
- |-10L
fteplaeS Lf horizontal
movement exceeds toler-
ances listed below.
ver
cee
T
tical
ds toler-
MODEL
YEAR
Chrysler
DeSoto
Dodge
Plymouth
Valiant (Barracuda)
Dart (Lancer)
Imperial
Colt
Cricket
57-64
65-72
57-61
57-67
68-72
57-67
68-72
60*67
68-72
60-67
68-72
67-66
67-72
71-72
71-72
.07
Ze
t
0"
ro
i
Edsel
Ford
Lincoln
Mercury
Pinto
Thunderbizd
58-60
54-72
52-72
64-72
71-72
55-60
67-72
61-66
1
.200"
1
See Fig. 11
,2i
1
0"
Buick Special
Buick
61-63
64-68
69-72
67-60
61-70
71-72
t
.150"
1
Zero**
1
1
Cadillac
ElDorado
57-72
67-72
.062"
.126"
~
*
Chevrolet
Chevelle
Corvoir
Corvette
Camaro
Chevy II (Nova)
All Models (IncL Vega)
66-6;»
64-70
64-70
60-63
64-70
66-63
64-70
67-69
70-72
62-67
68-70
71-72
t
.100"
1
Not Applicable
.070"
.070"
Zero**
See Fig. 11
.060"
Zero**
~
.2^0"
*
•
.250"
.250"
*
.260"
•
Oldsmobile FBS
Toronado
Oldsmobile
61-63
64-72
66-72
87-70
71-72
t
.125"
\
Zero**
t
*
i
PoDtiac
Pontiac
Tempest
Tempest (Le Mans)
Grand Prix—Le Mans
Firebird
Pontiac (Bonneville, etc)
68-64
65-70
61-63
64-
65-69
70-72
70-72
71-72
.lJo"
1
Zero**
~
*
«
.250"
.250"
t
• Do not test ball joints by reading horizontal movement of tire.
*'Preloaded in rubber. Can be inspected only after removal from steering knuckle.
Figure 10
-------
BALL JOINTS - MANUFACTURERS' TOLERANCES
UPPER BALL JOINT
Vertical Movement
Horizontal Movement
WITH SPRING OR TORSION BAR ON UPPER ARM
Hoist vehicle as shown to unload ball joints.
1. Hoist vehicle on frame crossmember or
side rails.
2. Wheel bearings must be properly adjusted.
3. Check ball joints according to chart.
&
MAX.
TOL.
HAX.
.•oi. .-~j
MMl
j J ^
l_L/
= !
Replace if vertical
movement exceeds toler-
ances listed below.
Replace if horizontal
movement exceeds toler-
ances listed below.
MODEL
YEAR
MAVERICK
COMET
COMET
METEOR
69-72
60-62
63-72
62-6 3
.200"
.250
FALCON
FALCON
FAIRLANE
MUSTANG
COUGAR
60-62
63-72
62-72
65-72
67-72
.200"
.250
THUNDERBIRD
61-66
67-72
.200"
See Figure 10
.250
CHEVY II
CHEVY II
62-63
64-67
.100"
.250
INTERNATIONAL
1000 - TRAVELALL
60-72
.095"
Do not test horizontal
movement
AMERICAN MOTORS-ALL MODELS
AMERICAN MOTORS-ALL MODELS
62-69
70-72
NO UPPER 8 A
.080"
L L JOINT
. 1 60"
-------
#il? H-*
¦ 8,2p^l
(a)
-
(b)
4^
Figure 12
Figure 13
Load carrying
ball joint
_ . ^ Non-load carrying ball joint
FOR BALL JOINT INSPECTION
Figure 14
-------
Procedure
Equipment
Reject Vehicle
Sagging springs, broken torsion bars, worn or deteriorated bushings, loose shackles
and loose or mislocated "U" bolts can cause vehicle handling instability and brake
pull.
U. Springs - With unloaded
vehicle on a level sur-
face, visually inspect
heights of four corners
of vehicle; if necessary,
use measuring device and
determine differences
from side to side; vis-
ually inspect for broken
leaves or bar damage;
inspect spring shackles,
bushings, and "U" bolts
H. Shock Absorbers - With
car on a hoist or jacked
up, visually inspect
shock absorbers for ex-
cessive leakage, and
looseness of mounting
brackets and bolts
Hoist or hydraulic
jack, scale, and
trouble light
Hoist or hydraulic
jack and trouble
light
G. If springs or torsion bars
are broken
If shackles or "U" bolts are
worn or loose
H. If severe leakage (not slight
dampness) occurs
If mounting bolts or mounts
are broken or loose
Possible causes for improper rear wheel tracking can consist of any one of the
following:
Broken main leaf on rear spring; shifted axle on center bolt; bent or out-of-
adjustment trailing links or radius rods, sway bar, or track bar; bent or damaged
axle housing or frame.
Rear Wheel Tracking -
Using a tape measure,
determine distance be-
tween centerline of front
wheel spindle and center-
line of rear axle drive
shaft and compare from
side to side* (front
wheels must be in
straight-ahead position)
Measuring tape, hoist,
hydraulic jack, and
trouble light
I. If wheel base on one side is
different from wheel base on
other side by more than 1
inch*
If rear axle is obviously
misaligned
*Not applicable if vehicle specifications indicate different left and right wheel-
base dimensions as designed.
-------
SECTICm III
BRAKES
The engine should be running when checking vehicles with power-assisted hydraulic
systems.
Procedure
Equipment
Reject Vehicle
A. Brake Hydraulic System
Leakage - While vehicle
is stopped, driver should
be able to apply a mod-
erate foot force (40-60
pounds in nonpowered sys-
tems, and 15-20 pounds in
power-assisted systems)'
and maintain same pedal,
height for 1 minute
Pedal
pressure gauge
A. If brake pedal height cannot
be maintained for 1 minute
B. Pedal Reserve - While
vehicle is stopped, de-
press brake pedal under
moderate foot force (40-
60 pounds in nonpowered
systems and 15-20 pounds
in power-assisted
systems)
Pedal
pressure gauge
B. If less than 1/5 of total
available pedal travel
remains
SIMPLE TESTS AND VISUAL INSPECTION PROCEDURES - Service brake tests should be con-
ducted on a substantially level, dry, hard, smooth surface road or area that is
free from loose material, oil, or grease. Using the service brake only, the stop-
ping ability of the vehicle should be tested by the following method:
C. Service Brake - On Road -
At a speed of 20 mph,
apply service brakes
firmly; observe whether
vehicle comes to a
smooth stop within dis-
tance prescribed by
state law without pull-
ing to the right or left
causing it to leave a
lane 12 feet wide;
driver should have firm
control of steering
wheel throughout test
Tape measure or pre-
marked lane
C. If vehicle does not stop
within following limits:
4-wheel service brakes on
any single vehicle or com-
bination of vehicles -
40 feet
2-wheel service brakes on
any single vehicle -
55 feet
Hand brake on any vehicle
or combination of vehicles
- 55 feet
-------
Procedure
Equipment
Reject Vehicle
If vehicle swerves enough
for any wheel to leave the
12-foot lane
Drive vehicle over a
premeasured distance
(1/4-mile minimum) at a
constant speed, and re-
cord elapsed time (max-
imum speed, 30 mph)
Stopwatch
If recorded elapsed time is
not within 20% of estimated
trip time
BRAKE LININGS AND PADS - It is recommended that at least one front or one rear
wheel and drum assembly be removed for inspection of linings on drum brakes.
D. Condition of Linings
D. Reject as follows:
and Pads -
1. Bonded Linings -
Measuring device
1. If thinnest point is less
Measure lining thick-
(steel scale or
than 1/16 inch
ness at thinnest point
gauge)
2. Riveted Linings -
Steel scale or gauge
2. If any rivets are loose
Inspect for loose or
or missing
missing rivets
Measure lining thick-
If lining is worn to
ness above rivet head
within 3/32 inch
at thinnest point
3. Wire-Backed Linings -
3. If wire is visible on
Inspect for wire show-
friction surface
ing on friction sur-
face of lining
4. All Linings - Inspect
4. If lining is broken,
for broken or cracked
cracked, or not firmly
linings, and parts of
and completely attached
linings not firmly
to shoe
attached to shoe;
Also for contamination
If friction surface is
and excessively uneven
contaminated with oil or
lining wear
grease
If lining wear is ex-
tremely uneven
-------
Procedure
Equipment
Reject Vehicle
NOTE: It is imperative that the brake system reservoir cover and the surrounding
area be thoroughly cleaned before the cover is removed for inspection to
assure that NO DIRT is mixed with the brake fluid.
E. Hydraulic System - Vis-
ually inspect condition
of hydraulic system
1. Wheel Cylinders - In-
spect for leakage
2. Hydraulic Hoses and
Tubes - Inspect for
leaks, cracks, chaf-
ing, flattened, or
restricted sections,
and improper support
3. Master Cylinder -
Inspect for leakage
and fluid level (Be
sure no dirt gets into
reservoir when cover
is removed and that
gasket is serviceable)
F. Dual Hydraulic Circuits -
In addition to above, if
vehicle is equipped with
a brake warning light:
Test operation of light
With ignition switch on,
apply 40-60 pounds of
pedal force (15-20
pounds for power-
assisted brakes), and
observe light
Steel scale
E. Reject as follows:
1. If wheel cylinders leak
2. If hoses or tubing leak
or are cracked, chafed,
flattened, restricted, or
insecurely fastened
3. If master cylinder leaks
If fluid level is more
than 3/4 inch below top
of reservoir
If gasket is torn or
misshapen
F. Reject as follows:
If light is burned out
If light comes on when
brake pedal is depressed
Many of today's cars have a combination of disc (caliper) type brakes on the front
wheels and drum type brakes on the rear wheels. On vehicles equipped with disc
brakes, some drag can be felt when turning the wheel and tire. This drag is NOT
excessive if the wheel can be turned readily with both hands.
-------
Procedure
Equipment
Reject Vehicle
G. Brake Drums - Inspect
condition of drum fric-
tion surface for substan-
tial cracks extending to
open edge of drum (short
hairline heat check
cracks should not be
considered)
G. If there are substantial
cracks on friction surface
extending to open edge
Inspect for cracks on
outside of the drum
If there are external cracks
Inspect for mechanical
damage
If there is evidence of me-
chanical damage, other than
wear
Inspect for contaminated
friction surface
If friction surface is con-
taminated with oil, grease,
or brake fluid
Measure inside diameter
of drum
If brake drums have been
remachined beyond tne fol-
lowing specifications;
Small diameter drums up
to 14 inches in diameter
not to be worn or
machined beyond 0.060
inch in diameter or 0.030
inch on a side
Large diameter drums 14
inches and over not to be
machined beyond 0.090
inch and not to be worn
beyond 0.120 inch
H. Brake Discs - Inspect for
substantial cracks ex-
tending to edge of disc
H. If there are substantial
cracks extending to edge
Inspect for mechanical
damage
If there is evidence of me-
chanical damage other than
wear
Measure thickness of
disc
If disc brake pad thickness
does not conform to the fol-
lowing manufacturers'
spec if icat ions;
-------
Procedure
Equipment
Reject Vehicle
Disc
Make Brake Pad
American Motors 1/16"
Chrysler Corp. 1/32"
Ford Motor Co. 1/32"
General Motors 1/32"
Studebaker 1/4"
(incl. shoe)
All Foreign and Replacement
Sports Cars thickness
according to
factory spe-
cifications
I. Vacuum System -
I. Reject as follows:
1. Condition of •• Inspect
1. If hoses or tubes are
system visually for
leaking, or are collapsed,
collapsed, broken,
broken, badly chafed, im-
badly chafed and im-
properly supported, or
properly supported
loose because of broken
hoses and tubes, and
clamps
for loose or broken
hose clamps
2. Operation of - Deter-
2. If service brake pedal
mine if system is oper-
does not move slightly as
ating by first stopping
engine is started while
engine; then depress
pressure is maintained on
brake pedal several
pedal
times to destroy all
vacuum in system; then
depress pedal with a
light force; while
maintaining this force
.on pedal, start engine
and observe if pedal
moves slightly when
engine starts
PARKING BRAKE INSPECTION - Parking brakes on most U.S. vehicles function through at
Least one set of the rear service brake shoes. A few U.S. vehicles have disc type
service brakes on all four wheels, which make it necessary to have separate drums
for the parking brakes. These drums and linings should be inspected in a manner
similar to that for service brakes. Any parking brake should hold a stopped vehicle
firmly on all normal road gradients.
-------
Procedure
Equipment
Reject Vehicle
J. Parking Brake Function -
Set parking brake firmly
to determine reserve
travel of hand lever or
foot pedal
J. If there is no reserve
travel in the Lever (or
pedal)
Hand brakes must be capa-
ble of holding any loaded
vehicle or combination of
Loaded vehicles on any
grade upon which it is
operated
If hand/parking brake wiiL
not hold vehicle when oper-
ated in second gear (or
"drive" if automatic
transmission)
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SECTION IV
LIGHTING AND ELECTRICAL SYSTEM
Preparation for headlamp and aim Inspection is t:o be done by the owner of the
vehicJLe prior to inspection
ANY ONE of the items listed below can affect the inspection results, causing rejec-
tion of the vehicle. To prevent this, the four items listed in procedure A should
be. che.cked prior to inspection.
Procedure
Equipment
Reject Vehicle
A. Prior to Inspection -
A. If any one of these items
are not accomplished to a
1. Remove excessive ice
reasonable degree, thereby
and mud from under
making a good inspection
fenders
difficult (inspector should
refuse vehicle until pre-
2. Inflate tires to spe-
paration is satisfactory)
cified pressures
.3. See that vehicle con-
tains no load other
than driver in his
normal position
A. Be sure that lenses
are clean; check for
burned-out bulbs and
proper beam switching;
replace headlamps with
cracked or broken
aiming pads
GENERAL LAMP AND REFLECTOR INSPECTION - This includes all original equipment ex-
terior lighting plus whatever lights have been added. If a vehicle is equipped
with a light, it should work properly.
See ADDITIONAL LIGHTING INFORMATION. Definitions: Page A-25-- SAE Coding: Page A-
B. Lamp Function - Turn on
night-driving lights and
visually check the fol-
lowing (check 1 and 2
with ignition switch
"on"):
Large mirrors may be
placed so that all
lamps may be observed
from driver's pos-
ition
B. If any bulb or sealed beam
unit fails to light
-------
Procedure
Equipment
Reject Vehicle
1. Actuate turn signal
1. If turn signals do not
lever to right and
properly indicate right
left and observe func-
and left when so switched
tion of turn signal
lights (1958 vehicles
or later)
2. Place vehicle in re-
2. If backup light system
verse gear and check
does not turn off auto-
backup lamps (if car
matically when vehicle
is so equipped)
goes forward
3. If car is so equipped,
3. If lamp shows color con-
actuate the following
trary to law
and observe lamps:
If lamp fails to light
Hazard warning lamps
proper filament indicated
at switch position
Brake warning lamps
If any lamp or reflector
Indicator lamps
does not direct light
properly
Stop lamps
If auxiliary equipment is
Headlamps - upper and
placed on, in, or in
lower beam (see Pro-
front of any lamp
cedure C)
If lamp assembly is im-
properly fastened
If lamp has a cracked,
broken, or missing lens
U. Observe function of:
Tail lamps
Parking lamps
Side marker lamps
Reflex reflectors
Clearance lamps
Identification lamps
Emergency warning
lamps
All others
-------
Procedure
Equipment
Reject Vehicle
HEADLAMPS - The vehicle must be located on a level area and loaded as it is normally
driven with the driver behind the wheel. U.S. headlamps (see Figure 15) are always
"sealed beam" and come in two sizes:
5-3/4-irich-ciiameter bUAL upper beam, Type 1, and lower beam, Type 2.
7-inch-diameter SINGLE - both upper and lower beam (most 7-inch lamps are
Type 2 only).
C. Headlamps -
Photo-optical head-
lamp testing machine
Driving or High Beam -
Check in accordance
with tester's instruc-
tions (this includes
single-beam 5-3/4-
inch-d intreter Type 1
lamps and older 7-
inch-d i.amerer dual-
filament lamps which
do not have a figure
2 molded in the lens
near the top)
C. Reject as follows:
1. If horizontal aim is more
than 6 inches to the left
or 6 inches to the right
If vertical aim is higher
than 4 inches up or lower
than 4 inches down
If candlepower is less
than 10,000
To save time, the.inspector should develop his own plan or sequence for checking
miscellaneous electrical items, many of which can be inspected while looking at
other items. This comes with practice.
2. Passing or Low Beam
and Fog Lights - Check
in accordance with
tester's instructions
(this includes dual-
filament 5-3/4-inch-
di.ameter Type 2 lamps
and dual-filament 7-
inch-diameter Type 2
lamps; all headlights
in this class have fig-
ure 2 molded in lens
near top)
2. If horizontal aim is more
than 15 inches to the Lefi
or 21 inches to the right
If vertical aim is higher
than 9 inches up or lower
than 13 inches down
If candlepower is less
than 7,000
LOCATION OF
IDENTIFICATION
NUMERAL
Trod* No. 4001-^T)rpt 2) Low*/ (Patting) >>am
•Trada No. 400l>(Typ« 1) Uppo* (Driving) Itont
Pig " ["in"
Figure 15
-------
Procedure
Equipment
Reject Vehicle
D. Electrical System -
D. Reject as follows:
1. Horn - Should be
securely fastened
1.
If horn is loose or fails
to function
2. Switches - Should all
function properly
2.
If switches fail to func-
tion or turn signal switch
fails to cancel (if so
designed)
3. Wiring - Should be
well insulated
3.
Wiring insulation is worn,
rubbed bare, or shows any
evidence of burning or
short-c ircuiting
ADDITIONAL LIGHTING INFORMATION - PASSENGER CARS
Definitions
A. Sealed Beam Headlamp Assembly
A sealed beam headlamp assembly is a major lighting device used to provide general
illumination ahead of the vehicle. It consists of the following:
1. One or more sealed beam units (bulb assembly).
2. Means for mounting securely to the vehicle.
3. Means to permit required aim adjustment.
B. Sealed Beam Unit
An integral and hermetically sealed optical assembly with the name "Sealed Beam"
molded in the lens.
C. Headlamp Upper Beam
A distribution of light intended primarily for distant illumination and for use
on the open highway when not meeting other vehicles.
-------
D. Headlamp Lower Beam
A distribution of light so directed as to avoid glare in the eyes of oncoming
drivers while providing illumination ahead of the vehicle and intended for use in
congested areas and on highways when meeting other vehicles within a distance of
500 feet.
E. 7-Inch Sealed Beam Unit
1. A sealed unit 7 inches in diameter providing an upper and a lower beam.
Two similar units are used on a vehicle. This unit is identified by a
number "2" on the lens and is aimed on the lower beam.
2. 7-Inch Sealed Beam Unit (no identifying number on lens) - A sealed unit
7 inches in diameter providing an upper and lower beam. Two similar units
are used on a vehicle. This is an obsolete unit no longer being installed
in production. It should be aimed on the upper beam.
F. 5-3/4-Inch Type 1 Sealed Beam Unit
A sealed unit 5-3/4 inches in diameter having a single filament and providing only
an upper beam distribution of light.
G. 5-3/4-Inch Type 2 Sealed Beam Unit
A sealed unit 5-3/4 inches in diameter having two filaments, one filament providing
the lower beam and one filament providing fill-in light for the upper beam. It is
aimed on the lower beam.
H. Symmetrical Beam
A symmetrical beam is one in which both sides are symmetrical with respect to the
median vertical plane of the beam. Lamps having symmetrical beams are:
1. ?. V4-inch Type 1
-------
2. 5-3/4-inch Type 2 (upper beam filament)
3. Ail 7-inch units (upper beam filament).
I. Asymmetrical Beam (Nonsymmetrical)
An asymmetrical beam is one in which both sides are not symmetrical with respect
the median vertical plane of the beam. All lower beams are asymmetrical.
J. Fog Lamps
Fog lamps are lamps which may be used with or in lieu of the lower beam headlight
to provide illumination under conditions of rain, snow, dust, or fog.
K. Tail Lamps
Tail lamps are lamps used to designate the rear of a vehicle.
L. Stop Lamps
Stop lamps are lamps giving a steady warning light to the rear of a vehicle, to
indicate the intention of the operator of the vehicle to reduce speed or stop.
M. License Plate Lamps
License plate lamps are lamps used to illuminate the license plate on the rear of
a vehicle.
N. Parking Lamps
Parking lamps are lamps used to designate the front of a parked vehicle.
0. Side Marker Lamps
Side marker lamps are lamps on the left and right sides, beamed to the side,
intended to indicate vehicle length. They are located near the front and rear on
each side, and for vehicles over 30 feet in length, are also located at the mid-
point (intermediate side marker).
-------
P. Backup Lamps
Backup lamps are lamps used to provide illumination behind the vehicle, and to
provide a warning signal when the vehicle is in reverse gear.
Q. Turn Signal Lamps
Turn signal lamps are lamps which provide a flashing warning light to indicate the
intended direction of the turn.
K. Emergency Warning Lamps
Emergency warning lamps are !j.amps which provide a flashing light to identify an
anf-.horizp.d vehicle on an emergency mission. The emergency signal may be either a
rotating beacon or pairs of alternately or simultaneously flashing lamps.
S. Hazard Warning Lamps
Hazard warning lamps are turn signal lamps which flash simultaneously to warn of
t.he presence of a vehicular hazard.
T. Reflective Devices
Reflective devices are devices used on vehicles to give an indication to an ap-
proaching driver by reflected light from the headlamps of approaching vehicles.
II. Indicator Lamps
Indicator lamps are lamps visible to the operator of a vehicle that indicate:
1. Appropriate electrical circuits are in operation
2. Malfunction of vehicle performance
3. Requirement for remedial action by the operator of the vehicle.
-------
V. Operating Units or Switches
Operating units or switches are devices by which the functioning of lamps are
controlled.
W. Lane Changer
A lane changer is a device, usually incorporated in the turn signal switch which
will actuate the turn signal lamps when held by the driver. It is intended for
momentary use for signaling a lane change. When released by the operator, it will
return to neutral and deactivate the signal lamp.
X. SAE Lighting Identification Code
The SAE lighting identification code is a series of standardized markings for light-
ing devices which a manufacturer or a supplier may use to mark his product to indi-
cate the SAE Lighting Standard or Standards to which the device is designed to con-
form. The code is not intended to limit the manufacturer or supplier in applying
other markings to the devices.
Y. Cornering Lamps
Cornering lamps are steadily burning lamps used when the turn signal system is
operating to supplement the headlamps by providing additional road illumination in
the direction of the turn.
Z. Driving Lamp
An auxiliary lamp or lamps that may be used to supplement the upper beam of the
regular headlamps.
AA. Passing Lamp
An auxiliary lamp or lamps that may be used to supplement the low beam of a stand-
ard headlamp system. It is not intended for winding roads or congested city areas,
-------
SAE Lighting Identification Code
Following Is a list of identifying codes for lights and signaling devices:
SAE Identification
Device Code Designation
Reflex Reflectors:
Class A A
Class B (used prior to 1969 only) B
Turn Signal Lamps:
Class A I
Class B D
Side Turn Signal Lamps E
Fog Lamps F
Headlamp Housing H
Cornering Lamps K
License Plate Lamps L
Motorcycle Headlamps (Motorcycle Type) M
Motorcycle Headlamps (Motor Driven Cycles) N
Spot Lamps 0
Identification or Parking Lamps P
Clearance or Side Marker Lamps PI
Combination Clearance and Side Marker Lamps PC
Turn Signal Operating Units:
Class A Q
Class B QB
Vehicle Hazard Warning Signal Operating Unit QC
Back Up Lamp8 R
Stop Lamps S
Tail Lamps T
Liquid Burning Emergency Flares V
Warning Lamps, Emergency and Service Vehicles Wl
Warning Lamps School Buses W2
Warning Lamps 360 Degree Emergency W3
Emergency Electric Lanterns X
Driving Lamps Y
Passing Lamps Z
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SECTION V
VEHICLE GLAZING
Automotive safety glazing is marked with the manufacturer's trademark and the
letters "AS" followed by a number from 1 through 11. Only AS1 (or AS10 - Bullet
Resistant) may be used in the windshield. Safety glazing for 1966 and later models
also has a glass manufacturer's model number or a DOT code number.
See Figure 16 for position numbers, discoloration areas, and markings.
Procedure
Equipment
Reject Vehicle
A. Proper Markings - Inspect
A. If improper or unmarked glaz-
glass for proper markings
ing materials are used for
specific positions
Nontransparent materials
such as plywood, etc., are
used to replace glass
B. Left Front Window - In-
B. If window at driver's left
spect operation of window
cannot be readily opened to
at driver's left; window
permit arm signals
must open readily even
though vehicle has ap-
proved turn signals
C. Stickers, Tinting - Wind-
C. If glazed surfaces contain
shield and other glass
any stickers not permitted
shall be clear of posters,
by law or regulation
stickers, or other non-
transparent materials ex-
Unauthorized tinting or non-
cept as allowed by law or
transparent material has
identification decals or
been used
stickers used for admis-
sion to or parking in re-
stricted areas; these
should not interfere with
driver's vision and if
placed on the windshield,
must be in lower righthand
corner or on top of wind-
shield behind the rear
view mirror if vehicle is
so equipped
-------
POSITIONS
MARKINGS
**
1 WINDSHIELD
AS1 or 10*
AS1, 2, 10*, or 11'
AS1, 2, 10*, or 11'
REAR SIDE 2 DR.SEDAN 6 REARQUARTER 7 REAR SIDE
l S«e
AS1, 2, 10*, or 11*
On soft top convertibles
only AS1, 2, 4, 6, 10*,
or 11*
8 REAR
REMARKS:
1-2-3 - Discoloration permitted as shaded diagram indicates.
1 - Star chips (stone nicks) larger than 1-1/2 inches in
diameter at any location in the unshaded portion of
the diagram should not be permitted.
1-2-3 - Any crack or separation that allows one piece of glass
to be moved should not be permitted.
8 - Vision must be clear at least 200 feet to rear of vehicle,
*Glazing marked AS10 or ASH has bullet resisting qualities.
**Acceptable "AS" numbers in accordance with ANSI Glazing Standard
Z26.1 - 1966.
Figure 16
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Procedure
Equipment
Reject Vehicle
D. Cracks, Chips, or Discol-
oration - Inspect wind-
shield and all windows
for hazardous cracks,
chips, sharp edges, and
discoloration of glazing
D. If windshield has cracks or
breaks which interfere with
driver's vision, if cracked
or broken in line with
driver's vision, it taust be
replaced.
If there is a crack longer
than 3 inches in the wind-
shield wiper arc on the
driver's side
If there is one "star" lar-
ger than 1 inch in diameter
located in the area covered
by the windshield wiper on
the driver's side
If there are three or more
"stars" larger than 1 inch
in diameter located in any
area of the windshield, or
any "star" larger than 3
inches in diameter located
in any area of the windshield
(excluding the area where
cloudiness is permitted)
If there are two or more
cracks originating from the
same or different points,
two or more of which extend
more than 8 inches in length
each
If there is cloudiness ex-
tending more than 1 inch from
the top edge or extending
more than 1 inch from the
edge on the passenger's side,
or more than 1 inch from the
edge on the driver's side,
or more than 3 inches from
the bottom edge (tinting of
approved tinted type safety
class is not considered as
"cloudiness")
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SECTION VI
BODY AND SHEET METAL
Body components and sheet metal are subject to rejections if a condition exists
which is hazardous to occupants, pedestrians, or other vehicles.
All vehicles manufactured after January 1, 1968, were equipped at the factory with
a left-hand exterior rearview mirror. Rejections below marked with an asterisk (*)
apply only to these vehicles.
Procedure
Equipment
Reject Vehicle
A. Exterior Rearview Mirror -
A. If mirror is loose enough
From the driver's position,
that rear vision could be
visually inspect exterior
impaired
mirror on driver's side for
a clear and reasonably un-
*If mirror is obscured by a
obstructed view to the rear;
pillar or unwiped portion of
look for correct location,
windshield
stable mounting, cracks,
sharp edges, unnecessary
*If mirror is mounted so that
protrusion, and ease of
it cannot be adjusted from
adjustment
driver's seated position
If mirror is cracked, pitted,
or clouded to the extent
that rear vision is obscured
B. Interior Rearview Mirror -
B. If mirror is loosely mounted
From the driver's position,
visually inspect interior
If forward vision is unsafely
mirror for proper mounting,
obstructed by mirror assembly
location, cracks, sharp
edges, and ease of
If mirror does not provide a
adjustment
clear view of highway at
least 200 feet to rear
If mirror is cracked, broken,
has sharp edges, or cannot be
cleaned, such that rear vi-
sion is obscured
If mirror is very difficult
to adjust or will not main-
tain a set adjustment
-------
Procedure
Equipment
Reject Vehicle
Body exterior components and sheet metal parts if damaged and/or dislocated so that
they project from the vehicle to present a safety hazard to occupants, pedestrians
or other vehicles, may be cause for rejection of the vehicle.
C. Ptofctudlnfi Metal - Inspect
for torn metal parts,
moldings, etc., which may
protrude from vehicle
D. Bumpers - Inspect bumpers
for hazardous condition
or unsafe mounting
E. Fenders - Inspect for re-
moval of front or rear
fenders
F. Doors - Inspect door
latches, locks, hinges,
and handles for proper
operation, fastening, bad
adjustment, or broken or
missing components (try
doors and locks)
G. Hood - Open hood and in-
spect safety catch for
proper operation; close
hood and inspect for
proper full closure; man-
ually inspect latch or
remote control for proper
operation
H. Floor Pan - Inspect floor
pan in both occupant com-
partment and trunk for
rusted-out areas or holes
which could permit entry
of exhaust gases, or
which would not support
occupants adequately
C. If torn metal, glass, or
other loose or dislocated
parts protrude from surface
of vehicle causing a safety
hazard to pedestrians or
cyclists
D. If bumper is badly misplaced,
loosely attached, or a
broken or torn portion is
protruding, creating a hazard
E. If any fender has been
removed
F. If doors or door parts are
missing, broken, or sagging
so that door cannot be
tightly closed
G. If hood latch does not se-
curely "hold hood in its
proper fully closed position
If secondary or safety catch
does not function properly
If latch release mechanism
or its parts are broken,
missing, or badly adjusted
so that hood cannot be
opened and closed properly
H. If floor pan (front and/or
rear) is rusted through suf-
ficiently to cause a hazard
to an occupant, or so that
exhaust gases could enter
either occupant compartment
or trunk
-------
Procedure
Equipment
Reject Vehicle
I. Seats and Seat Belts -
I. If all seat anchor bolts are
Inspect seats for proper
not securely fastened to
operation of adjusting
floor or are missing
mechanism and to see that
seats are securely an-
If seat adjusting mechanism
chored to floor pan; in-
slips out of set position
spect seat belts for
frayed, split, or torn
If belt buckles do not
webbing, malfunctioning
operate
buckles, or loose or dam-
aged anchorages or floor
pan
WINDSHIELD WIPERS - U.S. vehicles produced
with wiper systems capable of operating at
consist of blade movement from one extreme
return.
J. Windshield Wipers - In-
spect for satisfactory
operation (if vacuum
operated, engine must be
idling and control full
on); windshield must be
free of bugs, oil film,
or other foreign matter,
and must be continuously
wet when tested
Inspect for damaged, torn,
or hardened rubber ele-
ments of blades
Inspect for damaged metal
parts of wiper blades or
arms
K. Sun Visors - Inspect sun
visors for broken, bent,
or loose parts which pre-
vent the visors from
being positioned, or for
visors which will not
stay in a set position
after January 1, 1968, must be equipped
two or more speeds. A "cycle" shall
of the wiper pattern to the other and
J. If wipers do' not operate at
a minimum speed of 45 cycles
per minute
If vehicles produced after
Jan. 1, 1968 do not have two
or more speed systems
If blades smear or severely
streak windshield after 5
cycles
If blades show signs of phy-
sical breakdown of rubber
wiping element
If parts of blades or arms
are missing or are damaged
K. If driver visor is missing
or will not stay in a set
position
-------
Procedure
Equipment
Reject Vehicle
WINDSHIELD DEFROSTER - It is very important that the defroster be given a minimum
check as shown. Vehicles produced after January 1, 1968, must be equipped with
windshield defroster systems.
L. Windshield Defroster -
L. If defroster fan fails to
Turn on windshield de-
function
froster fan switch to
"high" blower speed and
If fan functions but a
inspect for heated air
stream of air cannot be
blowing over inside of
"felt" blowing against
windshield, covering
proper area of windshield
areas directly in front
of driver and front seat
passenger (engine must be
warm and all elements of
defroster system must be
"on")
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SECTION VII
EXHAUST AND FUEL SYSTEM
The exhaust system includes the piping leading from the flange of the exhaust mani-
fold to and including the mufflers, resonators, and the tail piping.
Procedure
A. Exhaust System - Visually
examine mufflers, reson-
ators, tail pipes, ex-
haust .pipes, and support-
ing hardware while vehi-
cle is on a hoist or over
a pit; check muffler for
leakage by momentarily
restricting flow at tail
pipe; rusted or corroded
surfaces should be given
particular attention
(holes in system made by
manufacturer for drainage
are not cause for rejec-
tion); all gasoline pow-
ered vehicles manufac-
tured in the U.S. after
July 1, 1965 and all
other motor vehicles
equipped with crankcase
ver.tilat'on systems shall
be inspected for proper
operation
Reject Vehicle
A. If vehicle has no muffler
If there are loose or leak-
ing joints
If there are holes, leaking
seams, or patches on muffler
If tail pipe end is pinched
If elements of system are
not securely fastened
If there is a muffler cutout
or similar device that allows
excessive noise or emits a
higher noise level than
original equipment
If any part of system passes
through occupant compartment
If crankcase ventilating
system is missing or inop-
erative
If exhaust gases are dis-
charged in area between
ground and outer body lines
If flexible tubing is used
other than original equipment
or a replacement equal to
The fuel system includes the fuel tank, fuel pump, and necessary piping to carry
the fuel from the tank to the .carburetor.
-------
Procedure
Equipment
Reject Vehicle
B. Fuel System - Visually
B. If any part of the system is
examine fuel tank, fuel
not securely fastened
tank support straps, fil-
ler tube (rubber, plastic,
If there is fuel leakage at
metal), tube clamps, fuel
any point in the system
tank vent hoses or tubes,
filler housing drain,
If fuel tank filler cap is
overflow tubes, and filler
missing
cap
If there is physical damage
caused by aging
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APPENDIX C
-------
APPENDIX C
INSPECTION TASK TIME ANALYSIS
The following inspection time estimates are based on the results
of inspection lane observation, discussions with lane operators
and equipment manufacturers, time-motion studies, and analysis
of existing documents and previous studies. Thus, the time
estimates represent the consensus of several inputs. Listed
below is a typical sequence of inspection tasks, not all of
which would be performed because of the various options avail-
able.
o Vehicle Receiving Function
Check vehicle registration data
Check license plates
10 seconds
10
20
o Brakes — Dynamic Road Test
Enter vehicle, drive to road test area
Accelerate, hold at 20 mph
Perform brake test
Check brake travel and reserve
Check failure indicator and pedal effort
Stop engine and check power assist
Restart engine, check emergency brake
Release brake, advance to lift
10 seconds
10
10
5
5
5
5
5
-------
e Brakes — Dynamic Roller Test
Enter vehicle, advance front wheel over rolls 10 seconds
Start rollers, test front brakes 30
Stop rollers, advance vehicle 5
Start rollers, test rear brakes 30
Check brake travel and reserve 5
Stop engine, check power assist 5
Restart engine, check emergency brake 5
Advance vehicle 10
100
© Brakes — Dynamic Platform Test
Enter vehicle, advance vehicle 10 seconds
Apply brakes upon approaching platform 2
Note front and rear recordings 2
Advance vehicle to next test area 10
Check brake travel and reserve 5
Stop engine, check power assist 5
Restart engine, check emergency 5
Advance vehicle _10
49
o Brakes — Static Inspection
Advance vehicle over lift 10 seconds
Raise vehicle or specific front wheel 5
Remove wheel and drum 30
Inspect drum, note wear 3
Inspect lining or disc pad 3
Inspect wheel cylinder 3
Check brake lines and fittings 5
Replace wheel and drum, adjust wheel bearing _30
89
Remove rear wheel and drum 45 seconds
Inspect same as front brakes 15
Replace rear wheel and drum _30
90
-------
© Headlight Alignment
Position headlight tester 10 seconds
Check headlight alignment and operation 15
Remove tester, position on other lamp 15
Check headlight alignment and operation 15
Remove headlight tester _5
50
o Lighting and Electrical
Check taillights illuminated 3 seconds
Check turn signals, parking lights 3
Check flasher operation 2
Check brake lights 2
Check back-up lights,; license lights 3
Check horn _2,
'15 !
e Glazing
Check windshield 3 seconds
Check windshield operation 3
Check rear view mirrors __3
9
e Exterior Body
Check bumpers and fenders 5 seconds
Check doors and locks 5
Check side and rear reflector lenses __5
15 seconds
e Engine Compartment
Unlatch hood, check safety release, open 5 seconds
Check belts, water and heater hoses, clamps 3
Check power steering fluid, hoses 3
Check brake master cylinder, lines, fittings 3
Check steering column 2
Close hood _2
18
-------
o Steering System — Interior
Enter vehicle, note steering wheel diameter 2 seconds
Pick arbitrary wheel point, turn wheel from
stop-to-stop 3
Check for excessive lash or free play 3
Check for jamming or binding __3
11
0 Steering System — Exterior
Advance vehicle over lift 5 seconds
Raise vehicle to load ball joint 5
Grasp front tire, check linkage play 3
Check ball joint seals 3
Check stabiliser bars 3
Check front shocks for leakage, worn bushings 3
Check radius rods for damage 3
Lower vehicle __5
30
« Exhaust System, Brake Lines, Fuel Lines
Enter vehicle, start engine 5 seconds
Check muffler for loudness 2
Advance over lift 3
Raise vehicle 5
Check muffler, resonator, pipes, clamps 15
Check brake lines and fittings 5
Check fuel lines and fittings 5
Lower vehicles 5
45
-------
© Tires and Wheels Assemblies
While vehicle on lift, check tires for:
Match, correct size 5 seconds
Tread depth 5
General conditions 5
Check wheel assemblies for:
Retention or mounting 30
Runout or deformation each wheel 30
Check alignment on scuff gauge __3
78
o Vehicle Certification Function
Complete inspection form 60 seconds
Inform owner of deficiencies if any 10
Remove old sticker 10
Affix new sticker _5
85
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APPENDIX D
-------
APPENDIX D
RECOMMENDED safety inspection equipment list
The following list was developed as a result of an evaluation
and analysis of the Colorado inspection standards and other
reports on vehicle safety inspection. This contracted study
with the Colorado Motor Vehicle Division is documented in
"Motor Vehicle Safety Inspection Program Study" prepared by
Olson Laboratories, Jnc., dated 15 November 1972.
A station must have the following
equipment and tools to qualify for
a state permit:
Aimer, headlamp, photo-optical
Air chuck
Air compressor
Air hose
Ballpoint pen
Blow gun
Brake bleeding equipment
Brake cylinder hone set
Clamps, brake cylinder, hydraulic (6)
Cold chisels
Creeper
Cutter, diagonal
Cutter, tubing
Dial indicator, w/swivel and stand
Drop light
Electric drill w/bits
-------
Equipment and Tools List (Continued)
Floor stands (4)
Grease gun
Gauge, scuff, drives-over
Gauge, pedal pressure
Gauge, tire pressure
Gauge, tire tread depth
Hammer, 2-pound
Hammer, 8-ounce
Hammer, rubber
Jack, heavy duty
or tvfo-ton, floor
or chassis lift
Light tester or volt-ohm meter
Micrometer, brake drum
Parts cleaning facilities
Pliers, brake spring
Pliers, vise grip
Screwdrivers, Phillips set
Screwdrivers, slot set
Soldering iron
Socket set, 1/2" drive, 7/16
to 1-1/4
Spreader fork, drag link and
shock arm
Steel tape
Stop watch
Vise, bench, 4-1/2" jaw
Wheel puller
Wire brush
Workbench
Wrenches, brake adjusting
Wrenches, Allen set
-------
APPENDIX E
PROGRAM COST SUMMARY FOR VEHICLE
-------
APPENDIX E
PROGRAM COST SUMMARY FOR VEHICLE
EMISSION INSPECTION
The following cost data were extracted from the State of
Colorado, Department of Health study, "Vehicle Emission
Inspection and Control Program," as prepared by Olson Labora-
tories. . For details relative to the cost model, cost elements,
data inputs, assumptions and conditions of the total study,
the reader should refer to the cited reference (Ref. 5).
Table E-l. FACILITIES
Region
Alternatives
Privately
Operated
State Operated3
Idle
Key Mode
Idle
Key
Mode
I
59
78
3F
5M
8F
3M
II
316
418
35F
3M
42F
3M
III
20
25
3M
4M
IV
95
128
9F
3M
11F
4M
V
11
12
2M
2M
VI
11
13
2M
2M
VII
40
53
IF
4M
2F
4M
VIII
9
10
1M
2M
Total
561
737
48F
23M
63F
34M
aF for fixed facility.
M for mobile unit.
-------
Table E-2. PERSONNEL
Description
State
Privately Operated
State
Operated
Salary
Idle
Key Mode
Idle
Key Mode
Program Manager
$19,800
1
1
1
1
Regional Manager, Safety
Supervisor
14,800
3
3
4
4
Executive Secretary
8,800
1
1
1
1
Clerk/Secretary
6, 800
8
8
10
10
Public Relations Specialist
14,100
1
1
1
1
Training and Certification
Specialist
14,100
1
1
1
1
Technical Support
Specialist
14,800
3
3
3
3
Instructor
11,200
0
0
1
1
Facility Compliance
11,200
22
30
4
4
Instrumentation Technician
9, 300
2
3
6
6
Lead Test Technician
9,300
0
0
71
87
Facility Supervisor
9,300
0
0
4
5
Test Technician
6, 200
0
0
71
87
Clerk/Data Recorder
5, 200
8
11
6
-------
Table E-3. INITIAL INVESTMENT
W
I
Major Costs
Privately Operated
State
Operated
Idle
Key Mode
Idle
Key Mode
"Site Acquisition
$ -0-
$ -0-
$
382,156
$ 425,728
Facility Construction
-0-
-0-
787,992
1,326,620
Inspection Equipment
6,997,914
14,793,064
797,666
1,308,663
Facility Certification
75,125
99,934
29,621
30,655
Personnel Training
22,137
27,603
66,122
131,564
Administrative Support
200,741
222,641
108,177
109,665
Total
$7, 295,915
$15,143,241
$2,
171, 734
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Table E-4. ANNUAL OPERATION
Major Costs
Privately Operated
State
Operated
Idle
Key Mode
Idle
Key Mode
Inspection Personnel
$ -0-
$ -0-
$1,291,381
$1,562,060
Station Administrative
Personnel
-0-
-0-
74,214
141,592
Inspection Equipment
Maintenance
699,791
1,479,303
79,766
130,866
Supplies and Equipment
1,902,570
3,195,917
203,392
296,174
Facility Maintenance
-0-
-0-
77,510
89,232
Facility Recertification
82,466
120,072
10,785
11,819
Personnel Training
3, 677
4, 771
12,992
26,467
Program Administration
Support
647,932
784,131
427,881
433,592
Supplies and Equipment
-0-
-0-
9, 600
12,600
Depreciation and Planned
Expansion
-0-
-0-
38,650
65,331
Total
$3,336,434
$5,584,193
$2,226,068
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APPENDIX F
INTEGRATED SAFETY-EMISSIONS
-------
APPENDIX F
INTEGRATED SAFETY-EMISSIONS
PROGRAM COST
The following cost analysis derives and uses the information,
data, and cost estimates recorded in two studies performed
for the State of Colorado that were completed in 1972. The
"Vehicle Emission Inspection and Control Program" study was
contracted with the Department of Health, Air Pollution Control
Division, and the ''Motor Vehicle Safety Inspection Program"
study was contracted with the Department of Revenue, Motor
Vehicle Division.
F.l STATE OPERATED EMISSIONS — SAFETY INSPECTION FACILITY
Assumptions:
e Idle emissions inspection only
© Safety-related inspection only
e No on-line station adjustments, repair, service
o Estimated vehicle throughput — 15 minutes
o Estimated lane output — one vehicle every 5
minutes
9 Automated data retrieval and processing
e Lane capacity — 12 vehicles per hour maximum
-------
• Facility capacity — minimum of two lanes, maximum
of four lanes, per State site
o Lane efficiency — 60 percent (accounting for
equipment downtime, vehicle scheduling)
9 Inspection period — open 8 working hours per
day, 5 days per week, 50 weeks per year
e Expected lane capacity — 14,400 vehicles per year
„ vehicles ... „ hours .. n days weeks\
0.6112 —r— x 8 -—z x 5 x 50
y hour day week year J
F.l.l Lanes Required
If an annual inspection is used then capability must be pro-
vided for 1.69 million vehicles. However, if twice-a-year
inspection is anticipated, then capability must be 3.38 mil-
lion vehicles. These figures are derived from the.following
calculation:
C.
1.3 million vehicles + 30 percent retests = (1.3) (1.3) (10 )
= (1.69)(10^) vehicles
The number of inspection lanes required then would be:
... 1,690,000 ,
Once-a-year inspection, 14 400 = lanes
_ • _ . • 3,380,000 ,
Twice-a-year inspection, 14 400 = lanes
The number of lanes required may be decreased by scheduling
longer operating hours (e.g., 12 hours instead of 8 hours)
and also by remaining open more days per week (e.g., 6 or 7
days per week instead of 5 days). These alternatives may be
-------
considered in the future because a complex trade off is involved
including investment costs for buildings, sites, and equipment;
versus operating costs for inspection personnel, building up-
keep, and equipment utilization; versus the time, distance
traveled, and other convenience factors of the motorist. These
considerations would be far beyond the contracted scope of
this study.
F.1.2 Facility and Site Requirements
In order to service the entire State, 66 fixed-site facilities
and 23 mobile units will be required (see Table F-l). Each
fixed site will consist of a double-lane configuration with
sufficient acreage for a building, traffic control, and staff
parking. Each mobile unit will be completely equipped for
safety and emissions testing plus data recording and adminis-
trative functions. A mobile unit is equivalent to a single-
lane configuration.
Table F-l. FACILITY AND SITE REQUIREMENTS
Region
Fixed
Mobile
Facility
Unit
I
4
5
II
48
3
III
1
3
IV
12
3
V
0
2
VI
0
2
VII
1
4
VIII
0
1
Total
66
23
-------
The calculated facility capacity is:
Fixed Site = (66)(2) = 132 lanes equivalent
Mobile Units = (23)(1) = 23 lanes equivalent
155 lanes
Each lane = 14,400 vehicles per year
Then total capacity = 14,400 x 155 = 2,232,000 vehicles.
Recall previously that capacity was estimated at 60 percent
efficiency. Consequently, the theoretical maximum would be
3.7 million vehicles per year, or sufficient facilities to
provide twice-a-year inspection with 30 percent reinspection.
F.1.3 Site Acquisition and Facility Construction
9 Each site has acreage of 15,000 square feet.
Site acquisition = $1 per square foot
Site preparation = $1 per square foot
Total cost = $2 per square foot
(66 sites)(15,000 sq.ft.)($2) = $1,980,000
® Each facility has 4,000 square feet.
Facility construction = $12 per square foot
Total cost = (66) (4,000) ($12) = $3,168,000
F.1.4 Inspection Equipment
Each two-lane configuration includes all of the equipment
needed to perform vehicle safety inspections (see Appendix D),
vehicle Idle emission testing, and data processing.
-------
® Two lane configuration = $54,270 installed.
(66 sites) ($54, 270) = $3, 581,985
q One mobile unit = $80,000
(23 units) ($80,000) = $1,840,000
© Total equipment cost = $3,581,995 + $1,840,000
= $5,421,985
F.1.5 Facility Certification
» One day per facility involving one team of two
certifiers
a Travel time between facilities = 1 day
« Per diem on travel status = $25 per da}
e Recertification quarterly
e Initial certification
(66 sites)(1 day) = 66 days
(23 mobile units)(1 day) = 23 days
66 work days = 14 weeks = 28 man weeks
= 196 travel days
23 days for mobile units
= no travel charges, unit tested at "home"
Per diem = (196) ($25) = $4,900
One certification van = $15,000
Total certification cost = $19,900
One-half of a man year = $5,000
® Recertification quarterly
Per diem cost = $4,900
Equipment cost = $500
-------
Van upkeep = 10,000 miles x 0.12
Quarterly cost - $6,600
Annual cost = $26,400
= $1,200
F.1.6 Initial Training Personnel
e Two lane configuration
Receiving inspector
Lane inspectors
Certification inspector
Supervisor
Administration
1
6
1
1
1
Total
10
«» Mobile unit — two inspectors
® Training periods — 80 hours, 10 working days
® Manpower expended
(66) (10) + (23) (2) = 660 + 46 = 706 inspectors
(706)(10 days) = 7,060 man days
o Technician pay range — $6,200 to $9,300
Assume average of $8,000 per year
Fringe benefits of 30 percent
Typical technican cost = (1.3) ($8,000) = $10,400
per year
Man days per year = 260
® Training cost = "^260^ X = $282,400
-------
F.1.7 On-Going Training
• Assume 20 percent annual turnover
© New training of replacements = (0.25) ($282,400)
e Annual training = $70,600
F.1.8 Program Administration
Table F-2 gives a breakdown of the costs for administra 1 ->n of
the program.
Table F-2. PROGRAM ADMINISTRATION COSTS
Salary
Cost
Program Manager
$19,800
$
19,800
Regional Manager
14,800
59,200
Public Relations
14,100
14,100
Training and Certification
14,100
14,100
Technical Support
14,800
44,400
Training Instructor
11,200
11,200
Certification Inspectors
11,200
33,600
Instrumentation Technician
9,300
55,800
General Clerks/Secretary
6,800
476,000
Executive Secretary
8, 800
44,000
Total Annual Salary
$
772,200
Fringe Benefit 30 percent
231,700
Total Annual Cost
$1.
003,900
-------
F.1.9 Initial Investment Costs
Table F-3 shows the initial investment required to set up a
test facility.
Table F-3. INITIAL INVESTMENT COSTS
Site Acquisition
$ 1,980,000
Facility Construction
3,168,000
Inspection Equipment
5,422,000
Facility Certification
24,900
Personnel Training, Initial
282,400
Administrative Support
165,700
Total
$11,043,000
F.1.10 Annual Operating Costs
Annual operating costs are shown in Table F-4.
Table F-4. ANNUAL OPERATING COSTS
Inspection Personnel — (706) ($10,400)
Inspection Equipment Maintenance
Supplies and Depreciation
Facility Maintenance
Facility Recertification
Personnel Training
Program Administration Support
Facility Depreciation and Expansion
$
7,342,400.
813,300
406,600
26,400
26,400
70,600
1,003,900
158,400
Total
$
9,848,000
Annual amortization of $11 million
at 6 percent per year over 20 years
959,000
Total costs per year
$10,807,000
Allocated cost per vehicle per year
$8.30
-------
F. 2
PRIVATELY-OPERATED EMISSIONS-SAFETY INSPECTION FACILITY
Assumptions:
e Licensed stations currently exist to perform safety
inspections
e Same stations will be licensed for Idle emissions
inspections
a Vehicle emissions adjustments, service and repairs
performed by mechanic of owner's choice
e Manual data recording and reporting to state
Program Office
9 Equipment available and operating on demand
® Inspection personnel available for testing vehicle
without job interruption
• Inspectors receive same training as state inspec-.
tors — 80 working hours paid by station operator
a Existing labor rate is $10 per hour; $5 to inspec-
tor, $5 to station operator
F.2.1 Emission Equipment
Each station will purchase an HC/CO gas analyzer at $2,500.
Equipment for data processing is negligible. Emission tune-up
and servicing equipment normally are available in facilities.
No additional units are recommended. Thus, the equipment
required is only for exhaust analyzers.
-------
The initial cost of $2,500 is amortized over 5 years at 6 per-
cent, yielding an annual payment of $590. Assume an annual
maintenance cost equal to 8 percent of equipment cost, or
$200. Then the annual ownership cost is $790.
A station is assumed to remain open 10 hours per day, 6 days
per week, 50 weeks per year. This is equivalent to 3,000
operating hours. It is recognized that the equipment will not
be utilized full time. However, for analytical purposes, the
allocated operating cost increases, by $790/3,000 = $0.26 per
hour for adding the emission inspection equipment.
F.2.2 Inspection Personnel
It was assumed in the State-operated alternative that each
inspector receives 80 hours of training. Each facility would
be required to have two technicians who are qualified for emis-
sion inspection. The direct labor charge is $5 per hour.
Fringe benefits are assumed to equal 30 percent, as in the
State-operated alternative. Thus the cost for training is:
(1.3) ($5.00) = $6.50 per hour.
o Two men at 80 hours each = 160 man hours
• Total training cost to operator = (160)($6.50)
= $1,040
Assuming that a technician remains with the initial station
an average of 3 years, then the total hours per technician is
(40) (50) = 2,000 hours per year, or 6,000 hours total. For
two technicians, this is equivalent to 12,000 hours. Then the
allocated cost to the stations is:
12!000 = $0*09 Per hour-
-------
F.2.3
Labor Rate for Emission Inspection
Assuming that the current labor rate for vehicle tune-ups is
$10 per hour, and considering a pay-scale escalation of
5.5 percent annually, then by 1975, the new labor rate would
be (1.05)2($10) = $11.13 per hour. By adding emission equip-
ment and training, the labor rate becomes in 1975:
$11.13 + 0.26 + 0.09 = $11.48 per hour.
F.2.4 Estimated Safety-Emissions Inspection Charges
From Appendix C and the Vehicle Emission Inspection study, the
inspection task times shown in Table F-5 are derived.
Table F-5. INSPECTION TASK TIMES
Task
Time
(minutes)
Vehicle registration check
1.5
Vehicle preparation
1.5
Vehicle safety inspection
9.0
Vehicle emission testing
5.0
Inspection data recording
2.0
Certification and results analysis
2.0
Total
21.0
Non-functional time (vehicle movement
into, out of station)
2.0
Total
23.0
Using the estimated 1975 labor rate of $11.50 per hour, the
safety-emissions inspection charge would be:
$11.50 =* $4.40 per visit.
-------
This charge does not include State management expenses, such
as the $0.25 sticker price currently charged.
F.2.5 State Program Management Expenses
The personnel necessary to administer the program are shown
in Table E-6.
Table E-6. PROGRAM ADMINISTRATION PERSONNEL
Title
Annual
Salary
Cost
Program Manager
$19, 800
$
19,800
Regional Manager
14,800
118,400
Public Relations
14,100
28,200
Training and Certification
14,100
14,100
Technical Support
14,800
44,400
Training Instructor
11,200
22,400
Certification Inspectors*
11,200
795,200
Instrumentation Specialist
9,300
158,100
General Clerks/Secretaries
6,800
54,400
Executive Secretary
8,800
70,400
Total Annual Cost
$1
,325,400
Fringe Benefits — 30 percent
397,600
Total Program Cost
$1
,723,000
~Certification inspectors:
• 4,200 stations inspected every quarter
• 65 working days per quarter
• 65 stations per day certified
-------
• Each certification team inspects two statioa^
per day
• Require 34 teams of 2 members each, or 68 inspec-
tors
• Add 5 percent for absentees, or 71 inspectors
required
A total of 1.3 million passenger vehicles are registered in
the State. The annual allocated cost per registered vehicle
then would be $1,723,000/1.3 million vehicles = $1.33 per
vehicle per year.
F.2.6 Estimated Vehicle Inspection Fee
• For annual inspection,
$4.40 + 1.33 = $5.73 per visit
• For semi-annual inspection,
$4.40 + 0.67 = $5.07 per visit
The above charges by the privately-operated inspection station
includes a labor charge of $4.40 per inspection plus the sticker
charge of either $1.33 for annual inspection or $.67 for twice-
a-year inspection.
-------
APPENDIX G
EPA ADVISORY CIRCULAR ON
-------
oru Muvisory circular
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR PROGRAMS • MOBILE SOURCE POLLUTION CONTROL PROGRAM
A/C No. 16
June 8i 1972
Page 1 of 3 pages
Subject: Approval of Emission Control Modifications for High
Altitudes on New Motor Vehicles or Engines
A. Purpose
The purpose of this Advisory Circular is to explain the
procedure whereby EPA will approve requests from manufacturers to
modify new motor vehicles or engines to reduce emission levels at
high altitudes.
B. Background
1. Recent studies have shown that emission-controlled
vehicles and engines emit higher levels of pollutants at high
altitudes than those same vehicles emit at low altitudes.
2. Tn TTianv pmi c 3 ion 5 O Z C£Tt. i VShliclsS SLTld.
engines at higher altitudes can be significantly reduced through
the use of modified calibrations in the fuel induction and ignition
systems. However, the provisions of Section 203(a)(1) of the
Clean Air Act make it a prohibited act for a manufacturer to
distribute in commerce, sell, or offer for sale; or introduce, or
deliver for introduction, into commerce; or import into the
United States any new motor vehicle or motor vehicle engine unless
the vehicle or engine is covered by a certificate of conformity.
Thus, if a light duty vehicle or heavy duty engine manufacturer
wished to modify the certified production vehicle or engine, in
terms of any of the parameters listed in 40 CFR 85.89(a)(3),
40 CFR 85.89(b)(3), or 40 CFR 85.310(b)(3), the manufacturer would
need to receive a determination from the Administrator that the
vehicle would still be covered by the certificate of conformity
then in effect.
3. If the vehicle has already been sold to an ultimate
purchaser, Section 203(a)(3) of the Clean Air Act prohibits any
manufacturer or dealer knowingly t:o remove or render inoperative
any control device or element of design installed on or in the
vehicle in compliance with regulations under Section 202 of the
Act. Thus, manufacturers and dealers who modify the emission
control system "to reduce emission levels at high altitudes must
first obtain a determination from the Administrator of EPA that
such modification would not "render inoperative" the control
system.
-------
ENVIHONMENTALPfiOTECTlON AGENCY o OFFICE OF-AIR PROGRAMS A/C NO. PAGE —— GF
4. EPA encourages manufacturers to pTOvide the vehicle owner
an opportunity to have his vehicle modified so as to lower emission
levels at high altitudes. This Advisory Circular explains the
procedure for approving such modifications.
C. Applicability
The procedure described in this Advisory Circular covers
requests from manufacturers to modify the emission control system
of current model year production vehicles or engines which are
intended for sale at high altitudes. Special carburetor calibra-
tions and ignition timing changes would be examples of changes
covered by the procedures described in this Advisory Circular.
Upon obtaining EPA approval of the modification on production
vehicles or engines, the manufacturers and dealers would be allowed
to provide for the performance of these modifications.as field
fixes on current model year vehicles in the hands of the ultimate
purchaser^ as set forth in Advisory Circular No. 2.
D. Procedure
1. Requests for emission control modifications for use in
high altitudes shall be submitted in accordance with 40 CFR
85.58. The testing to be required on high altitude modifications,
in accordance with 40 CFR 85.58(b) is the following:
a. Fifty thousand mile Durability and four thousand
mile Emission Data vehicles shall be run in those cases where the
modification changes the engine - system combination of the certi-
fied vehicle or engine. Emission Data vehicles alone shall be run
in those cases where the modification does not alter the configura-
tion of the engine-system combination of the certified vehicle or
engine. An example of a modification requiring Durability and
Emission Data vehicle testing is the addition of an air pump. An
example of a modification requiring only an Emission Data vehicle
test is an alternate calibration.
b. Vehicles or engines equipped with a high altitude
modification must be capable of demonstrating that they meet all
applicable EPA emission control standards when tested at the EPA
laboratory.
c. Manufacturers are encouraged to show, e.g. by
results of tests conducted under high altitude conditions or by
appropriate engineering data, what the effect of the modification
is on vehicles or engines operating at high altitudes as compared
to unmodified vehicles or engines of the same engine family at
the same high altitude. Such data is useful to EPA in determining
what impact high altitude modifications have on air quality.
d. The label prescribed under 40 CFR 85.4 shall indicate
the engine tune-up specifications of the modified vehicle or engine
for the high altitude for which the vehicle or engine is intended
to be sold.
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£NVih~JNMENTAL.PROTECT ION AGENCY o OFFICE OF AIR PROGRAMS A/C NO. PAGE —— OF -2
2. A suggested format for the application and a format for
reporting data are attached to this Circular.
Eric 0. Stork
•Director
Mobile Source Pollution Control Program
Enclosure
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APPENDIX H
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
Office, of Enforcement and General Counsel
December 22, 1972
Mobile Source Enforcement Memorandum No. 1
Subject: Interim Tampering Enforcement Policy
A, Purpose
The purpose of this Memorandum is to state the interim policy of
EPA with regard to enforcement of the "tampering" prohibition -
Section 203(a)(3) - of the Clean Air Act.
1. Section 203(a)(3) of the Clean Air Act provides:
"The following acts and the causing thereof are prohibited -
"(3) for any person to remove or render inoperative
any device or element of design installed on or in
a motor vehicle or motor vehicle engine in compliance
with regulations under this title prior to its sale
and delivery to the ultimate purchaser, or for any
manufacturer or dealer knowingly to remove or render
inoperative any such device or element of design
after such sale and delivery to the ultimate purchaser."
Section 205 of the Act provides for a maximum civil penalty of $10,000
for any person who violates Section 203(a)(3).
2. This "tampering" provision of the law has created a great
deal of uncertainty, primarily among new vehicle dealers and auto-
motive aftermarket parts manufacturerst regarding what actions and/
or use of what parts are prohibited. The terms "manufacturer" and
"dealer" in §203(a)(3) refer only to motor vehicle manufacturers and
new motor vehicle dealers; however, the law impacts indirectly on
aftermarket parts manufacturers through its applicability to vehicle
dealers who are customers for their products. Other provisions in
the Act establishing manufacturer warranties and authorizing compulsory
recall of properly maintained vehicles also have a potential for anti-
competitive effects in the aftermarket.
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-2-
3. In general, it is clear that EPA's primary objective in enforcing
the statutory prohibition on "tampering" must be to assure unimpaired
emission control of motor vehicles throughout their useful life. It is
EPA's policy to attempt, to achieve this objective without imposing un-
necessary restraints on commerce in the automotive aftermarket.
The long range solution to minimizing possible anticompetitive
effects that could result from implementation of these statutory provisions
may lie in some type of certification program for at least certain
categories of aftermarket parts. EPA is currently studying the technical,
administrative and legal problems which such a program presents. EPA has
yet to develop the policy, procedures, or facilities attendant to any
long range solution.
5. In the absence of a long-term solution, and in the absence of
proof that use of non-original equipment parts will adversely affect
emissions, constraining dealers to the use of only original equipment
parts would constitute an unwarranted burden on commerce in the
automotive aftermarket, Pending development of a long range solution,
the following statement reflects EPA's interim policy in the tampering
area. This policy is intended to reduce the uncertainty which dealers
now face by providing criteria by which dealers can determine in
advance that certain of their acts do not constitute tampering.
B. Interim Policy
Unless and until otherwise stated, the Environmental Protection
Agency will not regard the following acts, when performed by a dealer,
to constitute violations of Section 203(a)(3) of the Act:
(1) Use of non-original equipment aftermarket part as
a replacement part solely for purposes of maintenance
according to the vehicle manufacturer's instructions,
or for repair or replacement of a defective or worn
out part, if the dealer has a reasonable basis for knowing
that such use will not adversely affect emissions performance;
(2) Use of non-original equipment aftermarket part or
system as an add-on, auxiliary, augmenting, or secondary
part or system, if the dealer has a reasonable basis for
knowing that such use will not adversely affect emissions
performance; and
-------
-3-
(3) Adjustments or alterations of a particular part or system
parameter, if done for purposes of maintenance or repair according
to the vehicle manufacturer's instructions, or if the dealer has
a reasonable basis for knowing that such adjustment or alteration
will not adversely affect emissions performance.
For purposes of clause (l), a reasonable basis for knowing that a
given act will not adversely affect emissions performance exists if:
(a) the dealer reasonably believes that the replacement
part is designed to perform the same function with
respect to emission control as the replaced part, or
(b) the replacement part is represented in writing by the
part manufacturer to perform the same function with
. respect to emission control as the replaced part;
For purposes of clauses (2) and (3), a reasonable basis for knowing
that a given act will not adversely affect emissions performance exists
if:
(a) the dealer knows of emissions tests which have been
performed according to testing procedures prescribed
in 40 CFR 85 3howing that the act does not cause
similar vehicles or engines to fail to meet applicable
emission standards for their useful lives (5 years or
50,000 miles in the case of light duty vehicles); or
(b) the part or system manufacturer represents in writing
that tests as described in (a) have been performed
with similar results; or
(c) a federal, state, or local environmental control.agency
expressly represents that a reasonable basis exists.
For purposes of clauses (1), (2), and (3):
(a) the permanent removal or disconnecting or blocking of
any part of the original system installed primarily for
the purpose of controlling emissions will be presumed
to affect adversely emission performance; and
(b) the prescription and appropriate publication by EPA of
an act as prohibited will be deemed conclusive that
such act will adversely affect emissions performance.
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-h-
C. Discussion
1. Clause (l) will apply to replacement parts, protecting the
dealer when he uses such a part to conduct necessary maintenance if
a person familiar with the design and function of motor vehicles and
engines would reasonably believe that such part is designed to
perform the same function as the replaced part, or if there is written
representation by the parts manufacturer that the part is so designed.
Other reasonable bases (e.g., emissions tests showing no adverse
effect) may exist, but these other bases will probably not occur often
in the replacement part context. If EPA gains information that
certain replacement parts do adversely affect emissions, a listing of
such parts will be published.
2. Clause (2) will protect the dealer who installs add-on parts
if he knows, or if it has been represented in writing to him by the
part manufacturer, that emissions tests have been performed according
to Federal procedures which show that such a part will not cause
similar vehicles to fall to meet applicable emission standards over
the useful life of the vehicle. The dealer is protected from
prosecution even if the test results have not been reported to EPA.
However, the aftermarket parts manufacturer who represents that such
tests have been conducted should have available the data from the tests,
including where, when, how and by whom the tests were conducted!should
EPA request it. Such add-on parts might be auxiliary fuel tanks, which
would require evaporative emission control on light duty vehicles to
the prescribed standard, or superchargers, which would require emission
testing showing conformance to standards over the useful life of the
vehicle or engine. Clause (2) will also protect the dealer,who installs
retrofit devices to reduce emissions at the request of a state or
local environmental control agency.
3. Clause (3) applies to dealers conducting necessary adjustments
or alterations, according to the vehicle manufacturer1s instructions,
of parts already on the vehicle, e.g., adjustment of the carburetor or
ignition timing. It also covers adjustments or alterations, as in the
case of altitude "fixes", if a "reasonable basis" exists as described
above.
U* This interim policy -applies only to dealers, and not to motor
vehicle manufacturers. Procedures exist whereby vehicle manufacturers
may acquire EPA approval of any emission-related change in the vehicle
from its certified configuration or parameters (See MSPC Advisory
Circulars No. 2-A "Field Fixes Related to Bnission Control-related
Components", November 14, 1972, and No. 16 "Approval of Einission Control
-------
-5-
Modifications for High Altitudes on New Motor Vehicles or Engines",
June 8, 1972.) Hence, if a manufacturer performs or causes to be
performed (e.g«, by providing parts and/or instructions to dealers)
any acts not approved by EPA that would constitute a change in the
certified configuration or parameters of the vehicle as represented
in the application for certification, including those acts addressed
in the interim policy, he runs the risk of violating §203(a)(3) in
the event that such act is subsequently identified as having an
adverse effect on emissions performance.
5. Any questions regarding this interim policy should be addressed
to the Mobile Source Enforcement Division, Office of Enforcement and
General Counsel,
Mobile Source Enforcement Division
Office of Enforcement and General Counsel
-------
APPENDIX I
-------
LETTERS MAILED TO FOLLOWING ADDRESSEES
Mir. Fred Bowditch
Director of Emission Control
General Motors Technical Center
Warren, Michigan 48090
Ford Motor Company
Research and Engineering Center
20000 Rotunda Drive
Dearborn, Michigan 48121
Mr. G. A. Lacy
Vehicle Emissions Control
Engineering Research Office
Chrysler Corporation
P.O. Box 1118
Detroit, Michigan 48321
American Motors Corporation
Administrative Offices
142 50 Plymouth Road
Detroit, Michigan 48232
Toyota Motor Sales, USA Inc.
2055 W. 190th Street
Torrance, California 90501
U.S. Importers, Inc.
Volkswagen of America
Englewood Cliffs, N. J.
Nissan Motors Corporation USA
18501 S. Figueroa
Gardena, California
-------
In reply refer to
0400-73-99/RDG:Is
October 22, 1973
Olson Laboratories, Inc., is currently assisting the State of Colorado,
Department of Health, in evaluating various plans to reduce and control
vehicle emissions. One of these strategies involves the installation of
additional exhaust control devices on a retrofit basis for 1968-1972
model year light-duty (under 6001 pounds GVW) vehicles.
Recent investigations by the Federal EPA have shown that vehicles
operating at high altitude cities such as Denver emit significantly
greater levels of exhaust pollutants than similar vehicles operating
at lower elevations. The Colorado Health Department is currently spon-
soring a test program to evaluate several devices and modifications
which may reduce these excessive exhaust pollutants (see enclosure for
device listing). Emission testing is being performed in accordance with
Federal test procedures by a recognized, independent laboratory located
in a suburb of Denver. The Denver regional office of the EPA is cogni-
zant of this program and is providing assistance in data analysis tasks.
Assuming these devices and/or modifications are effective in reducing
emission levels, the State would then implement a program to require
their utilization. However, the State recognizes that vehicle owner
warranties may be voided if unauthorized alterations, parts replacement,
or adjustments are attempted.
It is requested that the warranty requirements of your 1968-1972 vehicles
be reviewed to ascertain where problem areas may exist and notify us of
such. The legality of these devices and modifications is being evaluated
against the stipulations of the EPA Interim Tampering Enforcement Policy
of December 22, 1972, Thank you for your assistance.
Enclosure
-------
COLORADO HEALTH DEPARTMENT
RETROFIT DEVICES TEST PROGRAM
Emission Control Approaches
Device Manufacturer
Air bleed to intake manifold
Echlin
Air bleed to intake manifold and
exhaust gas recirculation
Dana Corporation
Carburetor float chamber pressure
regulation
Colspan
Catalytic converter
UOP
Gaseous fuel conversion
Carburetor modifications -
changes in springs, jets, air-
fuel mixture, choke setting,
removal of idle screw limiter
Ignition timing change
-------
TOYOTA
TOYOTA MOTOR SALES. USA. INC.
CABLE ADDRESS "JIDOSHA TORRANCE"
TELEPHONES.
(213) 770-1730
(213 ) 932-0010
TfeLBR 373146
2055 WEST 190TH STREET
P. O BOX 2991
Torrance, California ooso9
November 13, 1973
TMS-WAM-3072
Mr. Robert A. Gafford
Vice President, Research & Engineering
Olson Laboratories, Inc.
421 E. Cerritos Avenue
Anaheim, California 92805
Dear Mr. Gafford:
This is in reply to your letter of October 22 regarding after market emission
control devices and their effect on 1968-1972 Toyota vehicle warranty requirements.
For the most part, the majority of 1968-1972 Toyota vehicles are out of warranty.
However, for 1972 vehicles still under the new car warranty, the use of a non-
Toyota product, part or modification does not void the warranty. However, if the
use of such a product, part or modification causes failure of other Toyota com-
ponents, our warranty will not cover the replacement of those affected components.
In addition, all passenger cars from the 1972 model year are covered by a special
warranty on the emission control system. This warranty provides that the car is
free from defects in materials and workmanship at the time of sale, which would
cause the vehicle to fail to conform with applicable Federal Environmental
Protection Agency regulations for a period of five years or 50,000 miles. Due
to the fact that this warranty relates only to the condition of the vehicle at
the time of sale, it would not be directly affected by the addition of after
market devices. However, should a situation arise presenting a question as to
whether a failure to conform with applicable regulations was caused by a defect
existing at the time of sale or by the addition of an after market device, the
stipulations of the EPA Interim Tampering Enforcement Policy of December 1972
will have to be considered.
I hope this sufficiently answers your question on Toyota warranty requirements.
^£ee Sawyer
Warranty Administration Manager
LS :ak
cc: J. Parcells
R. Schrandt
-------
GENERAL MOTORS CORPORATION
November 27, 1973
Mr. Robert D. Gafford, Ph. D.
Vice President
Research and Engineering
Olson Laboratories, Inc.
421 E. Cerritos Avenue
Anaheim, California 92805
Reference: 0400-73-99/RDG:Is
Dear Mr. Gafford:
This is in response to your letter of October 22, 1973 to Dr. Fred
Bowditch, Executive Assistant to the Vice President for Vehicle Emission
Matters. He has asked that the General Motors Service Section respond
to your inquiry because of our responsibilities in the administration
of new vehicle and emission control warranties on General Motors products.
As of this time it is our policy to consider the modifications you
describe a basis for denying General Motors warranty responsibility under
the express provisions of our 1972 and subsequent model year mandatory
emission warranty. It is necessary to do so, first, because we are not
in a position to test or otherwise determine the effect all such possible
modifications would have on total vehicle emissions. Secondly, the EPA
engine certification procedure is based on the original equipment
emission systems and similar 50,000-mile testing programs would be re-
quired to determine the effectiveness of modifications. Finally, as you
have recognized, the EPA Mobile Source Enforcement Memorandum No. 1
precludes such modification by General Motors or its dealer organization.
The General Motors New Vehicle Warranty (as distinguished from the Federal
Emissions Warranty) covers only malfunctions resulting from defects in
material or workmanship in the new vehicle and any equipment or acces-
sories thereon which are manufactured or supplied by General Motors.
Accordingly, products not manufactured or supplied by General Motors are
not covered by the General Motors New Vehicle Warranty.
Any General Motors New Vehicle Warranty claim filed following modification
of emission systems would necessarily require a determination by General
Motors of whether such system adversely affected the performance and
reliability of the car or any of its components. If a malfunction
occurred as a result of a modification, then it follows that it was not
the result of a defect in material or workmanship in an item supplied by
General Motors and such malfunction would not be covered by our New
Vehicle Warranty. However, defects in material and workmanship in
General Motors parts not adversely affected by the non-General Motors
product would be handled under the General Motors New Vehicle Warranty,
-------
Mr. Robert D. Gafford, Ph. D.
November 27, 1973
Page Two
and approval of warranty claims based on the repair or replacement of
such parts would not be refused simply because a product not manu-
factured or supplied by General Motors had been installed on the
particular car.
We trust that this information will assist you in evaluating the potential
applicability of certain retrofit emission devices to past model General
Motors vehicles.
Very truly yours,
Manager, Field Service Operations
ECH:ss
-------
Ford Motor Company
Environmental and Safety
Engineering Staff
The American Road
Dearborn, Michigan 48121
December 10, 1973
Dr. Robert D. Gafford
Vice President
Research and Engineering
Olson Laboratories, Inc.
421 E. Cerritos Avenue
Anaheim, California 92805
Dear Dr. Gafford:
In reply to your letter concerning the Colorado Health
Department test program to evaluate emission control
devices and engine modifications on 1968-72 vehicles
(Ref. 0400-73-99/RDG), the Ford Motor Company cannot
at this time, give you a specific answer with regard to
the vehicle warranty requirements unless the specific
changes on the vehicles are known.
We are definitely interested in the results of the test
program and will respond promptly if you send us more
details about the modifications.
Sincerely,
v r
--W Vv - ^.
B. H. Simpson
Executive Engineer
Emissions Control Planning
-------
VOLKSWAGEN OF AMERICA, INC.
ENGLEWOOD CLIFTS, N. J. 07632
December 10, 1973
Dr. Robert D. Gafford
Vice President
Olson Laboratories, Inc.
Research and Engineering
421 E. Cerritos Avenue
Anaheim, Calif. 92805
Subject: 0400-73-99/RDG:Is -¦ Oct. 22, 1973
Dear Dr. Gafford:
The intention of Olsen Laboratories, Inc., to evaluate
various plans to reduce and control vehicle emissions,
particularly in the Colorado higher altitude area, is
commendable.
It is our opinion that the installation of modification
devices on our vehicles by your company to assist the
state of Colorado, Department of Health, would not void
the owner 1s vehicle warranty.
However, any damage or malfunction that is caused by
such installation or modification will not carry the
responsibility of the importer and will therefore not
be covered under the VW New Vehicle Warranty.
We have enclosed copies of our 1968-1972 model warranties
and hope this information will prove helpful to you.
RP:ib Technical Service Manager
enclosures
1-9
western union Telex 135-427
-------
1968 OWNER'S MANUAL
No warranties, express or implied, as to Volkswagen vehicles sold in the United States are
made either by Volkswagen of America, Inc. or by the manufacturer or by the selling dealer,
except the following warranty by Volkswagen of America, Inc.
Warranty for new Volkswagen vehicles
This warranty Is issued by Volkswagen of America, inc. ("VWoA"), the authorized United Sfdte9 Importer of Volkswagen vehicles.
Free repair or replacement
In United States and Canada
of defective parts
for 24 months or 24,000 miles
1. VWoA warr.irtts that ever/ Volkswagen vehicle impound by V'vVoA and sold as a new vehicle
to a retail customer by an authorized United States Volkswagen dealer will be free from defects in
material and workmanship under normal use and service for 24 months after the date of delivery
of tho vehicle 10 the original retail customer or until the vehicle has been driven 24,000 miles,
whichever comes first. This warranty is limited, however, to the following- If any part of the vehicle
becomes defective during this period under normal use and service and the vehicle is brought to
the workshop of any authorized Volkswagen dealer in the continental United States, Hawaii or
Canada, the dealer will, without charge, either repair the defective part or replace it with a new or
factory reconditioned part.
Maintenance and validation
by owner required to keep
warranty In effect
2. In order to keep this warranty in effect, the owner must do two things:
FIRST: The owner must have the vehicle maintained and serviced as prescribed in the Volkswagen
Maintenance Schedule. (See page 56.)
SECOND. Ever/ twelve months during tho warranty period the owner must obtain from an authori-
zed Unitf.d C:c;v>s Volkswagen dealer a Validation Stamp on tho Maintenance Card to show that
tho vehicle lu:. been maintained'and serviced in accordance with the Volkswagen Maintenance
SchcJjl'. Va J..uon will be made upon presentation of bills or other evidence sufficient to satisfy
the dealer that the required service and maintenance have been performed The validated Main-
tenance Card must be submitted whenever a claim is made under this warranty.
Items not covered by warranty
3. VWoA's warranty does not cover:
(i) Defects, damage or deterioration due to normal use, wear and tear or exposure; (ii) normal
maintenance services, such as fuel system cleaning and wheel, brake or clutch adjustments,
(iii) the replacement of service items, as, for instance, spark plugs, ignition points, V-belts, wiper
blades or brake and clutch linings; (iv) deterioration of upholstery, soft trim and appearance
items: (v) damage or defects due to misuse, alteration, negligence or accident, and (vi) damage
or defects due to tiie repair of tho vehicle by someone other than an authorized Volkswagen dealer
or the installation of parts other than genuine Volkswagen parts.
Warranty outside United States
and Canada
4. If the vehicle is brought to an authorized Volkswagen workshop outside the continental
United States, Hawaii or Canada, VWoA's warranty will not be applicable, and defective parts v.'ill
be repaired or replaced free of charge with n?w or factory roconditor.-d p.Trts onl/ v:
terms and limitations of the warranty for new Volkswagen vehicles in effect in the country
where such authorized Volkswagen workshop is located.
No other warranties made
6. This warranty is in liou of all other exprnss or implied warranties of VWoA, the
manufacturerand tho seiling dealor, including any implied warranty of merchantability
or fitness for any particular purpose. Neither VWoA nor the manufacturer assumes, or
authorizes any person to assume, on its behalf, any other obligation or liability.
Let us explain the warranty . . .
Volkswagen of America, Inc. is proud of the quality of automobiles it imports. It vyarrants new vehicles for a period of 2 years or 24,000 miles
from the date of purchase, whichever comes first. In general the complete vehicle including battery and tires is covered under the provisions of the
Volkswagen New Vehicle Warranty. It will be honored by any Authorized Volkswagen Dealer in 2!! E0 States, tho District of Columbia end Canada.
This warranty is transferable if the ownership of the vehicle changes within the above period.
In order to keep the warranty in force, you a9 the owner of the vehicle have certain responsibilities. It is important that the vehicle be maintained
properly. To facilitate record keeping, this booklet provides or. pages 56 to 53 space for listing maintenance services and oil changes as they
ere performed. Maintenance services should be performed by Authorized Volkswagen Dealers. They offer with their factory-
trained Volkswagen mechanics and special tools, fast, efficient service in accordance with Volkswagen quality standards.
Validation is a requirement of the Volkswagen New Vehicle Warranty. One year after the date of delivery, the warranty must be validated for the
second year. This can be done at any Authorized Volkswagen Dealership in the USA or Canada. For that purpose, you should present to the
Authorized Volkswagen Dealer the maintenance record for your vehicle. Provided that maintenance services and oil changes were performed in
accordance with Volkswagen specifications, dated bills of other than Authorized Volkswagen Dealers will be accepted as proof that these services
were performed on time.
-------
1969 OWNER'S MANUAL
No warranties, express or implied, as to Volkswagen vehicles sold in the United States are
made either by Volkswagen of America, Inc. or by the manufacturer or by the selling dealer,
except the following warranty by Volkswagen of America, Inc.
Warranty for new Volkswagen vehicles
This warranty Is issued by Volkswagen of America, Inc. ("VWoA'*), the authorized United States importer of Volkswagen vehicles.
Free repair or replacement
in United States and Canada
of defective parts
for 24 months or 24,000 miles
1. V'.VoA worraii s, lliat every Volkswagen vehicle imported by VWoA and sold as a new vehicle
to a retail customer by an authorized United States Volkswagen dealer will be free from defects in
material and workmanship under normal use and service for 24 months after the date of delivery
of the vehicle to the original retail customer or until the vehicle has been driven 24,000 miles,
whichever comes first. This warranty is limited, however, to the following If any part of the vehicle
becomes defective during this period under normal use and service and the vehicle is brought to
the workshop of any authorized Volkswagen dealer in the continental United Stdtes, Hawaii or
Canada, the dealer will, without charge, either repair the defective part or replace it with a new or
factory reconditioned part.
Maintenance and validation
by owner required to keep
warranty in effect
2. In order to keep this warranty in effect, the owner must do two things:
FIRST The owner must have the vehicle maintained and serviced as prescribed in the Volkswagen
Maintenance Schedule. (See page 56 )
SEC ON D. Every twelve months during the warranty period the owner must obtain from an author-
ized Ui.it.;.J States Volkswagen dealer a Validation Stamp on the Maintenance Card to show that
the vehicle has been maintained and serviced in accordance with the Volkswagen Maintenance
Sc nodule jlid.it ion will De made upon presentation of bills or other evidence sufficient to satis' ¦
the dealer tout the required service and maintenance have been performed. The validated Main-
tenance Card must be submitted whenever a claim is made under this warranty.
Horn's not covered by warranty
3. VWoA's warranty does not cover:
(i) Defects, damage or deterioration due to normal use, wear and tear or exposure: (n) nornnl
maintenance services, such as fuel system cleaning and wheel, brake or clutch ad|ustm'-'i!~
(in) the replacement of service items, as, for instance, spark plugs, ignition points, V-bulis ; 1
blades or brake and clutch linings: (iv) deterioration of upholstery, soft trim and apD0.ir.irr"'
items; (v) damage or defects due to misuse, alteration, negligence or accident, and (vi) d.vr ¦ ¦ -
or defects due to the repair of the vehicle by someone other than an authorized Volkswagen cJ
or the installation of parts other than genuine Volkswagen parts
Warranty outside United States
and Canada
4. If the vehicle is brought to an authorized Volkswaoen workshop outside the continental
United States, Hawaii or Canada, VWoA's warranty will not be applicable, and defective parts will
be repaired or replaced free of charne with new or factory reconditioned parts only v.vlnn thc-
terms and limitations of the \v r.-i.ty for i.l.v Vo"....uaov.n vciuclt. in uiccl in tliu country
where such authorized Volkswagen workshop is located
No other warranties made
5. This warranty is in lieu of al! othrr exnress or implied warranties of VlVoA, the
manufacturer and the selling ricnlcr, including any implied warranty of merchantability
or fitness for any particular purpose. Neither VWoA nor the manufacturer assumes, or
authorizes any person to assume, on its behalf, any other obligation or liability.
Let us explain the warranty . .
Volkswagen of America, Inc. is proud of the quality of automobiles it imports. It warrants riew vehicles for a period of 2 years or 24,000 miles
from the date of purchase, whichever comes first. In general the complete vehicle including battery and tires is covered under the provisions of the
Volkswagen New Vehicle Warranty. It will be honored by any Authorized Volkswagen Dealer in all 50 States, the District of CoiumL/id and Canada.
This warranty is ttansferablc if the ownership of the vehicle changes within the above period.
In order to keep the warranty in force, you as the owner of the vehicle have certain responsibilities. It is important that the vehicle be maintained
properly. To facilitate record keeping, this booklet provides on pages 58 to 61 space for listing maintenance services and oil changes as they
are performed. Maintenance services should be performed by Authorized Volkswagen Dealers. They offer with their factory-
trained Volkswagen mechanics and special tools, fast, efficient service in accordance with Volkswagen quality standards.
Validation is a requirement of the Volkswagen New Vehicle Warranty One year after the date of delivery, the warranty must be validated for the
second year This can be done at any Authorized Volkswagen Dealership in the USA or Canada. For that purpose, you should present to the
Authorized Volkswagen Dealer the maintenance record for your vohicle. Provided that maintenance services or oil changes were performed in
accordance with Volkswagen specifications, dated bills of other than Authorized Volkswagen Dealers will be accepted as proof that these services
-------
1972 OWNER'S MANUAL
to express warranties, as to Volkswagen vehicles sold in the United States are made either by Volkswagen of
America, Inc. ("VWoA"), or by the manufacturer, the distributor or the selling dealer, except the following warranty by
Volkswagen of America. Inc.
Warranty for New Volkswagen Vehicles
This warranty is Issued by Volkswagen of America, Inc. ("VWoA"), the authorized United States importer of Volkswagen
vehicles.
Free repair or
replacement in
the United States
and Canada of
defective parts
for 24 months
or 24,00 miles
Maintenance
required to keep
warranty
in effect
Items not
covered by
warranty
1. VWoA warrants that every Volkswagen
vehicle imported by VWoA and so'id as a
new vehicle to a retail customer by an
authorized United States Volkswagen
dealer will be (ree from detects in material
and workmanship under normal use and
service for 24 months after the date of deli-
very of the vehicle to the the original retail
customer or until the vehicle has been
driven 24 000 miles whichever comes first
This warranty is limited, however, to the
following If any part of the vehicle be-
comes defective under normal us > and
service and the vehicle is brought during
this period to the workshop of any author-
ized Volkswagen dealer in the continen-
tal United States Hawaii or Canada, the
dealer will, without chaige. either repair
the defective part or replace it with a new
or factory reconditioned part
2 In order to keep this warranty in effect,
the owner must have the vehicle maintain-
ed and serviced as prescribed in the
Volkswagen Maintenance Schedule.
3. VWoA's warranty does not cover:
(i) Defects, damage or deterioration due
to normal use, wear and tear or exposure;
(ii) normal maintenance services, such as
furl system cleaning and wheel, brake or
clutcli adjustments; (iii) the replacement
of service items, as, for instance, spark
plugs, iqnilion points, wiper blades or
brake linings; (iv) deterioration of uphol-
stery. soft trim and appearance items;
(v) damage or defects due to misuse,
alteration, negligence or accident; (vi)
damage or defects duo to the repair of Ihe
vehicle by someone other than an author-
ized Volkswagen dealer or the installation
of parts other than genuine Volkswagen
parts; (vii) damage or defects due to the
use of the vehicle in competitive events,
including rallies and races; (viii) and loss
of time, inconvenience, loss of use of the
vehicle or other consequential damage.
Warranty
outside the
United S ates
and Canada
No other
warranties made
4. If the vehicle is brought to an authorized
Volkswagen workshop outside the conti-
nental United Stales, Hawaii or Canada,
VWoA s warranty will not be applicable
and defective parts will bo icpa.:ed oi ic-
placed free of charge with new or factoiy
reconditioned parts only within the terms
and limitations of the warianty for new
Volkswagen vehicles in effect in the coun-
try where such authorized Volkswagen
workshop is located
5. This warranty is in lieu of all other ex-
press warranties of VWoA, the manufac-
turer, the distributor and the selling
dealer. Neither VWoA nor the manufac-
turer assumes, or authorizes any person
to assume, on its behalf, any other obliga-
tion or liability.
Let us explain the warranty ...
Volkswagen of America, Inc. is proud of the quality of the-: auto-
mobiles it imports It warrants new vehicles for a period o!
2 years or 24,000 miles from the date of purchase, whichever
comes first. In general, the complete vehicle including battery
and tires is covered under the provisions of the Volkswagen
New Vehicle Warranty It will be honored by any Authorized
Volkswagen Dealer in all 50 Slates, the District of Columbia
and Canada.
This v.auauty r.> tiunsfeiable if the owneislup of the vehicle
chang,:s within Ihe above period
In order to keep the warranty in force you as the owner of th j
vehicle, have certain responsibilities. It is important that the
vehicle bo maintained properly To facilitate record keeping,
this booklet provides space for listing diagnosis, maintenance
and oil change services as they are performed
Diagnosis and maintenance services should be performed by
Authorized Volkswagen dealers. They have Volkswagen train-
ed mechanics and special tools to provide fast, efficient
service in accordance with Volkswagen quality standards
The terms of your warranty require you to keep a maintenance
record of your vehicle. Hiovided that maintenance or oil
change services were performed in accordance with Volks-
wagen specifications, dated bills of other than Authorized
Volkswagen dealers will be accepted as proof that these
services were performed when required.
-------
1973 OWNER'S MANUAL
Except for the following warranty and the Emission Control System warranty by Volkswagen of America, Inc, no
express warranties as to Volkswagen vehicles sold in the United States are made either by Volkswagen of America.
Inc. ("VWoA"), or by the manufacturer, the distributor or the selling dealer.
Warranty for New Volkswagen Vehicles
This warranty is issued by Volkswagen of America, Inc. ("VWoA"). the authorized United States importer of Volkswagen
vehicles.
Free repair or
replacement in
the United States
and Canada of
defective parts
for 24 months
or 24,000 miles
Maintenance
required to keep
warranty
in effect
1. VWoA warrants that every Volkswagen
vehicle imported by VWoA and sold as a
new vehicle to a retail cusiomer by an
authorized United States Volkswagen
dealer will be free from defects in material
and workmanship under normal use and
service for 24 months after the date of deli-
very of the vehicle to the original retail
customer or until the vehicle has been
driven 24.000 miles whichovm coines first
This wannni)' is limited however io the
following li r:ny nnrt of the vchu;lo be-
comes r'-M-'"in"-" uti'i'V r.O'-nv'l U'V -inrl
service and the vehicle is biouyht during
this period to the woi kshop of any r.utho-
rized Volkswagen denier in the continen-
tal United States Hc.;ia ciii or Canada the
dealer will, without chaicje either repau
the defective part or replace it with a new
or factory reconditioned part
2 In order to keep this warranty in effect,
the owner must have the vehicle maintain-
ed and serviced as prescribed in the
Volkswagen Maintenance Schedule.
Wciri anty
outside the
United States
and Canada
No ether
warranties made
4 If the vehicle is brought to nn autlvr :
Volksv,v..'i;\-i workshop outsit.;, the ccrv -
nentai United States. Hawaii or Canada
VWoA's warranty will not bo applicant
and defective parts will be ropaned or re-
placed free of charge with new or factoiv
reconditioned parts only within the tenns
and limitations of the wairanty for new
Volkswagr.n vehicles in effect m the coun-
try where such authorized Volkswagen
workshop is located.
5. This v/arranty and the emission Control
System warranty for Volkswagen vehicles
are in lieu of all other express warranties
of VWoA, the manufacturer, the distributor
and the selling dealer. Neither VWoA nor
the manufacturer assumes, or authorizes
any person to assume, on its behalf, any
other obligation or liability.
Items not 3. VWoA's warranty does not cover:
covered by (i) Defects, damage or deterioration due
warranty to normal use, wear and tear or exposure;
(ii) normal maintenance services, such as
fuel system cleaning and wheel, brake or
clutch adjustments; (iii) the replacement
of service items, as for instance, spark
plugs, ignition poinls, wiper blades or
brake linings; (iv) deterioration of uphol-
stery, soft trim and appearance items:
(v) damage or defects due to misuse,
alteration, negligence or accident; (vi)
damage or def^fts due to.the rep?'r e? the
vehicle by someone other thru< an author-
ized Volkswagen dealer or the installation
of parts other than genuine Volkswagen
parts; (vii) damage or defects due to the
use of the vehicle in competitive events,
Including rallies and races; and (viii) loss
of time, inconvenience, loss of use of the
vehicle or other consequential damage.
-------
1974 DRIVER'S MANUAL
Warranty for New Volkswagen Vehicles
Thl9 warranty Is issued by Volkswagen of America, Inc. ("VWoA"), the authorized United States Importer ot Volkswagen
vehicles.
Free repair or
replacement in
the United States
and Canada oi
defective parts
for 12 months
or 20,000 miles
Maintenance
required to keep
warranty
in effect
1. VWoA warrants that every 1974 Volks-
wagen veruele imported by VWoA and
sold as a now vehicle to a retail customer
will be free from defects in material and
workmanship lor 12 months after the date
of delivery of the vehicle to the original
retail customer or until the vehicle has
been driven 20,000 miles, whichever
comes first. This warranty is limited,
however, to the following. If the vehicle
becomes defective under normal use and
service and is brought during this period
to the workshop of any authorized Volks-
wagen dealer in the continental United
States, Hawaii or Canada the dealer will,
Without charge, rcpdir iy oolc-clw'. part
or replace it with a new or factory recondi-
tioned part.
2. In order to keep this warranty in effect,
the owner must have the vehicle main-
tained and serviced as prescribed in the
Volkswagen Maintenance Schedule.
Warranty
outside the
United States
and Canada
No other
warranties made
4. If the vehicle is brought to an authorized
Volkswagen workshop outside the con-
tinental United States, Hawaii or Canada,
VWoA's warranty will not be applicable
and defective parts will be repaired or
replaced free of charge with newor factory
reconditioned parts only within the terms
and limitations of the warranty for new
Volkswagen vehicles in effect in the
country where such authorized Volks-
wagen workshop is located
5. This warranty and the emission control
system warranty tor Volkswagen vehicles
are in lieu of all other express warranties
of VWoA, the manufacturer, the distributor
and the selling dealer. Neither VWoA nor
the manufacturer assumes, or authorizes
any person to assume, on its behalt, any
other obligation or liability.
Items not 3. VWoA is not responsible for: (i) damage
covered by or malfunctions resulting from: (a) acci-
warranty dent, misuse, negligence or alteration;
(b) improper repair of the vehicle, (c) use
of the vehicle in competitive events; or
(d) failure to follow recommended main-
tenance requirements: and (li) loss of
time, inconvenience, loss of use of the
vehicle or other consequential damage.
Maintenance services, nnrf replace-
ment of service items, such ps air and fuel
filters, and lubricants and fluids arc also
at the expense of the owner.
-------
APPENDIX J
IDLE TEST PROCEDURES
FOR
-------
IDLE TEST PROCEDURES FOR
PARTICIPATING GARAGES
Prepared for
The Air Pollution Control Division
Department of Health
State of Colorado
Prepared by
QLSQR3 IABQRMORBES. INC.
A Subsidiary of Northrop Corporation
-------
1.0 SPARK IGNITION-POWERED MOTOR VEHICLE EMISSION LIMITS
Table 1 shows the exhaust emission limits for spark ignition-
powered motor vehicles when measured by an approved exhaust gas
analytical system using the appropriate test procedures.
Table 1
EMISSION STANDARDS FOR SI MOTOR VEHICLES
AT 50% REJECTION RATE
Vehicle
Model Year
HC
CO
1968 and newer
3 00
ppm
3.0%
Pre-1968
600
ppm
4.5%
2.0 EMISSIONS-ORIENTED MAINTENANCE OF SPARK IGNITION
VEHICLES
Inspected vehicles failing to comply with the emission standards
described in paragraph 1.0 shall be serviced and repaired prior
to reporting for reinspection. The following paragraphs identify
the recommended procedures and instrumentation for servicing and
repairing vehicles that fail to meet the emission limitations.
Other procedures, techniques, or instrumentation that achieve
the desired emission reduction are acceptable and encouraged.
However, no person shall disconnect, modify, remove, or other-
wise alter any motor vehicle emission control device or system
installed in compliance with Federal, State, County, or City
standards, regulations, and ordinance, unless such action will
result in continuing compliance with the applicable emission
requirements.
2.1 Instrumentation
Table 2 lists the recommended equipment required to perform emis-
sion-oriented service and repair.
-------
Table 2
RECOMMENDED EQUIPMENT
Type
HC and CO Analyzer
Ignition Analyzer, Oscilloscope
Ignition Timing Light
Tachometer
Distributor Advance Tester
Voltmeter, Ammeter, Ohmmeter
Vacuum Gauge, Pressure Gauge
Compression Tester
Dwell Meter
2.2 Service and Repair Procedure
2.2.1 Pre-Test
Prepare vehicle and equipment for test.
Test Equipment - Service, warm-up, and calibrate
~~ HC/CO test equipment per manufacturer's
specifications.
Test Vehicle - Verify engine is at normal operating
temperature (warm-up as required).
Hook-up - Insert probe in exhaust pipe (driver side
if dual exhaust), hook-up tachometer per
manufacturer's instructions.
2.2.2 Test
Perform HC/CO and rpm measurements and compare to Idle Test
Standards.
2500 rpm - Operate engine in neutral at 2500 rpm;
record HC/CO.
Idle rpm - Operate engine at idle rpm (in drive if
automatic transmission); record measurements.
Compare - Idle rpm emissions to test standards and
record manufacturer's specified rpm; if HC or
CO is high, adjust per paragraph 2.2.3.
-------
2.2.3 Adjust
Perform engine adjustments for HC/CO. When any adjustment step
brings emissions within limits, STOP procedure at that point and
re-test per paragraph 2.2.2.
Rpm - Adjust (if required) to mahUfacturer1s specifica-
tions; recheck HC and CO and record.
HC - Check timing per manufacturer's procedure/and record.
If timing is not as manufacturer's specification,
adjust as required; re-adjust rpm, if required;
re-check HC/CO and record.
CO - Adjust idle mixture to manufacturer's specification.
Where no specifications are available, use 2.0% to
4.0% for pre-1968 vehicles and 1.0% to 3.0% for
post-1967 vehicles. Re-adjust rpm, if required.
After adjustment, enrich mixture slightly to avoid too lean a
condition. Recheck HC/CO, and record.
When adjusting idle CO, attempt to reduce CO to lowest possible
value consistent with good idle quality. Avoid a rough idle
condition, side-to-side unbalance or increase in HC (HC increase
indicates a lean idle misfire).
If CO/HC emissions cannot be reduced to within limits while main-
taining acceptable idle quality, diagnose and repair vehicle as
required. ONLY those repairs necessary to bring idle HC/CO
within limits are to be accomplished.
2.2.4 Repair
Table 3 shows some probable causes for vehicles failing to comply
with the emission standards. The table should be used as an aid
in diagnosing the cause for failure. The general steps recommended
are:
Evaluate test results - as provided by vehicle
inspection station to owner.
Consult information sources - probable causes and mal-
function table, owner's vehicle manual, manufac-
turer's manual, automotive shop service manual.
Perform failure diagnostic - as determined from above
information sources and test results, and using
test equipment as necessary.
Repair malfunction - remove and replace defective
components; adjust as required.
Retest - as per paragraph 2.2.2.
-------
2.3 Maintenance Record
A maintenance record documenting the parts replaced and the
engine parameters adjusted, such as injector plunger adjustment,
rack adjustment, and fuel distributor timing, will be required
for each vehicle repaired and/or serviced.
Table 3
PROBABLE CAUSES FOR HIGH EMISSIONS*
Probable Causes
HC
CO
Rouqh
High
Very High
High
Very High
Idle
PCV Valve Dirty/
Restricted
X
X
Air Cleaner Dirty/
Restricted
X
X
Choke Stuck
Partially Closed
Carburetor Idle
Circuit Mal-
function
X
X
X
X
Intake Manifold
Leak
X
X
X
Ignition Timing
Advanced
X
Leaky Exhaust
Valves
X
X
X
Ignition System
Misfire
X
X
X
~HELPFUL HINTS
High HC - May be caused by ignition misfires, advanced ignition
timing, exhaust valve leakage, and over-lean mixtures. Ignition
misfires can be diagnosed by use of the oscilloscope, timing
problems by use of the timing light. Valve failure may be de-
tected by cylinder balance testing with compression test verifica-
tion. Lean misfire may be caused by too lean idle mixture setting
or manifold vacuum leaks.
High CO - May be caused by abnormally restricted air cleaner,
stuck or partially closed choke, or carburetor idle circuit
failure. Rough or erratic idle may be caused by PCV valve mal-
function. Idle HC/CO failure/malfunction Truth Table may be used
as a guide to identifying failures.
-------
APPENDIX K
-------
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to
to
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00
MAKE
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mc
SLUIAL NUMBER
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DATf.
71 /OS/19
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ACCIDENT OK RECALL STATUS
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OFFICE
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TITLE NUMLTR
FU!3r.?.n7
CASE NUMBER
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2 Hro?
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STKKEh NUMbf'h
> '£
VEHICLE INFORMATION
MAKE
YR
BODY
SERIAL N U N" B T R
MODEL
DATE
SN
TITLE NUMBER
MILEAGE
TAG NUMBER
TV
Tl
HP
US
'<4.r
It P,
3 7j •] 1
71 / n v i q
?
F If s r. ? 0 7
Mfini
ACCIDLNT INFORMATION
EXHAUST EMISSION DATA
CA8L NO »
DAMAGE
COST
REPAIR
ABC
CAJU. NO 2
DAMAGC
COST
RF.PAIR
ABC
CASK NO 3
DAMAGT
C03T
H I KA1K
ABC
IDI.E
H C
C.O
AVG
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RECALL CAMPAIGNS
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DMV 51-10 i»d J*n 71)
-------
OFFICIAL INSPECTION RECORD-DEPARTMENT OF MOTOR VEHICLES. D.C.
PLEASE KrFP THIS CARD n.*T AN!) CLEAN AM") WITH CAR. It musl be presented with your
vehicle for re-inspection. Loss of cttrj n'u~»y cou^e delay in inspection piocedu-.o
Issuance of this card 1nJ1c.net that tin \ohick> described hci'son has been rejected. The items causinu
rejection are indicated by pun."*.i ni'irk opposite the items rejected.
Vehicle-; rejected arc- is'-ucd a led rejection sticUci upon which is stamnwl a definite date, and on or
before thit date the vehicle sh;.ll be returned tor fin*] approval Additional time for re-inspection cannot be
granted.
Necessary adjus' ments. collections or rcpans may be made by any person of your choice, and at any
place. Inspection station pci Sonne) will do NO work pertaining to adjustments, corrections or repans. nor
indicate how or v.'hcie snch work OiouJd bo done
IN
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-------
ONTARIO DEPARTMENT OF TRANSPORT**
VFHir.l F RRANP.H
VEHICLE BRANCH 0NW|10
MOTOR VEHICLE INSPECTION REPORT
NOTE:- THIS IS UQI A CERTIFICATE OF MECHANICAL FITNESS AS REQUIRED BY SECTION 49-1 H.T.A. AND ONTARIO REGULATION 354/C3
BU'Siiwro
owv* *.
65026
DATE
TIME A , M
RECHECK 0 0®©
VEHICLE IDENTIFICATION
M A * E
[ 1 VOLUNTARY
^ j COM^OLSOR^
[ ATTl*-T>ON HCCOMMtHOCD
P-A,-,_.S REMOVED
plate
no.
SERIAL
NO
TYPE
YEAR
MILEAGE
NOTE'- THE FO.. O'.s.NG COMPONENTS of this motor vehicle have been inspected to check compliance WITH EQUIPMENT
MENTS ANO MIN v« m r~ R FO^'V *NC E STANDARDS.
AN !X| MARn INOiC « Tf i ITt^. .NOT IN C OM PLIANCE OR ATTLNTION RECOMME -JOED,
AN i X X ! MAKK INC*-. . L. E S ITklK'S . N HAZARDOUS CONDITION.
1) BODY EXTERiOK *
| | DOOR t,
~
OTHER LAMPS
| ' ) BOOY CONDITION
INSPECTORS
INITIALS
| GLASS CONG 1 T IJN
iZD
f ] 0 I R E C T 1 ON LAMPS
~
IDENTIFICATION
LAMP
| | FILLER CAP
» J
[ ] MINDSnieiO WlPCRi
iz:
BRAKE LAMPS
| " ~| PARKING LAMPS
~
BUMPERS
| j FENOtRS
| " | VISIBILITY OBSTRUCTION
¦;zd
CLEARANCE LAMPS
| [ NUMBER PLATE LAMP
~
HORN
I | MUO F LA PS
2) STEERING AND SUSPENSION:-
2 J
j | ALIGNMENT TOE - .1*
~
STEERING TRAVERSE
| { RIGHT SUSPENSION
~
WHEEL BEARING
PLAY
| " ] STEERING PuAY
[ | ALIGNMENT TOE - v>.'
a
BALL JOINTS
| { LEFT SUSPENSION
n
SPRINGS
[ ] WHEELS
j | K lh C p.HS
CD
OR AC LINK
| j TIE-ROD EnOj
~
STEERING ARM
[ 1 STEERING SHAFT
| j bTLLftlNG ^Air.
IDLER ARM
| [ SHOCK AQSOROCRS
~
STEERING BOX
~
3) TIRES, EXHAUST AND UNDERBODY COMPONENTS:-
3 )
[ ] l f T,RES [ 1 R.r.
~
Chassis frame
J | FLOOR PAN
~
REAR AXLE
TRACKING
| j FRONT BRAKE FLEX LINES
1 _] l "• l_J
~
EXHAUST SYSTEM
~
Engine compartment:-
lZ3
front rUEL
FLCK LINES
CARBURETOR OR
~
RESERVOIR LEVELS
j | HORN MOUNTING
4)
f " -1 ACCELERATOR
l 1 LINKAGE ST SI LM
n
POWER STEERING
DRIVER BELT
j 1 INJECTION PUMP
1 1 CONTROLS ft LINKS
~
HOOD LA TC H
j 1 STEERING BOX
| j FOR SECURITY
5} HEADLAMP AIM:-
AS )T APPEARS ON TESTER SCREEN WITH INSPECTOR FACING VEHICLE
LEFT LAM P
R I GH T LAM P
b
— 2
B
UPPER
BEAM
B
cyy/y
V/VO,
A X////
^ •
e
CCHTfit OF HOTSPOT MUST FALL WITHIN SHADED AREA
LEFT LAMP RIGHT LAMP
m
y P R RlCHT EOCC OF HOTSPOT MUST FALL WITHIN SHAOEO AREA
~ "
CADLAMP SHUTTER IF EQUIPPED
~
OTHtR DEFECTS
6) BRAKES:-
~ BRAKE FLJIO LEAKAGE
~
~
~
~
~ BRAKE PEOAL PAD
LEFT
PEOAL RESERVE
PARKING BRAKE MECHANISM
drakinc force
BRAKING FORCE DISTRIBUTION
FRONT
LEFT
RIGHT
REAR
7;&qdy interior:- |«„v.tw
~ ?"» | I TURN SIGNAL I I atATS I I OCTROSTCR I I STKHwLlRROM , _
1 " INDICATOR LAMP ! 1 INDICATOR LAMP 1 1 1 | | } COLUMN | I O'J . S DE
REMARKS:-
_ _
-------
v'EiiJ CulS IUSPXJCTJ.ON REP'J.tt1
'i'jn: vehicle described
iK'ro has Lecn inspected
V, ';] 10 Now Yor); City Taxi
I, i I' OU^.: r.i.- Commission
In spec Lion Facility. The
RKSULTS of that, inspec-
tion are shown in the re-
sults column. Information
eor£ect.i.dn of
deficient items is listed
on the attached sheet.
It. is the responsibility
of the vehicle owner to
s.:e that these REPAIR IN-
STRUCTIONS are obtained
and complied with.
Michael J. Lazar
Chai rman
i—i
1 U' ^> ¦ >
L.
o
FRD
o
cun
0
AM
o
Clib
0
OTnrr<
ro L-i.i r. • 3 co
-i 75
!
7.'.
17
71
7U
01 D'.-l;
CO LO t. '-> CO CO r>3 CO CO till C • 3
to n«n ccn
i:o coco co co co co co to or: laij;: i
c i n
t.o fr 13 LO no Co t.o t'd !: 13 co i.cj
co to eta cc-n r.13 co co3 co oa co
en no co r. o c o
ra c o lo r.> 13 c o co c o c o c o c o
[TO LO CO CO CO CO CO CO CO CO
cn co co co co co co co co co
L O Ci ~
KVNCT3 0N
STATION 0
1. DOCUMENTATION
2 . IIORN
STATION 1
3 „ VJ1LEEL ALIGNMENT
4. WASHERS/WIPERS
5. HEADLIGHTS
6. RUNNING LIGHTS
7. SIGNAL LIGHTS
8. EXTERIOR CONDITION
9. TIRES/WHEELS
10. UNDERHOOD
STATION 2
11. BRAKES
12. EMISSIONS
13 . SPEEDO |
MILEAGE
14. TAXIMETER
STATION 3
15. INTERIOR/COMFORT
16. STEERING
37. SUSPENSION
UNDERC/yRRJ AGE
TTRE CONDITION
DEFICIENT ITEM
r:u czn ctzd t—i cru czrj
3CH ChO 5* ShT WE.C.1 ^ (.IC Pel flLfl C/C OP lt.X
. .. _ CZTJ
WASHcR Wi^Slrf
cm cin cm i—i
p/t/s in sve e u° i'C pvt
trri r~~t ,trrj
-,I7» iTflT
rrzi d~u t—i c^jTj czru era
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-------
ONTARIO DEPARTMENT OF TRANSPORT**
VEHICLE BRANCH WX&^T
NOTE:-
~ ONTARIO
MOTOR VEHICLE INSPECTION REPORT
THIS IS HflT A CERTIFICATE OF MECHANICAL FITNESS AS REQUIRED BY SECTION 49-1 H.T.A. AND ONTARIO REGULATION 354/63
RttlSTEREO
NO.
65026
DATE
TIME
A ^
RECHECK Q
LO ® ©
VEHICLE IDENTIFICATION
MAKE
ATT t^TION RECOMMENDtD
plat c
NO.
SERI
NO
A L
^ j COMPULSORY
PlA'CS REMOVED
TYPE
YEAR
Ml LEAGE
NOTE"* THE FOL.O'A.nG COMPONENTS OF THIS MOTOR VEHICLE HAVE BEEN inspected to check compliance WITH EQUIPMENT
MENTS ANO MIN.MUM r" :".RFO"VANCE STANDARDS.
AN 'A ) MARK IND.C^Tr.b ITEm." NOT IN COM PLIA NC E OR ATTENTION REC OMMENDEO .
AN ,KXJ MAHK INL5,. ITEMS iN HAZARDOUS CONDITION.
REQUIRE-
1) BODY EXTERlCk -
~
OOOBi
~
OTHER LAM PS
| " | BODY CONDITION
.*> uprc tors
INITIALS
[ ](LASS CONDITION
LZ1
n
DIRECTION LAMPS
~
IDENTIFICATION
LAM P
| | FILLER CAP
1 )
[ ] WINDSHIELD
a
~
Parking lamps
~
BUM PC R 9
| ] FCNOERS
1 1 OBSTRUCTION
i I
C LEARANC C LAMPS
~
NUMBER PLATE LAMP
~
HORN
I | MUD r L A PS
2) STEERING AND SUSPENSION:-
2)
I | ALIGNMENT TOE - fs
~
STtCR'NG TRAVCRSC
~
RIGHT SUSPENSION
~
WHEEL BEARING
Play
[ I STEERING PlAy
| | ALIGNMENT TOC - :
~
BALL JOINTS
~
LEFT SUSPENSION
~
SPRINGS
| [ WHEELS
| j king pins
(ZD
ONAC .INK
~
VIC-ROD CNOj
~
STEERING ARM
[ "j STCCHING SHAfT
[ | STEERING LAS"
a
lOLER ARM
~
SHOCK ABi>OR BE R S
~
STEERING BOX
~
3) TIRES, EXHAUST AND UNDERBODY COMPONENTS:-
3)
< 1 \ TIRES f ¦<
Ql.f. \Z2*r-
~
CHASSIS FRAME
n
FLOOR PAN
n
REAR AXLE
TRACKING
| | FRONT BRAKE FLEX LINES
[ 1 l «• CU
~
EXHAUST SYSTEM
~
~')e NGINE COMPARTMENT:-
FRONT FUEL
FLEX LINES
CARBURETOR Oft
n
RESERVOIR LEVELS
[ | HORN MOUNTING
4)
| 1 ACCELERATOR
1 1 LINKAGE SYSTEM
~
POWCR STEERING
DRIVE*" BELT
~
INJEC TION PUMP
CONTROLS 6 LINKS
~
HOOO LATCH
j 1 STEERING BOX
J J FOR SECURITY
5) HEADLAMP AIM:-
AS IT APPEARS ON TESTER SCREEN WITH INSPECTOR FACING VEHICLE
LE *T LAM P
RIGHT LAMP
b
1
<
/yyA- 2"
A
6
UPPER
BEAM
B
y//A
^ yi
M '
B
CCNTRC OF HOTS POT MUST FALL WITHIN SHAOCD AM C A
I.CT LAMP RIGHT LAMP
~
IJPPC* BIGHT COCt Of H0T6P0T MUST FALL WITHIN SHAOCD AREA
~
hcadlamp shutter ir couippco
OTHER OCfCCTS
6) BRAKES:-
~ BRAKE FLUID LEAKAGC
~
~
~
~
~
PEDAL RESERVE
Parking brake mechanism
BRAKING FORCE
BRAKING rORCE DISTRIBUTION
BRAKE PEOAL PA0
LEFT SI 5m T
fron t
LEFT
RIGHT
REAR
7;&QDY INTERIOR:*
I ]UPPER BGAM I I
" /NO ICATOR LAMP ! I
TURN SIGNAL
INDICATOR LAMP
~ '
~
DC F R 05 T C R
~
R EAR V I C W
STE ERIN C MIRR0R3
COLUMN I
SIDE
0UT5-DC
REMARKS:-
K-4
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