United States Air Programs Branch
Environmental Protection Region rv
Agency Atlanta, Georgia 30305 February 1979
Motor Vehicle Emissions
Inspect ion/ Maintenance
Program for
South Carolina
Final Report
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MOTOR VEHICLE EMISSIONS
INSPECTION/MAINTENANCE
PROGRAM FOR
SOUTH CAROLINA
Libraiy Region IV
US Esvinmmssla! Protection Agency
345 Cmr'imi Street
Atlanta, Ge&rgia 363G5
BY:
JOHN GUNDERSON
EMIL J, VODONICK
GARY PAN
DAVID D. CLARK
JIM GATACRE
SYSTEMS CONTROL, INC.
ENVIRONMENTAL ENGINEERING DIVISION
421 EAST CERRITOS AVENUE
ANAHEIM, CALIFORNIA 92805
IN ASSOCIATION WITH:
PACIFIC ENVIRONMENTAL SERVICES, INC.
SANTA MONICA, CALIFORNIA
CONTRACT NO. 69-02-2536
PROJECT OFFICER
WALLY JONES
U.S ENVIRONMENTAL PROTECTION AGENCY REGION IV
ATLANTA, GEORGIA
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This re-port has been reviewed by the Air Programs Branch, U.S. Environmental
Protection Agency3 and approved for publication. Approval does not signify
that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency} nor does mention of trade names or commercial
products constitute endorsement or recommendation for use.
ii
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ABSTRACT
This document was prepared to assist the South Carolina Department of
Highways and Public Transportation (SCDHPT) in the evaluation and development
of a Motor Vehicle Inspection/Maintenance (I/M) program for the State. I/M
was designated by the Clean Air Act Amendment of 1977 as a method by which
ambient air quality standards may be achieved by 1982. If standards cannot be
attained by 1982, an extension of compliance to 1987 may be obtained, in which
case I/M implementation will be mandatory.
This report presents an analysis of costs and benefits associated with a
basic I/M program that could be implemented in South Carolina. Study efforts
were limited to nonattainment geographic areas over 200,000 population, namely
Berkeley, Charleston, Lexington, and Richland Counties. For comparative pur-
poses, a cost analysis for a decentralized statewide program was also performed.
Three alternative options for administration of an I/M program were studied;
state operation, contractor operation, and private -garage operation.
Based upon cost information, the preferred option selected by the State
was the private garage integrated with an existing safety program. Due to
increased equipment and operating costs, only the idle-mode option was
investigated.
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CONTENTS
Section
Page
EXECUTIVE SUMMARY 1
A. Why an Inspection/Maintenance (I/M) Program 1
1. Inspection/Maintenance 2
2. I/M Implementation Schedule 8
B. Background of This Study 12
C. Study Findings 14
1. Assumptions 14
2. I/M Program Costs 17
3. Consumer Fee 21
4. Costs of Repair 25
5. Emission Reduction Benefits 27
6. Fuel Economy Benefits 27
7. Indirect Impacts and Political Issues 30
INTRODUCTION 35
A. Assumptions . - ........ 39
BACKGROUND AND TECHNICAL MEMORANDA 40
A. National Ambient Air Quality Standards 41
1. Origin of the Standards 41
B. Nonattainment Areas for Photochemical Oxidants and
Carbon Monoxide in the State of South Carolina 56
C. Clean Air Act Amendment Requirements for I/M Program. . . 58
1. CAAA Requirements 58
2. Potential EPA Sanctions 61
D. I/M Program Effectiveness in Reducing Hydrocarbon and
Carbon Monoxide Emissions From Light-Duty Vehicles ... 62
1. Emission Reduction Potential 62
2. Results of California Study 63
E. Testing Program With A 30 To 35 Percent Failure Rate. . . 67
1. Introduction 67
2. Emissions Percentages Appendix N Allowable For a
30 to 35 Percent Stringency Factor 70
3. Repair Cost Per Service Vehicle Under Various
Stringency Factor 70
4. Emission Reduction Versus Rejection Rate 72
5. Station Requirements With Varying Failure Rates. . . 72
6. Idle Regime Standards for Emissions Surveillance . . 72
F. Administrative Program Options. 7&
1. Administrative Options Defined 76
2. Background Information on Current I/M Programs ... 77
3. Qualitative Comparisons of Administrative Programs . 82
4. Functional Comparisons 82
G. Idle-Mode Test 90
DETAILED ANALYSIS OF PREFERRED OPTION/PRIVATE GARAGE 96
A. Program Description 96
1. Program Administration 96
2. Test Mode 97
v
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CONTENTS (Continued)
Section
Page
3. Frequency of Inspection 99
4. Types of Vehicles to be Tested 99
5. Stringency Factor 100
6. Data Handling. 100
7. Phasing Considerations 102
8. Mechanic Training 104
9. Quality Control 106
10. Public Relations 106
11. Consumer Protection 107
12. Enforcement. 107
13. Legislative Requirements 108
B. Cost Methodology and Data Base 1°®
1. Cost Methodology I®9
2. Data Base H2
C. Cost Analysis 1^9
1. Facilities Requirements 139
2. I/M Program Costs 140
3. Consumer Fee Calculation I42
D. Benefits
1 44
1. Emissions Reduction
2. Fuel Savings ........ 146
3. Effect on Vehicle Performance and Vehicle Life . . . ^
4. Retest of Failed Vehicles
5. Value of Warranty Repair Work Performed
E. Independent Program Variables
1. Enforcement.
2. Repair Analyses and Consumer protection
3. Quality Assurance
4. Data Management System Design
5. Legislative Considerations
6. Mechanic's Training * ^00
7. Decentralized I/M system Minimum Station
Requirements ^07
STATEWIDE I/M PROGRAM ANALYSIS 211
A. Facilities Requirements 211
B. Personnel Requirements 211
C. Emissions Reduction 213
D. Costs of Statewide Program 213
E. Consumer Fee. 215
SPECIAL TOPICS 217
A. Referee Stations 217
B. Correlation Car 220
C. Tampering Check 221
D. Diesel Vehicles 221
1. Constitutents in Diesel Engine Exhaust Emissions . 22i
2. Light-Duty Diesel-Powered Vehicles . . . # 223
3. Heavy-Duty Diesel-Powered Vehicles . . " ^ 226
E. First-Year Vehicles ....
VI
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CONTENTS (Continued)
Section Page
7 REFERENCES 232
Appendices
A Memo From the U.S EPA to Regional EPA on I/M Program 235
B Emission Credits Given in The Code of Federal Regulations. . . 247
C Short-Test Emissions Standards as Related to Federal
Constant Volume Sampling Testing 257
D General Definitions 269
E Cost and Fee Calculations 277
F Tampering as a Vehicle Emissions Problem 283
G Compilation of Air Pollutant Emission Factors 289
H Heavy-Duty, Diesel-Powered Vehicles 293
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FIGURES
Number Page
1 Nonattainment Geographic Areas of the State of South
Carolina 13
2 South Carolina I/M Responsibility Chart 15
3-1 Nonattainment Geographic Areas of the State of South
Carolina 57
3-2 Average Vehicle Repair Costs 71
3-3 Emission Reductions as a Function of Rejection Rate 73
3-4 Flow Diagram of Short-Cycle Study 74
3-5 Functional Administrative Chart 87
3-6 Functional Administrative Chart - Contractor Operated and
Private Garage 88
3-7 Idle Inspection and Repair Functions 91
3-8 Idle Test Station Functional Flow 95
4-1 Pilot Program at the State Testing Center Timeline Idle
Test Mode 105
4-2 Idle Inspection and Repair Functions 134
4-3 Possible Post Maintenance Deterioration Functions Short Run . • 150
4-4 Actual Exhaust Hydrocarbon Levels Versus MPC Levels 151
4-5 Station Certification Procedure 177
4-6 Example of Test Facility Data Flow 182
4-7 Example of Inspection Program Report Format 183
4-8 Example of Rejection Slip For Visual Inspection 185
4-9 Emissions Control Systems Repair Summary 188
4-10 Continuation Sheet for Additional Repair Information 189
4-11 Manual Data Encoding Format 193
4-12 Example of Daily Operations Summary Worksheet 196
6-1 Three-Lane/Referee Facility 218
6-2 Inner Office and Test Area Three-Lane/Referee Facility 219
6-3 Diesel Engine Exhaust Gas Constituents 224
6-4 Comparative Analysis Diesel Versus Gasoline Engine
Mercedes-Benz Data 224
6-5 Failure Rate Region 228
6-6 Frequency Distribution of CVS-75 HC Emissions for 1976
Passenger Cars 230
6-7 Frequency Distribution of CVS-70 CO Emissions for 1976
Passenger Cars 231
viii
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TABLES
Number Page
1 Qualitative Comparison of Administrative Program Options. ... 4
2 Existing I/M Program Summary 7
3 Typical I/M Problems, Solutions and Achievements 9
4 Preferred Option Program Considerations 12
5 Costs of South Carolina I/M Program - Four Counties Option. . . 18
6 Costs of South Carolina I/M Program - Statewide Option 19
7 I/M State Manpower Requirements 22
8 Annualized Costs of I/M Program - Four Counties 23
9 Annualized Costs of I/M program - Statewide 24
10 Arizona Service Industry Repair Cost for Failed Vehicles. ... 26
11 Repair Cost Summary for Existing I/M Program 26
12 HC Emission Reduction With and Without Implementation of I/M
program for 1977, 1982, and 1987 28
13 CO Emission Reduction With and Without Implementation of I/M
Program for 1977, 1982, and 1987 28
14 Estimated Annual Fuel Economy Benefits of Failed Vehicles ... 29
3-1 National Air Quality Standards Established in 1971 42
3-2 Federal Ambient Air Quality Standards 43
3-3 Effects of Air Pollution 46
3-4 Visual Range in a Polluted Atmosphere 53
3-5 Air Pollution Damage to Various Materials 54
3-6 Added Costs of Living in Dirty Environmental 55
3-7 Hydrocarbons Emission Reduction Idle Regime 65
3-8 Carbon Monoxide Emission Reduction Idle Regime 66
3-9 Comparison of Emissions and Fuel Consumptions Reductions and
Repair Costs With Other Studies 64
3-10 First Year Percent of Emission Reduction of Hydrocarbons
Through I/M Program 67
3-11 First Year Percent Emission Reduction of Carbon Monoxide
Through I/M Program 68
3-12 Subsequent Years Program Credits For HC 68
3-13 Subsequent Years Program Credits For CO 69
3-14 First Year Percent Emission Reduction of HC for LDV I/M
Program 70
3-15 First Year Percent Emission Reduction of CO for LDV I/M
Program 70
3-16 Idle Regime Standards for 35 Percent Failure Rejection 75
3-17 Existing I/M Program Summary 78
3-18 Typical I/M Problems, Solutions and Achievements 80
3-19 Qualitative Comparison of Administrative Program Options. ... 83
3-20 Malfunction Truth Table for Idle Testing 94
4-1 Effect of Reducing the Maximum Repair Cost 101
4-2 Outline of Program Cost Categories and Elements 110
4-3 Advertised Performance Specifications of Exhaust Emission
Analyzer 115
4-4 Initial/Ongoing Public Information Program for One Year .... 120
4-5 Capital/Operating Costs Associated with Consumer Complaint
Follow-Up and Service Industry Field Clerk 122
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TABLES (Continued)
Number Pa9e
4-6 Estimated Annual Cost Expenditures for State-Operated
Spot-Check Program 121
4-7 Assumed Cost Expenditures for Vehicle Test Scheduling 123
4-8 Mobile Unit Costs Per Unit 126
4-9 State Testing Station Equipment Costs 127
4-10 I/M State Personnel Requirements and Salaries - Four County • . 129
4-11 Quality Control Field personnel and Yearly Costs Per Unit
Basis. 128
4-12 Support Service Costs I32
4-13 Light-Duty Vehicle Registration Data and Projection 133
4-14 Mobile 1 Output for Emission Factors for the Year 1987 138
4-15 Costs of South Carolina I/M Program - Four Counties Option. . . 141
4-16 Annualized Costs of I/M Program - Four Counties 143
4-17 Consumer Fee 144
4-18 Mobile Emission Factors Berkeley County, 1977 No I/M 146
4-19 HC Emission Reduction With and Without Implementation of I/M
Program for 1977, 1982, and 1987 147
4-20 CO Emission Reduction With and Without Implementation of I/M
Program for 1977, 1982, and 1987 147
4-21 Estimated Annual Fuel Economy Benefits for Failed Vehicles. . . 149
4-22 Ability to Repair Facilities to Follow the MVIP Repair
Procedures 162
4-23 Repair Vehicles Which Failed Reinspection 163
4-24a Average Repair Costs - Failed Vehicles. ............ 165
4-24b Arizona - 1977 Report 165
4-25 Daily Operational Checks and Adjustments 174
4-26 Malfunction Truth Table ... 186
4-27 Content of Training Courses 203
4-28 Estimated Program Costs for Mechanic Training 206
4-29 Projected Private Garage Emission Test Stations Required for
Each County 209
4-30 Service Area Radius For Private Garage Test Stations in Each
County Service Area Radius 210
5-1 I/M Statewide Manpower Requirements 212
5-2 Costs of South Carolina I/M Program - Statewide Option 214
5-3 Annualized Costs of I/M Program - Statewide 216
6-1 Referee Station Equipment Costs 220
6-2 Correlation Vehicle Cost Per Unit 220
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Section 1
EXECUTIVE SUMMARY
A. WHY AN INSPECTION/MAINTENANCE (I/M) PROGRAM
Recent ambient air quality data for the State of South Carolina indicates
violations of the National Ambient Air Quality Standards (NAAQS) for carbon
monoxide (CO) and photochemical oxidants. Because of these violations, the
Environmental Protection Agency (EPA) and the State of South Carolina Department
of Health and Environmental Control, designated the urban areas of Columbia
and Charleston as non-attainment. These national standards have been established
in order to protect the health and welfare of the population. Both CO and 0^
are gases which, in sufficient concentrations in the atmosphere are potentially
harmful to the public health.
A major source of CO and photochemical oxidants in South Carolina are
motor vehicles. Carbon monoxide is a product of incomplete combustion of an
internal combustion engine. Photochemical oxidants are indirect products,
formed through a complex series of atmospheric reactions of two other direct
products of combustion, reactive hydrocarbons (HC), and oxides of nitrogen
(NO^) in the presence of sunlight. An I/M program is a cost-effective strategy
to reduce CO and HC emissions from motor vehicles. By significantly reducing
the emission of HC and CO from in-use vehicles in South Carolina, an I/M
program will enhance the attainment of NAAQS.
The Clean Air Act Amendments (CAAA) of 1977 have specific provisions that
require the establishment of I/M programs. According to the CAAA the state
was to submit revisions to its State Implementation Plan (SIP) by January 1979,
which specifies methods to achieve the NAAQS. These methods include control
of stationary sources of air pollution and various transportation control
measures whose objective is to reduce vehicle miles traveled (VMT) and hence,
1
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reduce pollution from mobile sources. If, in these revisions, the state
cannot demonstrate attainment of the NAAQS by 1982 using all reasonably avail-
able pollution control measures, then an extension to 1987 can be requested.
If an extension is granted a mandatory I/M program will be required by the
CAAA. Based upon the SIP provisions, the NAAQS can not be attained in Berkeley,
Charleston, Lexington and Richland Counties of South Carolina by December
1982. The CAAA of 1977 provides that if a nonattainment area does not imple-
ment a mandatory program, then Federal funds will be withheld for 1) highways,
except safety, mass transit, or transportation improvement programs related
to air quality improvements; 2) sewage treatment grants; and 3) air quality
planning grants.
1. Inspection/Maintenance Programs
Inspection/Maintenance is a two-phase emission control program applied
periodically to all in-use vehicles. The inspection (Phase 1) of an I/M
program serves as a screening procedure to identify vehicles having emissions
which exceed established standards. The maintenance (Phase 2) of an I/M
program involves the repair of those vehicles that exceed the established
standards. Vehicles that have failed the inspection phase are required to
obtain corrective repair in order to pass inspection retest.
The Federal Motor Vehicle Control Program (FMVCP) was established to
ensure that new cars, off the assembly line, are designed to meet increasingly
stringent emission standards. Federal testing of in-use vehicles throughout
the United States has demonstrated that motor vehicles are not meeting the
emission standards for which the vehicles were designed. The reasons they
exceed the standards include: improper or inadequate maintenance, tampering,
defective emission control devices, and fuel switching. Regardless of the
cause, it has become clear that some in-use vehicle emission inspection programs
are necessary to ensure that the emission controls on vehicles continue to
operate as they were intended over their useful life.
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a. Program Organizational Approach
A variety of approaches have been used to run I/M programs, but the major
types are generally in three organizational categories:
1. State - Centralized test facilities operated by state, city, or
local government.
2. Contractor - Centralized test facilities operated by a private
corporation under contract to the State.
3. Private Garage - Decentralized test facilities operated by private
automobile service garages, certified or licensed by the State.
Each type of administrative program is compared qualitatively by identify-
ing responsibilities, functions, and roles in the emission test process as
shown in Table 1. In each program, the State plays an integral part by auditing
records, maintaining quality control checks, certifying contractor or private
stations, and assuring consumer protection.
b. Background Information on Present I/M programs
Inspection/maintenance programs currently operating throughout the country
are presented in Table 2. All available information is summarized under the
following categories: program type, size of subject vehicle population,
emission test, station requirements, cost (i.e., capital and operational), and
consumer fee charges.
Govenment I/M programs can be further subdivided into either state or
municipally-owned/operated programs. New Jersey operates a state program that
annually idle-tests 3.9 million light-duty vehicles (LDVs) at 38 stations (62
lane total capacity). This requires $2.5 and $1.3 million dollars in capital
and operating costs, respectively. Oregon idle-tests 0.55 million vehicles at
7 inspection stations on a biennial basis in the City of Portland. Capital
costs are $0.38 million dollars for leased facilities, and operating costs are
$2.22 million dollars. Consumer fee is estimated at $5.00 per vehicle.
3
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Table 1. QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS
COST CATEGORIES AND
CONSIDERATIONS
Instrumentation and
Technology
Site Acquisition
Facility Construction
and Acceptance
Equipment Acquisition and
Installation
Maintenance and Support,
Inspection-Oriented
Equipment
STATE-
OPERATED
CONTRACTOR-
OPERATED
PRIVATE GARAGE-
OPERATED
Design, requirements
analysis, and specifica-
tion development is
required.
Initial capital cost
required.
Capital investment
required, local govern-
ment approval to meet
zoning laws.
Volume discount.
Preventive maintenance
done by facility person-
nel; major corrective
maintenance done either
by a single technical
department or contracted
outside service; moder-
ate cost to State.
Will have expertise in
these areas.
Low capital cost to
state, deferred to oper-
ational charge.
Contractor agency will
require building in-
spection approval by
the State and local
government.
Moderate cost volume
discount.
Minor corrective
maintenance done by
facility personnel;
major corrective
maintenance done by
contracted service;
no cost to State.
Will have some basic exper-
tise, but will need to be
expanded.
Capital invested already.
Facilities available.
Each participating garage
will have to purchase equip-
ment that it does not
already have.
Preventive and minor correc-
tive maintenance done by
facility personnel; major
corrective maintenance prob-
ably done by contracted ser-
vice; no cost to State.
Quality Control and
Support Activities
Periodic confidence test-
ing and calibration func-
tions; minor repairs of
supporting equipments
done by facility person-
nel; major repairs done
by single department or
contracted; moderate cost
to State.
Periodic confidence
testing and calibra-
tion of minimum
number of stations by
state. Data process-
ing by state.
Performed by State agency.
Numerous stations to be
checked. Data processing
input from card decks.
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Table 1. QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS (Continued)
COST CATEGORIES AND
CONSIDERATIONS
Program Management and
Functions
STATE-
OPERATED
Maintain records, sched-
ule vehicles, collect
fees, review emission re-
sults, update standards
and documentation, deter-
mine future requirements,
evaluate newer equipments,
determine budgetary re-
quirements, and other
program management func-
tions; may involve many
separate State agencies,
new and/or existing;
moderate cost to State.
CONTRACTOR-
OPERATED
Similar management
functions to state
operated program, but
with State agency
that oversees contrac-
tor administration;
moderate cost to State.
PRIVATE GARAGE-
OPERATED
Requires State to audit all
records on regular basis;
high cost to State.
Program Management and
ui Administration Surveil-
lance Program
Periodic certification of
existing facilities;
qualification/certifica-
tion of new facilities;
moderate cost to State.
Periodic certification
of contractor facil-
ities by State inspec-
tion team; moderate
cost to State.
Private-operated facilities
certified by state personnel;
high cost to State.
Initial Personnel Train-
ing and Indoctrination
Single department respons-
ibility; uniform training
policy, course content;
minimum quantity of
trained instructors,
equipment, buildings;
moderate cost to State.
Require single depart-
ment responsible for
training, etc.;
minimal cost to the
State.
Possibly many diverse training
policies, course contents,
equipment, facilities, in-
structors; requires guidance
from State agency on require-
ments; minimal cost to State.
State Qualification and
Certification
Single departmental re-
sponsibility; uniform
qualification and certi-
fication policies; mini-
mum quantity of techni-
cal and administrative
personnel; moderate cost
to State.
State responsibility to
supervise initial
operation of program;
moderate cost to State.
Mandatory that State qualify
and certify stations; high
cost to State.
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Table 1. QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS (Continued)
COST CATEGORIES AND
CONSIDERATIONS
STATE-
OPERATED
CONTRACTOR-
OPERATED
PRIVATE GARAGE-
OPERATED
Vehicle Scheduling
Facility Inspection
Personnel Salaries,
wages, etc.
Quality Assurance
cn
Single departmental
respons ibility.
Technical rating depen-
dent on test regime; cost
proportional to technical
requirements; salaries
and benefits must be com-
petitive to attract
higher-rated personnel;
high cost to State.
Responsible for complete
audit of all records;
complete data analysis;
adjusting confidence
limits; moderate cost to
State.
Mandatory that State
be responsible.
Technical rating de-
pendent on test re-
gime requirements.
Mandatory that State be
responsible.
Technical rating depends on
test regime; cost propor-
tional to technical rating.
Calibration records
frequently audited by
State personnel; State
responsible for com-
plete data analyses;
moderate cost to State.
Difficult to implement be-
cause of instrument differ-
ences, diversified personnel;
high cost to State.
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Table 2.
EXISTING I/M PROGRAM SUMMARY
PROGRAM TYPE
STATE
ADMINISTRATIVE
AGENCY
VEHICLE POP
(Millions)
TEST MODE AND
STRINGENCY*
STATION STATUS
COST (Millions § Yr)
L.D.V. H.D.V. #Lanes #Sta. Mobile
Capital0
Operating** INSPECTION FEE
1. GOVERNMENT
A' state New Jersey
_ c
Oregon
Portland
B. Municipal Ohio,
Cincinnati
Illinois,
Chicago
9
II. CONTRACTOR
III.
PRIVATE
GARAGE
Arizona,
Maricopa
and Pima
counties
Nevada
(Clark
Co. only)
Rhode
Island
DMV - EPA
Dept. of
Environ. Qual.
Cincinnati
APCD3
Chicago Dept..
Env. Control
Ariz. Dept./
Health Ser.
Dept. Motor
Vehicles and
Dept. Human
Resources
Dept. of Trans-
portation
3.9 LDVs
0.55 LDVs
(biennial)
0.2 LDVs
1.1 ICVs
1.1 cars,
trucks, and
motorcycles
0.20 LDVs
0.5 LDVs
Idle
23%
Idle
40%
Idle
30%
NA
HA
NA
Idle
30-35%
Idleh
30%
Idle
Idle
30%
62
14
10
38
7
1
1
None
EPA
city
36 12
21B Licensed
Private stations
NA 923 Private Garages
+ 1 State-Operated
challenge lane
$2.50 (1972) +
$0.38 Leased
facil. (1975)
$0,013 safety
facil.
$2.0 (1973)
$10.5
$0.17 (1974)
$1.00 (1977)
$1.33
$2.22
$0.13 for
$3.50 including
safety
$5
$3.75 including
safety
$1.45 (1977) Free
e'E
$4.0
$5
$0.43
approx.
(1974)
Part of
Capital cost
1st year
$10.00-$33.00
(including
adjustments)
$4
Percent of vehicle failing to meet established standards.
bCost data defined per particular year. To upgrade costs to present year multiply by appropriate inflation factor,
c
State of Oregon, Oregon Environmental Quality Commission - "Report to the Oregon Legislature on the Motor Vehicle Emission Testing Program,"
January 14, 1977.
^ A ir Pollution Control Department.
elncluded as part of the registration fee.
^Chicago's program costs are covered by a city sticker fee.
Definitions! DMV - Department of Motor Vehicles.
LDV - Light-Duty Vehicle (GVW <8501 lb.).
11DV - Heavy-Duty Vehicle (GVW >8500 lb.).
'state of Arizona, Bureau of Vehicular Emissions Inspections - "Tune-up for Less Emission - It's Working Arizona Vehicular Emissions Inspection
Program Operations", 1977.
^Loaded test with only idle fail/pass standards.
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Municipally-operated programs are found in Ohio (Cincinnati), and Illinois
(Chicago). These programs annually inspect 0.2 to 1.1 million vehicles. Ohio
has only one test facility, but intends to expand the program later. Illinois
currently operates five 2-lane capacity test facilities. In addition, Illinois
operates six mobile test facilities. Ohio capital cost is $13,000 and operating
cost is $0.13 million. Illinois expenditures are $2.0 million for capital
costs and $1.45 million annual operating expenses.
The only contractor-owned/operated program is located in Arizona (Maricopa
and Pima Counties). The 12 test facilities annually process an estimated
1.1 million cars, trucks, and motorcycles using 30 percent stringency factor
with idle test requirements. Capital cost expenditures are estimated at
$10.5 million with annual operating costs approaching $4.0 million.
At present, Nevada and Rhode Island are the only states that have private
garage-operated I/M programs. Rhode Island has an extensive program, testing
0.5 million vehicles at 923 certified private garages. The Nevada program is
comparatively smaller, licensing only 218 garages to test 200,000 vehicles.
As expected, the capital cost expenditure for Rhode Island is quite large
compared to Nevada. Unexpectedly, the cost to the motorist is quite high for
Nevada ($10.00 to $33.00) compared to Rhode Island ($4.00). However, the
Nevada program does have vehicle adjustment included in the test requirements.
For each I/M program type, typical problems encountered during implementa-
tion, and their subsequent solutions, are shown in Table 3. Additional informa-
tion includes representative achievements for each state I/M program.
2. I/M Implementation Schedule
In producing an I/M SIP revision, the state must provide for:
1. An analysis of the benefits and costs of the program,
2. A public information effort,
3. A legislative proposal, and
4. A schedule for I/M implementation.
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Table 3. TYPICAL I/M PROBLEMS, SOLUTIONS AND ACHIEVEMENTS
PROGRAM TYPE
STATE & RESPONSIBLE AGENCY
PROBLEMS
SOLUTIONS
ACHIEVEMENTS
I. GOVERNMENT-
OPERATED
A. State-Operated
California
New Jersey
.(Pilot Program)
Minimal Problems
.2-Year Exemption for New Cars
.Lack Operating Capital
Capacity Improvements Cannot be
Made
.DMV Resistant to Increased Re-
failure Rate Expected in
Phase III standards (23%)
.Refailure Rate is 25%
.Legislation Pending
.Funding Has Increased $330,000
.No Position Change
.Refailure Rate Now 11%
.Public Reaction Excellent
.Unique Combination of Ex-
haust Analysis, Engine
Monitoring, and Computer
Technology
.Diagnostic Testing
.Nation's Longest On-Going
I/M Program
.4,700 Garages Now Utilizing
Exhaust Analyzers
.Private Garage Reinspection
Program
B. Municipal-
Operated
Oregon
Portland
Ohio
Cincinnati
Illinois
Chicago
.Biennial Inspection Lowers
Program Effectiveness, Created
Cash Flow and Personnel Problems
.Tampering
.tow Throughput
.Inadequate Enforcement
•No Phase-In Period and No P.R.
Program
•Mechanics Inadequately Trained
.Less Than 20% of Registered
Vehicles Have Been Inspected
.Inspection Period Will be Shortened
.Trying to Implement An Annual In-
spection Cycle, Requires Legislat-
ion Action
•Improved Enforcement Led to
Increased Throughput
•P.R. Program Needed
.Mechanic Training Program
.Increased Enforcement Policies
.Favor Mandatory Inspection with
Three Conditions*.
1. Fed. Govt, and Auto Manufac-
turer's Concurrence On War-
rantee Program
2. Auto Manufacturer's Compli-
ance with Existing Statutory
Emission Standards
3. I/M Implementation Over Reg-
ional Area
.Estimates Reduction of HC is
14% and CO 7%
.Private Garage Acceptance is
Increasing
.Demonstrated Short Lead
Time in Adding 1/M program
to Safety Program
.Communication Channels Estab-
lished with Auto Manufactur-
ers Regarding High Emission
Levels of Late Model
Vehicles
.Nation's First Fully Auto-
mated Inspection Program
-------
Table 3. TYPICAL I/M PROBLEMS, SOLUTIONS AND ACHIEVEMENTS (Continued)
PROGRAM TYPE
STATE 6 RESPONSIBLE AGENCY
PROBLEMS
SOLUTIONS
ACHIEVEMENTS
II.
CONTRACTOR-
OPERATED
III. PRIVATE
GARAGE-
OPERATED
Arizona
Maricopa and Pima Counties
Nevada
Clark County
•Initial Adverse Public Reaction
.Queuing Problems
•Tampering
•Inadequate Inspector Training
. Minimal
.Expected to Disappear With Increased .Nation's First Contractor-
Efficiency and Better Public
Awareness
.Needs Contractor Monitoring
Operated Program
.DMV Control of Licensing
of Stations and Inspectors
.Minimal Cost
Rhode Island
.Inadequate Training of Garage
Mechanics
.Some Garages Violated
Regulations
.On-Going Mechanic Training
Program
.Constant Monitoring Needed
.Program Initiated by
Governor and Rhode Island
DOT With Backing From Exe-
cutive and Legislative
Branches
.State-Run Inspection Facil-
ity Used as Reference
Station
-------
Before January 1, 1979, an SIP revision was prepared by DHEC and submitted
to the EPA. As a part of the SIP revision submittal itself, a commitment was
made by the Governor to implement the I/M program in accordance with the
schedule submitted. This schedule is in accordance with Reference 1. Quoting
from Reference 1:
"C. Authority To Implement I/M
Normally, adequate legal authority to implement a SIP revision must exist
for a revision to be approved. Where a legislature has had adequate opportuni y
to adopt enabling legislation before January 1, 1979, the Regional Administra or
should require certification that adequate legal authority exists for I/M
implementation by January 1, 1979. However, for many states there
insufficient opportunity to obtain adequate legal authority before eir ^
legislatures meet in early 1979. Therefore, a certification of legal authori y
for the implementation in these states must be made no later than June 30,
1979. An extension to July 1, 1980 is possible, but only when the state can
demonstrate that a) there was insufficient opportunity to conduct necessary
technical analyses and/or b) the legislature has had no opportunity to consider
any necessary enabling legislation for inspection/maintenance between enac
of the 1977 Amendments to the Act and June 30, 1979. Certification of adequate
legal authority, or other evidence that legal authority has been adopted, must
be submitted to the EPA Regional Offices to be included in the SIP revision
already submitted. Failure to submit evidence of legal authority by t"®
appropriate deadline will constitute a failure to submit an essential element
of the SIP "
"D. I/M Implementation Deadlines
Implementation of I/M 'as expeditiously as practicable' shall be defined
as implementation of mandatory repair for failed vehicles no later tnan
2-1/2 years after passage of needed legislation or certification of ad®^
legal authority for new centralized systems (State or Contractor-operated;,
and 1-1/2 years after legislation or certification for decentralized s^tem
which are adding emission inspections to safety inspections. For the norma
legislation deadline of June 30, 1979, new centralized programs muststart y
December 31, 1981, and all others must start by December 31, 3.982, whii-a
other programs must start by December 31, 1981. Where I/M can be implemented
more expeditiously, it must be. Each state implementation schedule must b
looked at individually to determine if it is as expeditious as practicabi
11
-------
B. BACKGROUND OF THIS STUDY
In order to comply with requirements of the CAAA of 1977, Systems Control,
Inc. (SCI), was contracted to study alternative I/M options.
The initial effort was the development of background data regarding the
technical and administrative aspects of I/M programs. A summary report which
described I/M program elements and other states' experience in I/M and various
technical memoranda, was produced to assist in the selection of a preferred
option.
The purpose of this report is to analyze the preferred option in terms of
cost and benefits such that the Department of Highways and Public Transportation
(DHPT) may consider it as a viable option in their SIP to meet NAAQS.
The Preferred Option - As indicated earlier, the DHPT selected the decen-
tralized preferred option of an idle test conducted by private garages measuring
HC and CO combined with the existing safety inspection program. The two
alternative program scenarios studied are shown in Table 4.
Table 4. PREFERRED OPTION PROGRAM CONSIDERATIONS
PROGRAM CONSIDERATION SCENARIO 1 SCENARIO 2
a
Benefits yes yes
Costs yes yes
Geographic Coverage 4-County Statewide
(see Figure 1)
Inspection Enforcement Annual Vehicle Registration Annual Vehicle Regis-
tration or Window
Sticker
aEmission data extrapolated from 4-County data.
In addition to the program considerations listed in Table 4, there are a
number of support services that are important to I/M effectiveness and cost,
but do not directly influence option selection. These support services include:
o Quality Assurance
o Mechanic Training
12
-------
SCALE OF MILE.9
• 1J
Fiqure 1.
NONATTAINMENT GEOGRAPHIC AREAS
OF THE STATE OF SOUTH CAROLINA
SOUTH CAROLINA
COUNTY OUTLINE MAP
$ c tr*rr - /Mr
-------
o Consumer Protection
o Public Education
The eventual implementation of the preferred option will require the
cooperation of several different state offices internal to the DHPT. Figure 2
provides a functional outline of the DHPT as it relates directly to I/M needs
and requirements. Use of existing facilities, services and resources should
greatly reduce the cost of support services.
C. STUDY FINDINGS
1. Assumptions
The methodology used in this report was based upon the following
assumptions:
o The program operation is over a period of 10 years
o The private garages would assume the cost of purchasing test
equipments.
o Vehicle Population Growth
1976 to 1982 - 4 percent
1982 to 1992 - 3.5 percent
o Capital Investment Per Station
$3,000. - Cost of emission testing and auxiliary equipment
o Operations Throughput Time
3.75 minutes
o Mechanics Costs (including overhead)
$18. per hour
14
-------
Figure 2. SOUTH CAROLINA I/M RESPONSIBILITY CHART
-------
All current safety inspection facilities will participate in the I/M
program and there will be no increase in the number of facilities
over the life of the I/M program
Station inspection load factor capability - 10 percent. NOTE: In
the four-county area with safety inspection stations, the load
factor for emissions testing is about 3 percent.
Emissions for statewide option were developed by extrapolating the
four-county data.
Cost of capital is 6 percent for the State.
The State personnel benefits including sick leave, vacation, retire-
ment, insurance, holidays, etc., is 25 percent of base rate.
Fuel cost is $0.70 per gallon.
Inflation rate is 7 percent. To convert from 1978 to 1983, a compound
factor of 1.403 must be used.
Indirect costs reflecting the cost to consumers for waiting time at
inspection lanes and cost of transportation to and from the inspection
and repair facilities were ignored.
Average miles traveled per year for LDVs is 11,500 miles per year.
Failed vehicles consumed, on an average, 3.8 percent more fuel than
the certified vehicle.
Assumed miles-per-gallon fleet average for LDVs is 15 miles-per-
gallon (1982), 24 miles-per-gallon for 1987 LDVs.
16
-------
2. I/M Program Costs
a. I/M Program Costs
The major cost components for the four-county and statewide options are
summarized in Tables 5 and 6. The costs are identified as to state costs
necessary to administer and conduct surveillance of the private-garage program,
and operation and capital costs assigned to the private garage.
1. Four-County Option - It has been estimated that 671 private garages,
distributed in the four counties as noted in Table 5, will actively
participate in the I/M program. This will require a 10-year expendi-
ture by the private garages of $4.0 million and $9.9 million for
test equipment and facility operations, respectively. During this
same period, the State will expend $4.9 million for capital, operation,
and implementation costs. Total I/M expenditures by state and
private garages for a 10-year program duration is estimated at
$18.9 million.
The private garage capital/expenditure of 4.0 million is the accumu-
lated first time instrumentation costs of $3,000 and a 5 year replace-
ment cost for a total of $6,000 per private garage - (6,000 x 671 =
$4 million). The private garage-operation cost of 9.9 million are
for the 671 private garages over the 10-year program at an operating
cost per private garage over the 10 years of $14,800 or an average
of $1,500 per year. Therefore, the total average cost per private
garage per year is $2,200.
The state costs of $4.9 million or an average of $40,000 per year
over the 10-year program is for 3.2 million operating costs for
administrative support analysis of data, prepare reports and administer
the program including consumer protection, 1.2 million for quality
control of 671 private garages, $200,000 for one time public informa-
tion program, 1.2 million for quality control equipment, 8.5 thousand
for office equipment, $78,000 for vehicle for complaint investigation
17
-------
Table 5
COSTS OF SOUTH CAROLINA I/M PROGRAM - FOUR COUNTIES OPTION
($1,000 1978 Dollars)
CATEGORY
I Test Equipment Costs
II Operating Costs
Facility Operation
Administrative Support
Quality Control
III Initial Implementation Costs
Public Information
IV Other Capital Costs
Administrative Office
Equipment
Quality Control Equipment
Consumer Protection
TOTAL
TOTAL STATE fi PRIVATE GARAGE
1982-1986
State
0
1,616.5
612.0
61.5
200.0
8.5
119.0
78.0
Private
Garage
2,013.0
4,562.9
0
0
0
0
0
0
0
2,695.5 6,575.9
9,271.4
1987-1991
State
0
1,616.5
612.0
0
0
0
0
0
Private
Garage
2,013.0
5,351.6
0
0
0
0
0
0
0
2,228.5 7,364.6
9,593.1
TOTAL
State
0
3,233.0
1,224.0
0
0
8.5
119.0
78.0
4,924
Private
Garage
4,026.0
9,914.5
0
0
61.5
200.0
0
0
0
13,940.5
18,864.5
Number of private garages participations in the program are:
Berkeley County 47
Charleston County 235
Lexington County 124
Richland County 265
Facility operation costs increased to compensate for increase in the vehicle population.
-------
Table 6
COSTS OF SOUTH CAROLINA I/M PROGRAM - STATEWIDE OPTION
($1,000 1978 Dollars)
1982-1986
1987-1991
TOTAL
CATEGORY
I Test Equipment Costs
II Operating Costs
Facility Operation
Administrative Support
Quality Control
III Initial Implementation Costs
Public Information
State
0
7,552.5
2,859.3
202.0
200.0
Private
Garage
9,405.0
13,053.6
0
0
0
State
0
7,552.5
2,859.3
0
0
Private
Garage
9,405.0
15,508.5
0
0
0
0
State
0
15,105.0
5,718.6
202.0
200.0
Private
Garage
18,810.0
28,562.1
0
0
0
0
UD
IV Other Capital Costs
Administrative Office
Equipment
Quality Control Equipment
Consumer Protection
TOTAL
TOTAL STATE & PRIVATE GARAGE
41.1
575.7
377.4
0
0
0
11,808.0 22,458.6
34,266.6
0
0
0
0
0
0
10,411.8 24,913.5
35,325.3
41.1
575.7
377.4
0
0
0
22,219.8 47,372.1
69,591.9
Costs are to the closest $100.
3,135 private garages would be participating in the program.
'Costs for statewide option are considered directly proportional to the number
of stations participating in the program.
-------
and software development for vehicle scheduling, and one time cost
associated with vehicle scheduling.
2. Statewide Option - In contrast to the four county option, the total
capital costs for 3,135 private garages at $6,000 per garage is
$18.8 million. This will require an annualized cost for capital
equipment $700 per year per private garage. The private garage
operation costs over the 10-year period is $28.5 million or $9,000
per private garage. This amounts to $900 per private garage per
year and a total cost per year for capital and operation costs of
$1,600.
The statewide operation costs of each private garage is less because
they will not inspect as many vehicles per garage as in the four
county option. The operating costs per vehicle is equal for each
option.
The state cost of $22.2 million or an average of $2.22 million per
year over the 10-year program is to cover 1) 15.1 million for operating
administrative costs to support analyses of data, prepare reports,
administer the program, investigate complaints and consumer protection,
$5.7 million for increased quality control of the 3,135 private
garages, 2) initial implementation costs of $202,000 and $200,000
for public information, and 3) other capital costs of approximately
1 million consisting of $41,000 for administrative equipment, $575,000
for quality control equipment and $377,000 for consumer protection
capital cost.
The state costs increase was considered to be proportional to the
large increase of participating private garages which was a 4.7 fold
increase over the four county options.
The total operating and capital cost for the statewide option program
is approximately $69.5 million. The gross estimate under this
option was to provide general comparative data only.
20
-------
b. Comparison of State Manpower Requirements
Table 7 lists the State personnel requirements for the four-county area
and the statewide program options. The State personnel requirements do not
have a one-to-one correspondence to the number of vehicles because the minimum
effort of program administration is independent of the number of vehicles.
For example, the number of inspection agents is based upon a calibration check
at each station every two weeks.
Program management responsibilities for either option will include:
1) vehicle test scheduling, 2) record maintenance, 3) establishment and review
of emission test limits, 4) data analyses to determine inspection program
effectiveness, 5) evaluation of current and future equipment needs, and 6) pro-
vision for future analyses and development. These program responsibilities
will be coordinated by three key state personnel positions: 1) Quality
Control Assistant Program Administrator, 2) Testing Assistant Program Adminis-
trator, and 3) Environmental Engineer. The specific responsibilities for each
management position is outlined as follows:
1. Assistant Program Administrator (Quality Control) - Will manage the
twice-monthly equipment calibration checks for all private-garage
inspection centers; the statistical analysis of emission test data.
2. Assistant Program Administrator (Test) - Will be responsible for the
efficient day-to-day operation of referee test stations.
3. Environmental Engineer - Is responsible for monitoring program
effectiveness and evaluation of vehicle emission reduction.
3. Consumer Fee
In order to compute consumer fee, the program costs for the four-county
and statewide options in Tables 5 and 6 were converted into annualized costs.
This was done by amortizing capital-related (categories I, IV, and V) over
10 years of program operation. Results are presented in Tables 8 and 9. Cost
of capital was assumed to be 6 percent.
21
-------
Table 7. I/M STATE MANPOWER REQUIREMENTS
JOB CATEGORY FOUR-COUNTY AREA STATEWIDE
Program Administrator 1 1
Assistant Program Administrator (Quality Control) 1 1
Assistant Program Administrator (Testing) 1 1
Environmental Engineer 1 2
Statistician 1 2
Clerical 4 8
Secretaries 1 2
Inspection Agents 10 43
TOTAL 20 60
22
-------
CATEGORY
Table 8. ANNUALIZED COSTS OF I/M PROGRAM
(1978 DOLLARS)
TOTAL AMORTIZED COSTC
a,b
I. Test Equipment Cost
private garage
II. Operating Costs
private garage
state
III. Initial Implementation
Costs - state
IV. Other Capital Costs -
state
$2,013,000 x 0.2374 x 5" +
$2,013,000 x 0.2374 x 5 = $4,779,900
- POUR COUNTIES
AVERAGE ANNUALIZED COST ($/YR)
$4,778,862/10 = $477,900
$61,500 x 0.1359 x 10 = $83,600
$200,000 x 0.1359 x 10 = $272,000
(8,500 + 119,000 + 78,000) x 0.1359
x 10 = $279,300
a
Total - State
Private Garage
State and Private Garage
All costs are rounded off to hundred dollars
"'Basic cost data is taken from Table 5.
"Amortization factor (F) is determined by the formula
$9,914,500/10 = $991,500
$3,233,000 + 1,224,000/10 = $445,700
(83,500 + 72,000)/10 = $35,600
$279,300/10 = $27,900
27,900
$ 509,300
$1,469,400
$1,978,000
F = 2 where i is the cost of capital (=6%) and n is the number of years
d+u""1
For equipment amortization of 5 years, F = 0.2374
For capital amortization of 10 years, F = 0.1359
1 . ...
The equipment life is considered to be 5 years, therefore, it is required to replace equipment after
5 years.
NOTE: Fee Calculation
private garage share =
state share =
$1,469,400
622,200 vehicles
$509,300
622,200 vehicles
= $2.36
= $0.81
TOTAL FEE $3.17
-------
Table 9.
CATEGORY
I. Test Equipment Cost
private garage
II. Operating Costs
private garage
state
III. Initial Implementation
Costs - state
IV. Other Capital Costs
state
ANNUALIZED COSTS OF I/M PROGRAM3'b
(1978 DOLLARS)
TOTAL AMORTIZED COSTC
$9,405,000 x 0.2374 x 5^ +
$9,405,000 x 0.2374 X 5 =
$22,327,500
$28,562,100 facility operating
$202,000 x 0.1359 x 10 = $274,500
(41,100 + 575,700 + 377,400) x
0.1359 x 10 = $1,351,100
- STATEWIDE
AVERAGE ANNUALIZED COST ($/YR)
$22,327,500/10 = $2,232,700
$28,562,100/10 = $2,856,200
(15,105,000 + 4,718/500)/10 = $2,082,400
$274,500/10 = $27,500
$1,351,100/10 = $135,100
$5,088,900
$2,245,000
$7,333,900
Total - State
Private Garage
State and Private Garage
aAll costs are rounded off to hundred dollars.
"'Basic capital and operating cost data is taken from Table 6.
'Amortization factor (F) is determined by the formula.
F = i(l + i)n/l + i)n -1 where i is the cost of capital (= 6%) and n is the number of years.
For equipment amortization of 5 years, F = 0.2374
For capital amortization of 10 years, F = 0.1359
1
Equipment life is considered 5 years, therefore, it is required to replace equipment after 5 years.
$5,088,900
NOTE: Fee Calculations
private garage share =
state share =
2,103,000 vehicles
$2,245,000
2,103,000 vehicles
= $2.42
= $1.06
TOTAL FEE $3.48
-------
The average consumer fee to defray the four-county I/M program cost was
estimated to be $3.17 per vehicle (in 1978 dollars). The state's share is
$0.81 while the private garages's share is $2.36. The fee is derived by
dividing total annualized costs in 1978 dollars by the vehicle population of
622,200 in year 1986. The fee allows one retest of a failed vehicle.
The average consumer fee to defray the statewide option I/M program cost
was estimated to be $3.48 (see Table 9). The state's share is $1.06, while
the private garage's share is $2.42. The average vehicle population for the
statewide option was 2,103,000 vehicles. The increased cost for the statewide
option is because the costs of equipment and operations requrements of 3,135
participating private garages. - The participating garages for the statewide
program would be testing fewer vehicles then the participating stations in the
four-county option.
It should be noted that the fee covers only the State's direct cost on
the I/M program and certain indirect costs, such as utilities/supplies, office
rental, etc. It is difficult to include all governmental indirect costs in
this study without a detailed knowledge of the state's general accounting
procedure.
4. Costs of Repair
The maintenance of the I/M program involves the repair of those vehicles
which were identified as high emitters? the level of preventative maintenance
requested by vehicle owners; and any unnecessary repairs by the service
industry.
Recent Arizona I/M experience revealed that the average cost of repairs
of failed vehicles was $23.20 during 1977 based upon average repair cost for
1968 to 1977 model years with market distribution set forth in Table 10.
These costs ranged from zero for warranty repairs to over $600. for an engine
overhaul. Table 10 presents the average cost of repairs for various model-
year groupings in different facilities performing the repairs.
25
-------
Table 10. ARIZONA SERVICE INDUSTRY REPAIR COST FOR FAILED VEHICLES
MARKET SHARE
TYPE FACILITY 1964-1967 1968-1977 1964-1977 PERCENTAGE
Franchised dealers
Service stations
Merchandisers
Tune-up specialists
Independent garages
"Do-it-yourselfers"
Source: Ref. 2.
$41.25 $26.82
23.06 19.81
15.53 20.29
36.19 22.86
21.33 27.46
14.27 20.61
$27.97
13
21.14
15
19.43
3
24.72
3
26.79
27
19.08
39
Moreover, Table 11 presents vehicle percent contribution to various repair
cost categories for Arizona, Oregon, and New Jersey. Again the repair costs
are less than $10 for 29.8 to 66 percent of the vehicles tested. Lower repair
costs are attributed to carburetor adjustments, rather than expensive tune-ups
or engine repairs. The median value of $15 in the Arizona repair costs would
indicate when comparing it to the average cost of $23.20 that the majority of
vehicles have low repair costs and a few vehicles may have high repair costs.
Table 11. REPAIR COST SUMMARY FOR EXISTING I/M PROGRAMS
ITEM ARIZONA OREGON NEW JERSEY
Repair Costs
Less than $10 44% 64% 29.8%
$10 to $25 24% 21% 26.4%
$25 to $50 20% 8% 22.1%
$50 to $100 10% 5% 16.1%
More than $100 2% 2% 5.6%
Number of Vehicles 2,000 1,400 1,600
Median Repair Costs $15 $8 $20
Percent of Repairs less
than average cost 64% 71% 65%
Ref. 8
Other studies, however, indicated the average repair cost would be approxi-
mately $36. (in 1977 dollars). (Ref. 3, 4, 5, 6.) Some states have placed a
cost ceiling on the amount of repair.
26
-------
5. Emission Reduction Benefits
The levels of emission reduction that result from the implementation of
I/M programs depends on the number of vehicles inspected, stringency factor ,
function, and also on the travel characteristics in the county where the
vehicles are registered.
The calculation of emission reduction as a result of I/M implementation
was based on results obtained from the EPA-supported MOBILE 1 computer program.
This program enables the user to apply I/M program credits to emission factor
estimates by inputting a stringency factor and vehicle model-year applicability.
Emission levels developed by MOilLE 1 program, presented in Tables 12 and 13,
detail HC/CO emission levels without I/M; with I/M; and percent emission
reduction from I/M implementation,- for county and statewide geographic options.
This information was provided for 1982 and 1987 I/M program years using
1977 as a base year. The second column for HC and CO shows total emissions in
1977. The third and sixth columns show emissions expected in 1982 and 1987
without an I/M program. The lower figures for both years are attributable to
the Federal Motor Vehicle Emission Control Program (FMVCP). The fourth and
seventh columns show the amount of emission reduction that would occur with
FMVCP and an I/M program. The fifth and eighth columns show the actual percent
emission reduction that may be achieved through implementation of an I/M
program. In all instances, the percent reduction for each county closely
approximates percent reduction values achieved over the entire state.
6. Fuel Economy Benefits
One of the important benefits of I/M programs, in addition to the reduction
in vehicular emissions, is fuel conservation. A properly tuned engine operat
with greater efficiency, and therefore, consumes less fuel. This improvement
in fuel economy varies somewhat from one program to another but most so
agree up to a 10-percent fuel economy improvement can be expected between the
failed and maintained vehicles.
~Stringency factor refers to the percentage of total vehicles tested in an
I/M program, in a given time period, that fail inspection and are required
to have maintenance performed.
27
-------
Table 12. HC EMISSION REDUCTION WITH AND WITHOUT IMPLEMENTATION OF I/M PROGRAM FOR
1977 (Base Year), 1982, AND 1987 (Tons Per Year)
1977 1982 1987
COUNTY WITHOUT I/M WITHOUT I/M WITH I/M % REDUCTION WITHOUT I/M WITH I/M % REDUCTION
1.
Lexington
5,961
3,962
3,748
5
2,313
1,793
22*
2.
Richland
10,376
6,148
5,790
6
3,499
2,670
24*
3.
Berkeley
2,421
1,527
1,434
6
919
697
24*
4.
Charleston
9,205
5,335
5,028
6
2,920
2,216
24*
Total
27,963
16,972
16,000
6
9,651
7,376
24*
Statewide
89,662
56,086
52,785
6
31,870
24,358
23*
SOURCE:: Ref. 6
~Although the 1987 percent reduction does not meet the EPA reduction of 25 percent as specified in
Reference 1, the percent reduction could be within the error potential of the MOBILE1 program and
the State of South Carolina should not have any difficulty in meeting the required percent reduction
with the planned I/M program.
Table 13. CO EMISSION REDUCTION WITH AND WITHOUT IMPLEMENTATION OF I/M PROGRAM FOR
1977 (Base Year), 1982, AND 1987 (Tons Per Year)
1977 1982 1987
COUNTY WITHOUT I/M WITHOUT I/M WITH I/M % REDUCTION WITHOUT I/M WITH I/M % REDUCTION
1.
Lexington
43,973
38,548
32,552
16
25,903
17,459
33
2.
Richland
79,829
60,983
51,112
16
39,160
25,944
34
3.
Berkeley
17,581
14,684
12,278
16
10,116
6,609
35
4.
Charleston
71,793
53,356
44,626
16
32,715
21,456
34
Total
214,176
167,571
140,568
16
107,894
71,468
34
Statewide
683,540
552,835
463,754
16
356,300
236,010
34
SOURCE: Ref. 6
-------
An I/M program is to give an incentive to motorists to maintain their
cars better than they normally would in the absence of I/M. This maintenance
would increase vehicle-life and prevent problems such as vehicle stalling.
A 3.8 percent fuel economy improvement, per failed vehicle per year (as
established from California programs), was used in this study to calculate
fuel and dollar savings for the I/M program options. As shown in Table 14,
the four-county I/M option would save 5.48 million gallons of fuel in 1982 and
4.07 million gallons in 1987. At $0.70 per gallon, vehicle owners would save
$3.84 million and $2.85 million for 1982 and 1987, respectively. If coverage
is extended to include the entire state, motorists would save 18.10 million
gallons in 1982 and 13.45 million gallons in 1987. This amounts to $12.67 mil-
lion and $9.41 million for 1982 and 1987, respectively.
Table 14. ESTIMATED ANNUAL FUEL ECONOMY BENEFITS FOR FAILED VEHICLES3
1982 SAVINGSb 1987 SAVINGS0
J J
Fuel $ Per Fuel $ Per
OPTION Mil. Gal Million Vehicle Mil. Gal Million Vehicle
1. Four-County 5.48 $ 3.8 $7.14 4.07 $2.85 $4.46
(Lexington,
Charleston,
Berkeley,
Richland)
2. Statewide 18.10 $12.67 $7.14 13.45 $9.41 $4.46
a
See Section 4-D of the final report for computation details.
b
Fleet average fuel efficiency is assumed to be 15 miles per gallon.
Q
Fleet average fuel efficiency is assumed to be 24 miles per gallon.
d
Average miles traveled per year is 11,500 miles per year.
In terms of fuel savings per vehicle, it would be $7.14 in 1982 and $4.46
in 1987. Less fuel savings per vehicle in 1987 is anticipated because of
higher fuel efficiency of automobiles. Moreover, the motorist who repairs his
failed vehicle will realize a saving in fuel cost as an offset to the repair
cost.
29
-------
7. Indirect Impacts and Political Issues
In addition to the primary benefits of reducing vehicular emissions, fuel
savings, and improving air quality, I/M programs have indirect benefits and
bearing on political issues. To discover what the potential benefits and
poltical issues might be, other I/M programs were reviewed.
a. Indirect Benefits
There are several indirect benefits that do not relate to specific options
but would result from the implementation of any I/M program option. These
include the following:
o Improved health benefits (less respiratory problems, etc.)
o Improved vehicle performance and vehicle life
o Increased agricultural production
o Reduction of airborne particulates
o Reduction of sulfur oxides, carbon monoxide, ozone, and nitrogen
oxides
o Improvement in visibility
o Conservation of energy
The improvement in air quality in those areas where the NAAQS are currently
exceeded are likely to have some benefits in the health of the affected
population.
The amount and nature of the benefits would depend on the severity of air
pollution prior to the implementation of the I/M program, and the amount of
reduction in air pollution resulting from I/M. However, a recent publication
30
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"Clean Air for South Caroline - How Our State Stands", identified several
areas throughout the State that experienced 300 to 350 days of stagnant weather
conditions.
b. Political Issues
Political issues surrounding an I/M program are:
o Impacts on low-income citizens
o Potential overcharging for repairs and performance of unnecessary
repair work
o Problems of conflict of interest and uniformity of inspection in the
private-garage approach
I/M programs have the potential of placing a burden on low-income citizens
by forcing them to make expensive repairs for failed vehicles. This could
force low-income people who own older vehicles to make needed repair that
exceed the value of the vehicle. This problem has been reduced by instituting
repair cost ceilings. Thus, if the cost of the repairs needed to meet the
standard exceed a cost ceiling, then the vehicle could receive an inspection
waiver. A cost ceiling, if implemented, could create administrative problems.
The problem of dealing with repair overcharging or unnecessary repair
work can be dealt with in several ways. Some states have instituted recommended
repair procedures that are specified for various emission failure problems.
These procedures range from an idle adjustment to a low emission tune-up.
Mechanic training programs will result in a higher level of repair competence
and motivation. Consumer protection programs can be designed to identify
those garages that charge significantly more than the average repair cost or
identify garages generally drawing numerous consumer complaints. Such proce-
dures can be relatively informal or can be tied in with formal licensing of
garages and mechanics.
31
-------
The options with inspection, as well as repair, in licensed private
garages may pose quality assurance and consumer protection problems. With a
large number of garages having emission analyzers of varying degrees of quality,
and with less uniform supervision, there will probably be less uniformity of
the inspection in private garages. Moreover, there is an inherent conflict of
interest in having the same garage conduct both the testing and maintenance
phase of I/M.
Public Information Program - Many questions raised by I/M implementation
can be properly addressed through a well-designed and comprehensive public
information program. It can help to eliminate adverse public criticism by
stressing the purpose, objectives, benefits, and operation of I/M. Emphasizing
the checks and balances (e.g., quality assurance) designed into the I/M program,
and health benefits from emission reductions, will alleviate many problems
associated with the implementation procedure.
A public information program can address other benefits to the vehicle
owner. Improvements in fuel economy, vehicle performance and longevity are
important to vehicle owners. Control of vehicles that emit annoying quantities
of smoke, and assurances that I/M requirements will extend to all vehicles,
are important points to stress.
This can be accomplished by effective use of advertising techniques that
utilize the mass communication media (e.g.; radio, television, newspapers,
etc.), information centers, education programs, citizen group contacts, etc.
In the early stages of I/M implementation, initial program information should
explain the following:
o Need for an I/M program
o Explanations that specify derived benefits from automotive emission
inspection and maintenance
o Cost and benefit of an I/M program for in-use vehicles
o Explanations of the inspection procedure
32
-------
Supplemental information is required after the public has accepted the
need to understand the concepts of I/M. This additional information includes:
o The location of test facilities and private garage responsibilities
in the program
o Instructions and fee requirements
o Explanation of basic idle test requirements and retest requirements
and conditions
o Importance for allowing time for repair and retest, or considera-
tions for waiver (if implemented)
o Explanation of complaint referral system
o Explanation of area covered by I/M program
o Explanation of maximum repair level, average repair, carburetor and
ignition functions and major repair problems
33
-------
References
1. United States Environmental Protection Agency (EPA), "Inspection/Mainte-
nance Policy," David G. Hawkins, Assistant Administrator for Air and
Waste Management, July 17, 1978.
2. State of Arizona, Bureau of Vehicle Emission Inspection, Arizona Department
of Health Services, "Arizona Vehicle Emission Inspection Program Operation -
1977," April 1978.
3. State of California, Air Resources Board, "Evaluation of Mandatory Vehicle
Inspection and Maintenance Program," August 2, 1976.
4. Northrop Corporation, "Mandatory Vehicle Emission Inspection and Mainte-
nance," Vol. 5, 1971.
5. U.S. Environmental Protection Agency, "Control Strategies for In-Use
Vehicle," November 1972.
6. Olson Laboratories, Inc., "Effectiveness of Short Emission Inspection
Test in Reducing Emissions Through Maintenance," July 31, 1977.
7. Engineering Science, Inc., "South Carolina Highway Emissions, October
1978.
8. Kincannon, B.F., A.H. Castaline, "Informantion Documents in Automobile
Emissions Inspection and Maintenance Programs." Prepared for U.S.
Environmental Protection Agency, 1978.
9. State of South Carolina, "Clean Air for South Carolina - How Our State
Stands," South Carolina Lung Association and Bureau of Air Quality
Control, South Carolina Department of Health and Environmental Control.
34
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Section 2
INTRODUCTION
The purpose of this document is to present information on the possible
use of vehicle inspection/maintenance (I/M) as a strategy for reducing air
pollutant levels in the State of South Carolina. The format of the report was
developed with the specific intent of allowing distribution to a wide audience,
including both technical and nontechnical personnel. Depending on the back-
ground of the reviewer and his familiarity with I/M, it will be necessary to
examine all or only certain sections of the document. Section 1 of the report
presents an Executive Summary of the costs and benefits associated with poten-
tial I/M programs for South Carolina. This section will be particularly
useful for persons with a good initial understanding of I/M and limited time
for review. Section 3 is made up of a series of technical memoranda which
give generalized background information on the following topics:
o The National Ambient Air Quality Standards (NAAQS)—their origin,
basis and health implications, particularly with respect to photo-
chemical oxidants and carbon monoxide.
o Geographic description of the nonattainment status of the State with
respect to oxidant and carbon monoxide air quality standards.
o Requirements of the Clean Air Act Amendments of 1977 as they relate
to I/M, including a discussion of the Federal sanctions which may be
imposed if states do not comply with these requirements.
o General description of the effectiveness of an I/M program in the
reduction of hydrocarbon and carbon monoxide from vehicular sources.
35
-------
o Testing program (emission testing program with a 30 to 35 percent
failure rate).
o Ownership of test lanes and equipment (private garage with safety
inspection program).
o Test mode (idle).
Section 4 gives more detailed descriptions of the analysis work that was
performed for this project. It includes an expanded explanation of each of
the various facets of an I/M program for South Carolina. The section also
discusses the methodology used to compute costs and benefits, and provides
information on the particular requirements of certain program issues such as
consumer protection, mechanic training, legislation, etc. This technical
information is of use to those governmental agencies which will be responsible
for implementation of a certain facet of the I/M program.
Recent national interest in I/M as a control measure for vehicle emissions
was generated by provisions of the Clean Air Act Amendments of 1977. Briefly,
in accordance with the Amendments, all areas of the country are to achieve
ambient air quality standards by 1982 through the implementation of Air Quality
Management Planning. One of the means by which this 1982 goal can be reached
is through implementation of I/M. Under certain circumstances, an extension
of compliance until 1987 can be granted. In this situation, however, the
implementation of I/M is mandatory.
Four counties in the State of South Carolina have been designated by EPA
as nonattainment areas. Three counties are currently designated as CO nonattain-
ment. The State of South Carolina has been investigating a number of pollution
control measures to attain standards in these areas and, as a portion of this
effort, has directed Systems Control, Inc. (SCI) to provide data on I/M
implementation.
The scope of the work performed by SCI during Task II was primarily
focused on the cost/benefit analysis of the four counties designated by the
36
-------
State of South Carolina; Berkeley, Charleston, Lexington and Richland. The
scenario studied was as follows:
o Private garage-operated
o Idle-mode check for HC and CO (with safety inspection)
o 30 to 35 percent stringency factor
o Vehicle registration enforcement
o Area coverage is for the four noted counties (Note - a gross analysis
was completed on the entire state)
Task 1 of the program outlined certain program options that allow for
Federal Appendix "N" credits. The Appendix N requirements and associated
program options were identified as follows:
o Ensure regular periodic inspections - (Reference Item(c),(i),
Appendix N)
Vehicle registration process
Clean air sticker program
o Inspection failure criteria - Idle mode test, 30 to 35 percent
stringency factor administered by either of the following options
(Reference Item(c),(ii), Appendix N):
- Government-operated
Contractor-operated
Private garage-operated
o Ensure that necessary maintenance is performed - (Reference Item(c),
(iii), Appendix N)
Sanctions against owner by denial of vehicle registration
and/or imposing fines.
Sanctions against repair facilities by imposing a fine and/or
loss of license.
Retesting failed vehicles.
Certification of repair facilities to ensure that they have the
proper equipment, necessary parts, and adequate knowledge for
emission control repair.
37
-------
Capital investment Per Station
-$3,000 - Cost of emission testing and auxilary equipment
Operations Throughput Time
-3.75 minutues
Mechanics Costs (including overhead)
-$18 per hour
Station inspection load factor capability - 10 percent. NOTE: In
the four county area with safety inspection stations the load factor
for emissions testing is about 3 percent.
Emissions.for statewide option were developed by extrapolating the
four county data.
Cost of capital is 6 percent for the state.
The state personnel benefits including sick leave, vacation, retire-
ment, insurance, holidays, etc., is 25 percent of base rate.
Fuel costs is $.70 per gallon.
Inflation rate is 7 percent. To convert from 1978 to 1983, a com-
pound factor of 1.403 must be used.
Indirect costs reflecting the cost to consumers for waiting time at
inspection lanes and cost of transportation to and from the inspection
and repair facilities were ignored.
Average miles traveled per year for LDVs is 11,500 miles per year.
Failed vehicles consumed 3.8 percent more fuel than the certified
vehicle.
Assumed miles per gallon fleet average for LDVs is 15 miles per
gallon (1982), 24 miles per gallon for 1987 LDVs.
38
-------
o Enforcement measures to ensure that vehicles are not intentionally
readjusted or modified after inspection. {Reference Item(c),(iv),
Appendix N).
Highway Patrol spot checks
Random Sampling Reinspection
The appendices provide information on the correlation of short tests to
the FTP, a glossary of terms relating to I/M program, and the reprints of
Federal Register Appendix N, and the memorandum from the United States EPA to
regional administrators.
Data utilized in this study were provided by the State of South Carolina
Department of Highway and Public Transportation. The data represent the most
current information available at the time of the study, it should be stressed,
however, that the methodology utilized in this study was derived from past
experiences with other I/M programs, and that the authors possess only a
superficial knowledge of the structure of the South Carolina State government.
The actual implementation of an I/M program for the State will require further
in-depth analysis to determine particular locations for test sites, emission
failure criteria, designated agency responsibilities, test station design and
other considerations.
A. ASSUMPTIONS
The methodology used in this Task 2 report was based upon the following
assumptions:
o The program operation is over a period of 10 years.
o The State would assume that cost of purchasing test equipment and
lease them to private garages.
o Vehicle Population Growth
1976 to 1982 - 4 percent
1982 to 1992 - 3.5 percent.
39
-------
Section 3
BACKGROUND TECHNICAL MEMORANDA
A. National Ambient Air Quality Standards
B. Nonattainment Areas for Photochemical Oxidants and Carbon Monoxide in the
State of South Carolina
C. Clean Air Act Amendment Requirements for I/M Programs
D. I/M Program Effectiveness in Reducing Hydrocarbon and Carbon Monoxide
Emissions from Light-Duty Vehicles
E. Testing Program with a 30 to 35 Percent Failure Rate
F. Administrative Program Options
G. Idle-Mode Test
40
-------
A. NATIONAL AMBIENT AIR QUALITY STANDARDS
1. Origin of the Standards
The basis for the development of the National Ambient Air Quality Standards
(NAAQS) was established by Congress through the Air Quality Act of 1967. The
Act, as originally adopted, required the Secretary of Health, Education and
Welfare to develop and issue criteria of air quality which were requisite for
the protection of the public health and welfare. Under the 1967 Act, the
states were then expected to develop air quality standards and plans for the
implementation of the standards. In May 1971, however, the EPA promulgated
national ambient air quality standards for six major pollutants. The Standards
as originally adopted are shown ih Table 3-1. In subsequent revisions to the
Standards by the EPA, secondary standards for certain pollutants were also
adopted. These secondary standards were established at levels deemed necessary
to protect the public welfare from any known or anticipated adverse effects of
a pollutant. The secondary standards were set to prevent harmful effects on
animals, vegetation, weather and visibility, and to preserve a certain "quality
of life." The current primary and secondary standards are given in Table 3-2.
The latest revisions to the NAAQS have resulted from the 1977 Amendments
to the Clean Air Act. Section 109 of the Act was amended to require the EPA to
establish an independent scientific committee to review air quality criteria
and the NAAQS not later than December 31, 1980 (at subsequent intervals not
exceeding 5 years), and recommend revisions in the criteria and standards as
may be appropriate. The EPA was also directed to promulgate short-term primary
standards for N02 (less than 3 hours within 1 year).
a. Health Effects of Air Pollutants
The major air pollutants which are of significance are characterized as
follows:
0 particulate matter is generally any matter (less than 500 microns),
whether solid or liquid, that is dispersed in the air. Studies
41
-------
Table 3-1.
NATIONAL AIR QUALITY STANDARDS
ESTABLISHED IN 1971
Level not to exceed
Pollutant
Mg/m3
ppm
SO,
Carbon monoxide
Particulate matter
Photochemical oxidants
Hydrocarbons
Nitrogen oxides
80*
365 b
75c
260b
I0d
40*
160e
160f
100*
9
35
0.03
0.14
0.08
0.24
0.05
aAnnual arithmetic mean.
bMaximum 24-hr concentration not to be exceeded
more than once a year.
c Annual geometric mean.
^Maximum 8-hr concentration not to be exceeded more
than once a year.
'Maximum 1-hr concentration not to be exceeded more
than once a year.
fMaximum 3-hr concentration (6-9 a.m.) not to be
exceeded more than once a year.
42
-------
Table 3-2.
FEDERAL AMBIENT AIR QUALITY STANDARDS
FEDERAL
POLLUTANT
AVERAGING
TIME
Primary
Secondary
Carbon
Monoxide
8 hrs
1 hr
9.0 ppm?
(10 mg/m )
35.0 ppm.
(41 mg/m)
Same as
primary
standards
Nonmethane
hydrocarbons
6-9 a.m.
0.24 ppn£
(160 xg/m )
Same as
primary
standards
Photochemical
oxidants
1 hr
0.08 ppm?
(160 *g/nT)
Same as
primary
standards
Nitrogen
dioxide
Annual
0.05 ppm-
(100 Mg/nT)
Same as
primary
standards
Particulate
Annual
geometric
Mean
75 fig/m3
60 Mg/m3
24 hrs
260 Mg/m3
150 Mg/m
Sulfur
dioxide
Annual
arithmetic
Mean
24 hrs
3 hrs
0.03 ppm-
(80 pg/uO
0.14 ppm-
(373 /xg/m )
0.02 ppm-
(53 Mg/m )
0.50 ppm,
(1334 ug/m )
aNot to be exceed more than one per year.
43
ppm --parts per mil7ion
mg/m^-nrilligrams per cubic meter
#g/m -micrograms per cubic meter
-------
indicate an association between particulate matter and certain
health effects, especially injury to the respiratory system. Other
problems associated with high concentrations of particulate matter
are impaired visibility, increased corrosion of some metals, and
damage to plants and vegetation.
Carbon monoxide (CO) emissions arise primarily from incomplete
combustion of carbonaceous fuels. Factors such as oxygen concentra-
tion, flame temperature, gas residence time, and combustion chamber
turbulence are important variables that affect the CO concentrations
in exhaust. Carbon monoxide is absorbed into the blood stream
within the respiratory tract and reacts primarily with the hemoglobin
in red blood cells. This decreases the oxygen-carrying capacity of
the blood reducing the amount of oxygen transported to vital tissues.
Hydrocarbons are primarily associated with processing and use of
petroleum products. They constitute the major portion of the
reactive organic substances that produce photochemical oxidant. The
only direct effect attributable to high ambient levels of hydrocarbons
(i.e., ethylene) is vegetation damage. Polynuclear hydrocarbons,
some of which are carcinogenic—such as benzo( ) pyrene— are primary
pollutants arising from a variety of combustion processes. Auto
exhaust is a major source of atmospheric polynuclear aromatic
hydrocarbons.
Photochemical oxidants are produced in the atmosphere when reactive
organic substances (mainly hydrocarbons) and nitrogen oxides are
exposed to sunlight. Ozone is the major reaction product of these
oxidants. Photochemical oxidants at certain concentrations can
cause irritation of the mucous memberances, damage to vegetation,
and deterioration of materials. They affect the clearance mechanism
of the lungs and alter resistance to respiratory bacterial infection.
Nitrogen oxides (NO^), namely nitrogen dioxide (N02) and nitric
oxide (NO), are formed during combustion processes in chemical
44
-------
reactions involving atmospheric nitrogen and fuel-bound nitrogen.
The amount formed depends on the temperature of both reactants and
products, and the length of time favorable conditions persist for
the oxygen-nitrogen reactions. Nitric oxide has not been shown to
have any adverse effects on health or welfare. However, there are
several atmospheric reactions which can lead to the oxidation of
nitric oxide to nitrogen dioxide, NO^. Nitrogen dioxide has been
associated with a variety of respiratory diseases and is also essen-
tial to the production of photochemical smog. Corrosion of electrical
components and vegetation damage have been linked to NO^ at high
concentrations.
o Sulfur dioxide (SOis'produced by the combustion of fuel in power-
generating facilities as well as in automobiles. The effects of SC>2
on health are related to irritation of the respiratory system at low
concentrations, destruction of the upper respiratory cilia carry
capacity at high concentrations, and reduction to viral resistance
in the presence of particulates. Research has also been conducted
to study the synergistic effects of particulates and SO^ in combina-
tion as related to corrosion damage.
Tables 3-3 through 3-6 describe in further detail the effects of air
pollutants.
45
-------
A. Biological Effects on Human Subjects
PoliuUnt
Effect
Single
concentration
Carbon monoxide
Epidemiological
significance
Discomfort
Severe distress
Lethal
30 ppm
900 ppm
100 ppm
100 ppm
4 000 ppm
Hydrocarbons
Inorganic
particulates
Pulmonary
sclerosis
Nitrogen
dioxide
Lethal
Mild accelerator
of lung tumors
500 ppm
Table 3-3.
EFFECTS OF AIR POLLUTION
Average
concentration
Exposure
Other
Refer-
ence
900 ppm
100 ppm
100 ppm
8 hours
1 hour
9 hours
] S hours
<1 hour
Synergistic
in PO, de-
pression
HC + O,-
tumorigen
S00 ppm 48 hours
NO, + micro-
organisms
(pneumonia)
+ HNO,
(bronchiolitis,
fibrosa obliterans)
+ Ian (smokers,
lung cancer)
-------
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
Pollutant
Effect
Singfe
concentration
Avenge
concentration
Expotuie
Othw
Refer-
ence
Ozone
it*
vj
Odor
Pulmonary
function
Discomfort
Mucosa
Severe distress
Histological
Other
<0.02-0.05
ppm
0.60-0.80 ppm
0.05-0.10 ppm
0.30-1.00 ppm
1.5-2.0 ppm
0.2-0.25 ppm
0.60-0.80 ppm
Instan-
taneous
120 min-
utes
13-30 min-
utes
15-60 i^n-
utes
120 min-
utes
30 minutes
120 min-
utes
Accelerated
aging
Reduction in
steady
state pul-
monary dif-
fusing
capacity
-------
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
Pollutant
Effect
Single
concentration
Avenge
concentration
Exposure
Other
Refec
ence
PAN"
Sulfur dioxide,
sulfur tri-
oxide
>£>
00
Total oxidant
Pulmonary
function
Odor
Taste
Epidemiological
significance
Pulmonary
function
Discomfort
Severe distress
Pulmonary
function
>0.30 ppm
5 minutes
0.5-0.7 ppm
0.3-0.1 ppm
0.20 ppm
1.6 ppm
5 ppm
5-10 ppm
0.015 ppm
0.138 (mean
of daily
maxima NKI)
I second
A few
seconds
24 hours
(annual
average)
10 minutes
10 min-
utes
(sensi-
tive
subjects)
1 week
Significant
increase In
oxygen up-
take during
light exercise
12
SO,. SO, +
particulates
aggravate
lung disease
13
13
13
13
13
14
-------
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
Pollutant
Effect
Single
concentration
Avenge
concentration
Exposure
Other
Refer-
ence
Suspended
particulate
and set lie-
able mailer
Epidemiological
significance
500 jig/rn'
24 hours
In presence
of 24-hour
August SO,
concentration of
O.IS ppm
18,19
4^
Suspended
particulate
and settle-
able matter
(Cont.)
Discomfort
Other
2:150 mg/m1
1.5 mg/cm'
24 hours
30 days
Continuous
source,
dustfall
Particles <5 jim
and concentration
>10 particles/
cm* do not
have com-
plete elim-
ination
from lungs
20
21
-------
B. Biological Effects on Animals
Pollutant Effect Subject
Nitrogen
dioxide
en
Q
Odor
Discomfort
Mucosa
Severe distress
Pathological
Lethal
Mice, rabbits,
cats
Mice, rabbits,
cats
Mice, rabbits,
cats
Mice
Man
Nitrogen Lethal Mice
oxide Mice
PAN" Lethal Mouse
Sulfur Lethal Rabbit
dioxide Central nervous Animal
system
Other Animals
Total Histological Mouse
oxidant Pathological Mouse
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
concentration concentration average
5 ppm 5 seconds 2
10-20 ppm
10-20 ppm *
20-100 ppm *
8 ppm 8 ppm 8 weeks 3
SOOppm 500 ppm 48 hours •
2 500 ppm 6-7 minutes 2
320 ppm 60 minutes 4
105 ppm 120 minutes s
50 ppm 30 days/6 hour day 6
0.20 ppm 10 seconds 6
several
times
1000 ppm 8-16 hours 100% kill 6
>0.40 ppm (NKI) 2-3 hours 7
0.40 (mean of 16 months 8
daily maxima
NKI)
-------
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
C. Biological Effects on Vegetation
Pollutant
Subject
Effect
Single
concentration
Avmft
concentration
Time of
average
Other
Reference
Nitrogen
dioxide
Plants
ui
Ozone
Plants
Peroxyacetyl
nitrate (PAN)
Sulfur dioxide
Plant*
Plant leaf
symptomi
3 ppm
2.5
4 houri
Palisade of leaf is affected. Growth
suppression and changes in pigmenta-
tion, such as Hecks, stippling, bleach-
ing, and bleached spotting, occur.
There is early abscission, and conifer
needles become brown and necrotic.
Time, 4 hours; concentration, 0.03
ppm. See References 11-21
Spongy cells of leaves are affected.
Glazing, silvering, or bronzing occurs
on the lower leaf surface. Time, 6
hours; average concentration, 0.01
ppm. See References 20, 21, 23, and
24
Plant leaf
symptom!
Plant
chlorosis
Plant growth
altered
>0.25 ppm
0.28 ppm
0.03 ppm
0.05-0.20 ppm
24 hours
Annual
average
24 hours;
for
Symptoms similar
to SO,. Ir-
regular, white,
or brown col-
lapsed lesion
on inter-
costal tissue
and near leaf
margin
9.10
Bleached spots,
bleached
areas between
veins, bleached
margin
Growth supprei-
slon, early
10, 26
10, 26
10, 26
-------
Table 3-3.
EFFECTS OF AIR POLLUTION (Continued)
p , Single Avenge Time of
Subject Effect concentration concentration average Other Reference
growing abscission,
Ktson reduction In
yield
Total oxidant Hants See Reference! 11,14-16,27 Affect! mcso-
phyll cell*
ui
to
REFERENCES
1. Air Pollution. A.C. Stern, Ed., Vol. 1, Academic Press, New York, N.Y., 1962.
2. Occupational Diseases, U.S. Public Health Service Publication 1097, p. SI.
3. F.A. Patty, Industrial Hygiene and Toxicology, Vol. 2, John Wiley i Sons, New York, N.Y., 1962.
4. California Standard! for Ambient Air Quality and Motor Vehicle Emissions, Department of Public Health, Bureau of
Air Sanitation, 1964.
5. E.J. Largent, Fluorosis. Ohio State University Press, 1961.
6. A. Hcnschler eta)., Archiv ftir GewerbepatholgieundGewerbehygiene. 17:547, I960.
7. W.W. Witheridge and C.P. Yaglou,/ Amer. Soc. Heat. Vent. Eng.. 45:509, 1939.
8. W.A. Young, D.B. Shaw,and D.V. Bates,/. Appl. PhysioL. 19:765, 1964.
9. S. Wilska, Acta Chem. Scand.. S:359, 1951.
10. S.S. Griswold, L.A. Chambers, and H.L. Motley, Arch. !nd. Health, IS: 108, 19S7.
11. R. flrinkman, H.B. Lamberts, and T.S. Veninga, Lancet. 7325:133, January 18, 1964.
12. L.E. Smith, Arch. Environ. Health, 10:161, February 1965.
13. Air Quality Criteria for Sulfur Oxides. U.S. Public Health Service Publication 1619, 1967.
14. J.E. Remitters and O.J. Balchum, Paper 65-4 3, Presented at the 58th Annual Meeting of the Air Pollution Control
Association, June, 1965, Toronto, Canada.
15. K.A. Bushtueva, in Limits of Allowable Concentrations of Atmospheric Pollutants, V.A. Rayatonov, Ed., Book 3,
U.S. Department of Commerce, Washington, D C., 1957.
16. M.O. Amdur, L. Silverman, and P. Drinker, AM A Arch. lad. Hyg. Occup. Med., /6.305,1952.
17. M.O. Amdur etaL, Ann. Occup. Hyg., J: 71,1961.
IS. A.F. Martin, Proc. Roy. Soc. Med. (London), 57:969, 1964.
19. J.L. Burn and J. Pemberton, Int. J. Air Water Pollut. (London), 7:5,1963.
20. To Control Local Air Pollution from Sources of Particulate or Gaseous Matter Emissions. Regulation IV,
Commonwealth of Pennsylvania, Department of Health, Harrisburg, Pa., Adopted March 15, 1966.
21. C.N. Davis, Brit. Med. Bull., 19:49,1963.
-------
Table 3-4.
VISUAL RANGE IN A POLLUTED ATMOSPHERE
Relation Between Equivalent Visual Range
and Particle Concentration
Scattering
Equivalent
Equivalent
Mas
coefficient
visual
visual
concentra-
due to aerosol.
nnge.
range.
tion, Mg/ms
bjcat/m
km
mies
10
0.3 i 10"
120.0
75.00
30
1.0 x 10-*
40.0
25.00
100
3.3 x 10-"
12.0
7.50
300
10.0 x 10-4
4.0
2-50
1 000
33.0 x lO"4
1.2
0.75
Note: These
experimental
data are in
substantial
agreement with other reported measurements; see Air
Quality Criteria for Particulate Matter, AP-49, National Air
Pollution Control Administration, January 1969.
Source: R. J. Charlson, "Atmospheric Aerosol Research
at the University of Washington," J. Air Poliut. Contr.
Aon., /*:652, 1968.
53
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Table 3-5.
AIR POLLUTION DAMAGE TO VARIOUS MATERIALS
Material*
Metals
un
Building
materials
Paint
Leather
Paper
Textiles
Dyes
Rubber
Ceramics
Typical manifestation
Spoilage of surface,
low of metal,
tarnishing
Discoloration,
leaching
Discoloration,
softened finish
Powdered surface,
weakening
Embrittlement
Reduced tensile
strength, spotting
Fading
Cracking, weakening
Changed surface
appearance
Measurement
Weight gain of corrosion
products, weight loss after
removal of corrosion
products, reduced physical
strength, changed reflec-
tivity or conductivity
Not usually measured
quantitatively
Not usually measured
quantitatively
Observation, loss of tensile
strength
Decreased folding resistance
Reduced tensile strength,
altered fluidity
Fading by reflectance
measurements
Loss in elasticity, increase
in depth of cracks when
under tension
Changed reflectance mea-
surements
Principal air
pollutant
SO,, acid gases
SO,, acid gases,
sticky particu-
lates
SO,, II, S, sticky
particulates
SO,, acid gases
SO,, acid gases
SO,, acid gases
NO,, oxidants,
SO,
Oxidants, O,
Acid gases
Other environ-
mental factors
Moisture,
temperature
Moisture,
freezing
Moisture,
fungus
Physcial wear
Sunlight
Moisture, sun-
light, fungus
Sunlight,
moisture
Sunlight
Moisture'
Source: J.E. Yocom and R.O. McCaldin, in Air Pollution, A. C. Stern, lid.. Vol. I, Academic Press, New York, N.Y., 1966, p. 624.
-------
Table 3-6.
ADDED COSTS OF LIVING IN DIRTY ENVIRONMENT
Downtown Steubenville. Ohio, 383 lajm3
Venus Uniontown, Pa., 115 jig/m
Particulates for 28 Activities, 1960
Extra cost
per family
Income
Do-it-
Non-do-it-
group3
youneif
yourself
Inside
A
$ 29
$162
maintenance
B
44
227
Outside
A
21
49
maintenance
B
337
368
Laundry and
A
27
79
cleaning
B
129
186
Haii and
facial care
9
48.
Totals, per family
In private homes
A
86
338
B
519
829
In apartments
A
47
263
(no inside painting or
B
158
423
decorating, no outside
maintenance)
¦A—Annual income under S8 000.
B— Annual income, iS 000 or more.
Source: Interstate Air Pollution Study. U.S. Department of Health, Education,
and Welfare, Robert A. Taft Sanitary Engineering Center, Cincinnati, O., 1966..
55
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B. NONATTAINMENT AREAS FOR PHOTOCHEMICAL OXIDANTS AND CARBON MONOXIDE IN THE
STATE OF SOUTH CAROLINA
Recently, the South Carolina Environmental Protection Agency had identi-
fied two geographic areas as air quality nonattainment regions. The first
geographic area, located in central South Carolina, includes Richland and
Lexington Counties (Figure 3-1). This area was developed using measured
oxidant data from existing monitors in Richland, and then extrapolated to
Lexington County. The CO problem is localized within the boundaries of Richland
County.
The second geographic area, identified as an oxidant nonattainment region,
includes Charleston and Berkeley Counties. This area was not developed from
air quality data, but rather was identified by the EPA using population cri-
terion such that any metropolitan area with a population exceeding 200,000 is
considered as a nonattainment area.
55
-------
en
-J
Figure 3-1.
NONATTAINMENT GEOGRAPHIC AREAS
OF THE STATE OF SOUTH CAROLINA
SOUTH CAROLINA
COUNTY OUTLINE MAP
t c MTATT Mtttwur
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C. CLEAN AIR ACT AMENDMENT REQUIREMENTS FOR I/M PROGRAM
The passage of the 1977 Amendments to the Clean Air Act {CAAA) has brought
about a number of new requirements for the control of air pollutant emissions
from automobiles. Among the most important of these requirements is the idea
that vehicles should maintain their lowest feasible emission levels throughout
their lifetime. To attain this goal, the Act now specifies provisions for
motor vehicle emission I/M programs. The purpose of this technical memorandum
is to summarize the specifications of the CAAA with regard to I/M and forecast
the implications of these specifications on the planning duties of the relevant
environmental protection agencies.
1. CAAA Requirements
The CAAA include many specifications for the revision of State Implemen-
tation Plans (SIPs) and, in particular, call for the inclusion of transporta-
tion control measures which are necessary to attain and maintain National
Ambient Air Quality Standards. Motor vehicle I/M programs have been shown to
provide important emission reduction benefits and, hence, deserve attention as
a potential transportation emission control measure for many areas throughout
the country. This potential is recognized in the CAAA. Section 108 of the Act
was amended to require the EPA to publish information regarding processes,
procedures, and methods for implementing I/M programs. The EPA has fulfilled
this charter through the publication of "Information Document on Automobile
Emissions Inspection and Maintenance Programs" (Ref. 1).
More significant, perhaps, are the CAAA requirements for nonattainment
areas and their inclusion in SIPs. Each state in which there are any nonattain-
ment areas must submit a revised SIP by December 31, 1979 which provides for
attainment of ambient air quality standards by December 31, i982. In areas
which demonstrate that the standards for oxidant or CO cannot be met by
December 31, 1982, an extension to December 31, 1987 can be granted. Two of
the many requirements for this extension are that an updated SIP revision must
be submitted before July 1, 1962, and that a specific schedule for implemen-
tation of an I/M program be established. The EPA has also established the
58
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general requirements for I/M programs in a February 24, 1978 memorandum from
the EPA Administrator to the Regional Administrators (reprinted in the Federal
Register on May 19, 1978, 43 F.R. 21673).
In producing an I/M SIP revision, states must provide for:
1. An analysis of the benefits and costs of the program,
2. A public information effort,
3. A legislative proposal, and
4. A schedule for I/M implementation.
Before January 1, 1979, an SIP revision must be adopted by the state air
pollution control board or agency head, as appropriate. As a part of the SIP
revision submittal itself, there must be a commitment by the Governor to
implement the I/M program according to the schedule submitted.
"Normally, adequate legal authority to implement a SIP revision must exist
for a revision to be approved. Where a legislature has had adequate oppor-
tunity to adopt enabling legislation before January 1, 1979, the Regional
Administrator should require certification that adequate legal authority exists
for I/M implementation by January 1, 1979. However, for many states there will
be insufficient opportunity to obtain adequate legal authority before their
legislatures meet in early 1979. Therefore, a certification of legal authority
for the implementation in these states must be made no later than June 30,
1979. An extension to July 1, 1980, is possible, but only when the state can
demonstrate that a) there was insufficient opportunity to conduct necessary
technical analyses and/or b) the legislature has had no opportunity to consider
any necessary enabling legislation for inspection/maintenance between enactment
of the 1977 Amendments to the Act and June 30, 1979. Certification of adequate
legal authority, or other evidence that legal authority has been adopted, must
be submitted to the EPA Regional Offices to be included in the SIP revision
already submitted. Failure to submit evidence of legal authority by the
appropriate deadline will constitute a failure to submit an essential element
of the SIP, under Sections 110(a)(2)(I) and 176(a) of the Act.
59
-------
Prior to the respective deadlines for initiating mandatory inspection and
mandatory repair of failed vehicles, the state, local government, or regional
agency should adopt whatever legally enforceable requirements are necessary to
ensure that vehicles are not used unless they comply with the inspection/
maintenance requirements. Written evidence of adoption of these requirements
should be submitted to the EPA Regional Offices, to be included in the SIP
revision already submitted by January 1, 1979" (see Appendix A).
"Implementation of I/M 'as expeditiously as practicable" shall be defined
as implementation of mandatory repair for failed vehicles no later than
2-1/2 years' after passage of needed legislation or certification of adequate
legal authority for new centralized systems (State- or Contractor-operated) and
1-1/2 years after legislation or certification for decentralized systems
(private garage-operated) or for centralized systems which are adding emission
inspections to safety inspections. For the normal legislation deadline of
June 30, 1979, new centralized programs must start by December 31, 1981, and
all others must start by December 31, 1980. For the case of the latest possible
legislation date, July 1, 1980, this means that a new centralized program must
start by December 31, 1982, while all other programs must start by December 31,
1981. Where I/M can be implemented more expeditiously, it must be. Each state
implementation schedule must be looked at individually to determine if it is as
expeditious as practicable. Implementation dates ordered by courts, if earlier
than these dates, take precedence" (see Appendix A).
The Emission Control System Performance Warranty contained in Section 207(b)
of the Clean Air Act provides warranty coverage to motorists in areas having an
I/M program. The Emission Performance Warranty, upon promulgation of regulation
by the EPA, will require the automobile manufacturer to bear the cost of repair
of any properly maintained and operated vehicle which fails an EPA established
emissions test within 24 months or 24,000 miles, whichever occurs first, of the
original sale to the ultimate purchaser. After this period, the warranty
applies only to catalytic converters, thermal reactors, or other components
installed on or in a vehicle for the sole or primary purpose of reducing
vehicle emissions.
60
-------
The CAAA extended the coverage of Section 203 of the Clean Air Act to
prohibit the removal of, or tampering with, emission control equipment by
independent auto repair operators. Civil penalties of $2,500 for such actions
were also established.
2. Potential EPA Sanctions
There are sanctions for noncompliance with I/M requirements such that a
state will lose its highway funds (except for transit-, safety-, or air quality-
related transportation projects) if the Governor has not submitted an SIP
revision by July 1, 1979, or that reasonable efforts toward submitting such a
SIP are not being made (this also applies to the 1982 SIP revision). If state
or local governments are not implementing an SIP, they cannot receive any
grants under the Act. There is a requirement for Federal agencies not to take
any action including making any grant that does not conform to an approved SIP,
nor can any transportation planning agency give approval to anything which does
not conform to the SIP. Priority must be given for programs with air quality-
related transportation consequences to the implementation of SIPs necessary to
achieve and maintain air quality standards.
61
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D. I/M PROGRAM EFFECTIVENESS IN REDUCING HYDROCARBON AND CARBON MONOXIDE
EMISSIONS FROM LIGHT-DUTY VEHICLES
Inspection and maintenance of light-duty vehicles has been shown to
produce significant reductions in emissions of carbon monoxide (CO) and hydro-
carbons (HC). Since mobile sources are usually the major contributors to CO
and HC emissions in an urban area, the emission reductions produced by an I/M
program can be translated into beneficial improvements in the region's air
quality.
1. remission Reduction Potential
The potential benefits which can result from an I/M program depend on a
number of factors. The most important of these factors deals -with I/M emission
standards, or "cut points." The cut point is the level of emissions which
distinguishes between those vehicles requiring emissions-related maintenance
and those that do not. The cut points that are selected define a "stringency
factor" which is a measure of the rigor of the program based on the estimated
fraction of the vehicle population whose emissions would exceed cut points for
either or both CO and HC. There are two basic concerns that constrain the
selection of I/M emission standards. As mentioned previously, the I/M emis-
sion standards determine the emission reduction potential. As such, I/M stand-
ards or cut points should be set to achieve a desired emission reduction. On
the other end, the cut point should be limited to a level that will be
acceptable to both the general public and the repair industry. As experienced
by other programs, negative public sentiments may result if an excessive
volume of vehicles do not comply with I/M standards at first inspection.
Further difficulties will arise if the total of the noncomplying vehicles
exceed the available capacity of the repair industry. The necessary vehicle
maintenance will be compromised under these conditions. Cut points must be
set at a level where potential emission reduction benefits are maximized while
impacts to the public are minimized. Detailed discussion of the stringency
factor is given in Technical Memorandum E.
The air quality benefit from an I/M program is also dependent, in part,
on the ability of the service industry to properly perform the repair work
62
-------
necessary to lower emissions. Depending on the level of service industry
training, emissions could be reduced just to the levels which would pass the
I/M test or well below them. Some savings in repair costs may also result
from the training since the mechanics would be familiar with the problems and
the best solutions.
The total emission reductions that result from the program are directly
dependent on the number and types of vehicles inspected and the requirement
that maintenance be performed. I/M programs are generally designed around
automobiles and other light-duty vehicles; however, motorcycles and heavy-duty
trucks can also be included to provide additional emission reductions. In
some cases, it may be desirable not to require repairs on old cars when the
repair work would cost a major percentage of the car's value.
Frequency of testing also can affect the emission benefit scenario. Most
existing I/M programs require annual inspection. This frequency is justified
on the basis that it minimizes costs and maximizes public acceptance while
maintaining a reasonably high level of emission reduction. A semi-annual
program would involve substantially higher program costs arising from the need
for a greater number of inspection lanes, as compared to an annual inspection
program. Semi-annual inspections may be justified for higher usage vehicles,
such as taxis, however. A bi-annual program, while certainly providing some
emission benefits, will lose some of the effectiveness of an annual program
because cars are allowed to deteriorate to a higher level.
The definitive statement on potential emission reductions from an I/M
program appears in the Code of Federal Regulation under the title of "Appen-
dix N—Emissions Reductions Achievable Through Inspection, Maintenance and
Retrofit of Light-Duty Vehicles" (see Appendix C).
2. Results of California Study
The California Air Resources Board (ARB) has conducted a number of study
efforts to determine the emission-reduction potential of various I/M programs.
63
-------
In May of 1976, results of these studies were published. The results of
these studies indicated that those vehicles which were repaired under the idle
I/M regime achieved immediate reductions of 38 percent in HC emissions and
33 percent in CO emission (see Tables 3-7,and 3-8). When these reductions are
deteriorated over 1 year's time and distributed over the total vehicle popula-
tion, the reductions are 9 percent HC and 8 percent CO.
These results generally agree with those obtained in other studies per-
formed by and for the U.S. EPA and the ARB (see Table 3—9).
Table 3-9. COMPARISON OF EMISSIONS AND FUEL CONSUMPTIONS
REDUCTIONS AND REPAIR COSTS WITH OTHER STUDIES
IMMEDIATE REDUCTIONS - FAILED VEHICLES ASSUMED
IDLE REGIME HC CO NO^ Fuel Consumption FAILURE RATE
California Study (Ref. 2) 38% 33% 4.2% 3.8% 35%
Northrop (Ref. 3) 40% 37% -13% - 50%
EPA (Ref. 4) 42% 34% 5.0% - 50%
Olson (Ref. 15) 38% 29% -7.3% 3.0% 50%
A study made by the Northrop Corporation for the ARB in 1971 showed
emissions reductions comparable to those in this study while using a 50 per-
cent failure rate.
64
-------
Table 3-7. HYDROCARBONS EMISSION REDUCTION
IDLE REGIME (REF. 2)
AVERAGE
MOTOR VEHICLE CLASSIFICATION GM/MI
A. Without Deterioration:
Pass * 4.02
Fail (Before Repair)** 7.21
Fail (After Repair)** 4.46
Immediate Reduction 2.75
% Decrease (Failed Vehicles)" 38.19
Total Population
Without MVIP 5.14
With MVIP 4.17
% Decrease 18.76
B. With Deterioration:
Total Population
Without MVIP 5.14
With MVIP 4.66
% Decrease 9.38
~Passed all Standards
**Failed one or more Standards
65
-------
Table 3-8. CARBON MONOXIDE EMISSION REDUCTION
IDLE REGIME (REF. 2)
AVERAGE
MOTOR VEHICLE CLASSIFICATION GM/MI
A. Without Deterioration:
Pass * 41>69
Fail (Before Repair)** 65.42
Fail (After Repair)** 43.94
Immediate Reduction
% Decrease (Failed Vehicles)
Total Population
Without MVIP
With MVIP
% Decrease
B. With Deterioration:
Total Population
Without MVIP
With MVIP
% Decrease
21.48
32.84
49.99
42.47
15.04
49.99
46.23
7.52
~Passed all Standards
**Failed one or more Standards
66
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E. TESTING PROGRAM WITH A 30 TO 35 PERCENT FAILURE RATE
1. Introduction
This section addresses an emission testing program with a 30 to 35 percent
failure rate. The percent failure rate is normally referred to as stringency
factor.
A stringency factor is defined as "a measure of the rigor of a program
based on the estimated fraction of the vehicle population whose emissions
would exceed cut points for either or both CO and HC if there were no improve-
ment in habits or maintenance quality to take place as a result of the program."
During the first year of program operation, the Appendix N credits allows
certain percentage of reductions in HC and CO for stringency factors of from
0.10 to 0.50 as noted in Tables 3-10 and 3-11 (Ref. 6) .
Table 3-10. FIRST YEAR PERCENT OF EMISSION REDUCTION OF HYDROCARBONS
THROUGH I/M PROGRAMS
FIRST YEAR
VEHICLE TYPE ADDITIONAL BENEFITS
Mechanics Training Semi-
STRIN-
GENCY
FACTOR
Tech-
nology
Ia
Tech-
nolggy
Motorcycles
and LDT
HDT
Tech-
nology
I
Tech-
nology
II
annual
Inspec-
tion
o
•
O
1
1
1
1
3
0.2
0.20
5
3
5
11.4
3
5
0.2
0.30
7
9
7
12.3
4
4
0.2
0.40
10
16
10
15.6
6
1
0.2
0.50
11
24
11
17.2
7
1
0.2
aLight-duty vehicles subjected to pre-1975 Federal emission standards.
Vehicles subject to 1975 and later model-year Federal emission standards.
67
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Table 3-11. FIRST YEAR PERCENT EMISSION REDUCTION OF CARBON
MONOXIDE THROUGH I/M PROGRAMS
FIRST YEAR
VEHICLE TYPE
STRIN-
GENCY
FACTOR
Tech-
nology
I
Tech-
nology
II
Motorcycles
and LDT
HDT
ADDITIONAL BENEFITS
Mechanics Training
Tech-
nology
I
Tech-
nology
II
Semi-
annual
Inspec-
tion
0.10
3
8
3
5
7
0.2
0.20
8
20
8
8.3
7
10
0.2
0.30
13
28
13
9.2
9
10
0.2
0.40
19
33
19
10.5
8
7
0.2
0.50
22
37
22
12.9
7
5
0.2
Subsequent years inspection credits and additional credits for mechanics
training are set forth in Tables 3-12 and 3-13 (Ref. 2).
Table 3-12. SUBSEQUENT YEARS PROGRAM CREDITS FOR HC
ADDITIONAL BENEFITS
Additive Credit HC (Percent)
NUMBER
ADDITIVE
STRIN-
Technology I
OF
CREDIT HC
GENCY
Inspections
INSPECTIONS
(PERCENT)
FACTOR
2
3 or more
2
7
0.10
3
15
3
14
0.20
4
10
4
20
0.30
6
9
5
25
0.40
5
5
6
30
0.50
3
3
7
33
8 or more
36
Technology II
Inspections
2 or more
10
8
2
1
1
68
-------
Table 3-13. SUBSEQUENT YEARS PROGRAM CREDITS FOR CO
ADDITIONAL BENEFITS
Additive Credit CO (Percent)
Mechanics Training
NUMBER
ADDITIVE
STRIN-
Technology I
Technology II
OF
CREDIT CO
GENCY
Inspections
Inspections
INSPECTIONS
(PERCENT)
FACTOR
2
3 or more
2 or more
2
8
0.10
3
13
4
3
15
0.20
8
15
2
4
19
0.30
5
9
1
5
23
0.40
5
5
3
6
27
0.50
2
2
1
7
30
8 or more
35
It is to be noted that Appendix N states that, for a viable program of
benefit credits for a stringency factor at any level, it is necessary that the
following activities must be initiated:
o Provisions for regular periodic inspection of all vehicles for which
emissions reduction are claimed.
o Provisions for the establishment of inspection failure criteria
consistent with the claimed reductions.
o Provisions to ensure that necessary vehicles receive the maintenance
necessary to achieve compliance with the inspection standards. This
might include sanctions against individual owners or repair facil-
ities, retest of failed vehicles following maintenance, a certifica-
tion program to ensure that repair facilities performing the required
maintenance have the necessary equipment, parts and knowledge to
perform the tasks satisfactorily, a program to train mechanics,
and/or other measures.
o A program of enforcement to ensure that vehicles are not intention-
ally readjusted or modified subsequent to the I/M in such a way as
would cause them to no longer comply with the inspection standards.
This might include spot-checks of idle adjustments and/or a suitable
type of physical tagging.
69
-------
2. Emissions Percentages Appendix N Allowable for a 30 to 35 Percent
Stringency Factor
The first year allowable minimum/maximum percentage reduction of emissions
for 30 to 35 percent as developed from Tables 3-10, 3-11, 3-12, and 3-13 is
presented in Tables 3-14 and 3-15 for I/M program implementation.
Table 3-14. FIRST YEAR PERCENT EMISSION REDUCTION OF HC FOR LDV I/M PROGRAM
MINIMUM MAXIMUM
STRINGENCY Technology Technology Technology Technology
FACTOR I II I II
30 7 9 11.2 13.2
35 8.5 12.5 13.7 16.4
Table 3-15. FIRST YEAR PERCENT EMISSION REDUCTIONS OF CO FOR LDV I/M PROGRAM
MINIMUM MAXIMUM
STRINGENCY Technology Technology Technology Technology
FACTOR I I1 I II
30 13 28 22.2 38.2
35 16 30.5 24.7 39.2
Therefore, under an I/M program with a 30 to 35 percent failure rate, the
first year emission reduction is between 7 to 16.4 percent for HC, and 13 to
39.2 percent for CO, depending upon the details of the test program. For the
subsequential years, it increases in direct proportion to the number of years
the inspections continued.
3- Repair Cost Per Service Vehicle Under Various Stringent
The average cost of repair as noted in Figure 3-2 decreases with an
increase of the stringency factor. This decrease in average cost is the
result of the maintenance status of the vehicle 4- 4.x.
¦ie due to the age of the vehicle.
The older the vehicle the higher the cost of repairs
70
-------
CALIFORNIA AND MICHIGAN IDLE TEST DATA
Controlled Vehicle*
Uncontrolled Vehiclek
20 30 40 50
REJECTION RATE (%)
20 30 40 50
REJECTION RATE <%)
COST PER SERVICED VEHICLE ($)
Controlled Vehicle - vehicle manufactured after year 1968.
"Uncontrolled Vehicle - vehicle manufactured before year 1968.
Figure 3-2. AVERAGE VEHICLE REPAIR COSTS (REF. 7)
71
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4. Emission Reduction Versus Rejection Rate
Figure 3-3 from the Olson Laboratories' California and Michigan study,
present emission reductions as a function of failure rate. As shown emission
reductions increase with failure rate.
5. Station Requirements with Varying Failure Rates
The station requirements for testing will increase if a retest is required.
Figure 3-4 presents flow sequences for various inspection/service levels. The
following illustration presents output rates of a single-lane station for
various stringency factors.
Vehicles
Tested
per
Year
40
30
20
32,800
25,200
24,300
10
LL
10 20 30 40 50
Percent Failure Rejection
The above data is based upon a 3.5~minute throughput rate for an idle
test, an 8-hour day, 40-hour week, 52 weeks out of the year, and with a 92 per_
cent efficiency factor and the retest of those cars that were failed.
6- Idle Regime Standards for amissions Surveillanno
The standards for a failure rata of 35 percent of the vehicle population,
based upon an idl. test of mora than 12.000 oars by the state of California,
are presented in Table 3-16.
72
-------
CONTROLLED
VEHICLES
CALIFORNIA AND MICHIGAN 1975 CVS OATA
IDLE TEST
UNCONTROLLED
VEHICLES
IDLE
OJ>-&
tOuO—-
- - -OJ3 ""£>
X-L
20 30 40 50
REJECTION RATE (%) "
10 20 30 40 50
REJECTION RATE (*)
60
Figure 3-3.
EMISSION REDUCTIONS AS A FUNCTION OF REJECTION RATE
73
-------
1. Test for fail/pass and repair no retest
2. Test for fail/pass, repair and retest
3. Test for fail/pass, repair, retest and repair
4. Test for fail/pass, repair, retest, repair,
¦I
S5)SrCMSCO!*TIKH,MC -
ENVIRONMENTAL ENGINEERING Division
-------
Table 3-16. IDLE REGIME STANDARDS FOR 35 PERCENT FAILURE REJECTION
MORE THAN 4 CYLINDERS
TYPE 4 CYLINDERS OR LESS
MODEL YEAR CONTROL HC CO HC CO
(gm/mi){gm/mi)(gm/mi)(gm/mi)
1955-1965 (domestic)
1955-1967 (import)
1966-1970 (domestic)
1968-1970 (import)
1966-1970 (domestic)
1968-1970 (import)
1971 and later
1971 and later
aAI = Air injection.
Source: Reference 1.
None 1,200
Ala 350
Other 500
AI 200
Other 350
8.0 1,800 8.0
4.5 350 3.0
6.0 600 6.0
3.0 275 3.0
4.5 400 5.0
75
-------
F. ADMINISTRATIVE PROGRAM OPTIONS
This section presents background documentation on I/M administrative
alternatives proposed by the South Carolina DHPT. These alternatives con-
sidered are:
o Government-operated
o Contractor-operated
o Private garage-operated
Much of the following information was compiled from past and current I/M
studies. The intent was to provide South Carolina with adequate decision-
makers necessary to evaluate the proposed alternatives.
This section is organized into four parts:
o Administrative Options Defined
o General Background Information
o Qualitative Comparisons
o Functional Comparisons
The first two parts carefully define the administrative options and
provide in-depth analysis of each alternative using past I/M studies. The
remaining two parts compare each option by identifying specific responsibil-
ities, roles, and functional relationships.
I. Administrative Options Defined
The three alternative administrative options characterizes the opera-
tional format of the inspection phase of an I/M program. In each case, private
service garages and dealerships comprising the automobile repair industry will
participate in the maintenance phase. Conceptionally, the selection of a
specific configuration should not have an impact on I/M program emissions
effectiveness. However, the administrative option does have substantial
effects on capital and operational costing expenditures, quality assurance,
enforcement, etc.
76
-------
a. Government-Operated
Under a government-operated program, a designated agency at either the
state or municiple levels would assume complete managerial and operational
control of a centralized system of publicly owned facilities.
b. Contractor-Operated
A contractor-operated program is an arrangement whereby a corporation,
selected through a competitive bid process, assumes operational responsibility
for emission inspection at centralized test facilities. Administrative control
is still under the responsibility of a public authority.
c. Private Garage-Operated
Under a private garage-operated program, a public authority would certify
and license selected private establishments (e.g.; service garages, dealerships,
and independents) to perform emission and safety inspections. This would
provide a network of decentralized inspection and repair facilities.
2. Background Information on Current I/M Programs
Available background information on I/M programs throughout the country
are summarized in Table 3-17. Each I/M program is classified as either state-
, contractor-, or private garage-operated. For each program type, detailed
information such as responsible agency, number of vehicles serviced, stringency
factors, emission test, facility site, and estimated costing data (i.e.;
capital, operation, inspection cost) are provided under appropriate headings.
Govenment I/M programs can be further subdivided into either state or
municipally-owned/operated programs. New Jersey operates a state program that
annually idle tests 3.9 million light-duty vehicles (LDVs) at 38 station (62
lane capacity). This requires $2.5 and $1.3 million dollars in capital and
operating costs, respectively.
77
-------
Table 3-17.
EXISTING I/M PROGRAM SUMMARY
PROGRAM TYPE
STATE
ADMINISTRATIVE
AGENCY
VEHICLE POP
(Millions)
TEST MODE AND
STRINGENCY*
STATION STATUS
L.D.V. H.D.V. #Lanes #Sta. Mobile
POST (Millions
Capital"
$ !fr)
Operating" INSPECTION FEE
I. GOVERNMENT
A. State
CD
B. Municipal
II. CONTRACTOR
III.
PRIVATE
GARAGE
New Jersey
^ c
Oregon
Portland
Ohio,
Cincinnati
Illinois,
Chicago
Arizona,9
Maricopa
and Pima
counties
Nevada
(Clark
Co. only)
Rhode
Island
DMV - EPA
Dept. of
Environ. Qual.
Cincinnati
APCD*3
Chicago Dept.
Env. Control
Ariz. Dept./
Health Ser.
Dept. Motor
Vehicles and
Dept. Human
Resources
Dept. of Trans-
portation
3.9 LDVb
0.55 LDVs
(biennial)
0.2 LDVs
1.1 LDVb
1.1 cars,
trucks, and
motorcycles
0.20 LDVs
0.5 LDVB
Idle
23%
Idle
40%
Idle
30%
Idle
30-35%
Idleh
30%
Idle
NA
NA
NA
62
14
10
38
7
1
1
None
EPA
City
NA
36 12
218 Licensed
Private Stations
Idle
30%
NA 923 Private Garages
+ 1 State-Operated
challenge lane
52.50 (1972) +
$0.38 Leased
facil. (1975)
$0,013 safety
facil.
$2.0 (1973)
$10.5
$1.33
$2.22
$3.50 including
safety
$5
$0.13 for $3.75 including
sa fety
$1.45 (1977) Freee,f
$4.0
$0.17 (1974)
$1.00 (1977)
$0.43
approx.
(1974)
Part of
Capital cost
1st year
$5
$10.00-$33.00
(including
adjustments)
?4
Percent of vehicle failing to meet established standards.
bCost data defined per particular year. To upgrade costs to present year multiply by appropriate inflation factor.
CState of Oregon, Oregon Environmental Quality Commission - "Report to the Oregon Legislature on the Motor Vehicle Emission Testing Program,"
January 14, 1977.
^Air Pollution Control Department.
elncluded as part of the registration fee.
^Chicago's program costs are covered by a city sticker fee.
Definitions) DMV - Department of Motor Vehicles.
LDV - Light-Duty Vehicle (GVW <6501 lb.).
IIDV - Heavy-Outy Vehicle (GVW >8500 lb.).
9State of Arizona, Bureau of Vehicular Emissions Inspections - "Tune-up for Less Emission - It's Morking Arizona Vehicular Emissions Inspection
Program Operations", 1977.
hLoaded test with only idle fail/pass standards.
-------
Municipally-operated programs are found in Ohio (Cincinnati), Oregon
(Portland), and Illinois (Chicago). These programs annually inspect 0.2 to
1.1 million vehicles. Ohio has only one station, but intends to expand the
program later. Illinois currently operate five 2-lane capacity test stations.
In addition, Illinois operates 6 mobile test units. Illinois expenditures are
$20 million for capital costs and $1.45 million annaul operating expenses.
The only contractor-owned/operated program is located in Arizona (Maricopa
and Pima Counties). The 12 test stations annually process an estimated 1.1 mil-
lion cars, trucks, and motorcycles using 30 percent stringency factor with
idle test requirements. Capital cost expenditures are estimated al0.5 $9 mil-
lion with annual operating costs approaching $4.0 million.
After a 2-year (Phase I) feasibility pilot program (Refs. 9 and 10); on
March 1, 1979 California implemented a change of ownership program operated by
a private contractor (Phase II). This contractor-administered program operates
78 testing facilities at an estimated $12 million in capital outlay, and
$22 million (1978 dollars) in capital costs (Ref. 1). The inspection fee is
$11.00.
At present, Nevada and Rhode Island are the only states that have private
garage-operated I/M programs. Rhode Island has an extensive program, testing
0.5 million vehicles at 923 certified private garages. The Nevada program is
comparatively smaller, licensing only 218 garages to test 200,000 vehicles.
As expected, the capital cost expenditures for Rhode Island is quite large
compared to Nevada. Unexpectedly, the cost to the motorist is quite high for
Nevada ($10.00 to $33.00) compared to Rhode Island ($4.00). However, the
Nevada program does have vehicle adjustment included on the test requirements.
For each I/M program type, typical problems encountered during implementa-
tion and their subsequent solutions are shown in Table 3-18. Additional
information includes representative achievements for each state I/M program.
79
-------
Table 3-18.
TYPICAL I/M PROBLEMS, SOLUTIONS AND ACHIEVEMENTS
PROGRAM TYPE
STATE & RESPONSIBLE AGENCY
PROBLEMS
SOLUTIONS
ACHIEVEMENTS
I.
A.
GOVERNMENT-
OPERATED
S ta te-Ope rated
California
New Jersey
CD
O
Oregon
Portland
Municipal-
Operated
Illinois
Chicago
. (Pilot Program)
Minimal Problems
.2-Year Exemption for New Cars
.Lack Operating Capital
Capacity Improvements Cannot be
Made
.DMV Resistant to Increased Re-
failure Rate Expected in
Phase III standards (23%)
.Refailure Rate is 25%
.Biennial Inspection Lowers
Program Effectiveness, Created
Cash Flow and Personnel Problems
.Tampering
.Low Throughput
.Inadequate Enforcement
.No Phase-In Period and No P.R.
Program
•Mechanics Inadequately Trained
.Less Than 20% of Registered
Vehicles Have Been Inspected
.Legislation Pending
.Funding Has Increased $330,000
.No Position Change
•Refailure Rate Now 11%
.Inspection Period Will be Shortened
.Trying to Implement An Annual In-
spection Cycle, Requires Legislat-
ion Action
.Improved Enforcement Led to
Increased Throughput
.P.R. Program Needed
.Mechanic Training Program
.Increased Enforcement Policies
.Favor Mandatory Inspection with
Three Conditions:
1. Fed. Govt, and Auto Manufac-
turer's Concurrence On War-
rant ee Program
2. Auto Manufacturer's Compli-
ance With Existing Statutory
Emission Standards
3. I/M Implementation Over Reg-
ional Area
.Public Reaction Excellent
.Unique Combination of Ex-
haust Analysis, Engine
Monitoringi and Computer
Technology
•Diagnostic Testing
.Nation's Longest On-Going
I/M Program
.4,700 Garages Now Utilizing
Exhaust Analyzers
.Private Garage Reinepection
Program
.Estimates Reduction of HC is
14% and GO 7%
.Private Garage Acceptance is
Increasing
.Demonstrated Short Lead
Time in Adding 1/M Program
to Safety Program
•Communication Channels Estab-
lished with Auto Manufactur-
ers Regarding High Emission
Levels of Late Model
Vehicles
.Nation's First Fully Auto-
mated Inspection Program
-------
Table 3-18.
TYPICAL I/M PROBLEMS, SOLUTIONS AND ACHIEVEMENTS (Continued)
PROGRAM TYPE
STATE & RESPONSIBLE AGENCY
PROBLEMS
SOLUTIONS
ACHIEVEMENTS
II. CONTRACTOR-
OPERATED
III. PRIVATE
GARAGE-
OPERATED
Arizona
Maricopa and Pima Counties
Nevada
Clark County
•Initial Adverse Public Reaction
.Queuing Problems
.Tampering
.Inadequate Inspector Training
.Minimal
.Expected to Disappear With Increased .Nation's First Contractor-
Efficiency and Better Public
Awareness
.Needs Contractor Monitoring
Operated Program
.DMV Control of Licensinq
of Stations and Inspectors
.Minimal Cost
Rhode Island
00
.Inadequate Training of Garage
Mechanics
•Some Garages Violated
Regulations
.On-Going Mechanic Training
Program
.Constant Monitoring Needed
.Program Initiated by
Governor and Rhode Island
DOT With Backing From Exe-
cutive and Legislative
Branches
.State-Run Inspection Facil-
ity Used as Reference
Station
-------
3. Qualitative Comparison of Administrative Programs
Table 3-19 presents qualitative information for the state, contractor, and
private garage systems as a function of various cost categories and related
considerations. The program cost implications in terms of state financial
involvement were also evaluated. In addition, major operation program responsi-
bilities were identified for each administrative option.
4. Functional Comparisons
The implementation of comprehensive emission control program requires the
cooperation of several governmental agencies and departments (Figure 3-5).
These agencies and departments provide support services in three general
areas -legal, environmental, and enforcement. For example, legal services
provided by the joint cooperation of the Consumer Affair's Office and Attorney
General's Office include a complaint information and referral system, an on-
going public relations program, and legal redress mechanisms. Environmental
services could be provided by the Environmental Protection Division consisting
of an on-line computer analyses of emissions test data. Finally, enforcement
services could include direct computer access to the Department of Motor
Vehicles Registration files, personnel training facilities and capabilities,
and safety/spot check programs.
These support activities could be coordinated by a state administrated
Motor Vehicle Emissions Control Office (MVECO). Additional responsibilities
should include quality and operational controls of the day-to-day business of
the various inspection test centers.
The three alternative administrative approaches (state, contractor, and
private garage) differ in the operational format of the total I/M framework.
For instance, a contractor-operated program (Figure 3-6) is responsible for
their own internal quality control program. The state would provide independent
checks on quality assurance in the form of correlation vehicles and referral
stations. In addition to correlation vehicles, referrals stations, etc.,
private-garage operations (Figure 3-6) would require a certification program
for both mechanics and repair facilities (Figure 3-5).
82
-------
Table 3-19.
QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS
COST CATEGORIES AND
CONSIDERATIONS
Instrumentation and
Technology
Site Acquisition
Facility Construction
and Acceptance
Equipment Acquisition and
Installation
Maintenance and Support,
Inspection-Oriented
Equipment
STATE-
OPERATED
CONTRACTOR-
OPERATED
PRIVATE GARAGE-
OPERATED
Design, requirements
analysis, and specifica-
tion development is
required.
Initial capital cost
required.
Capital investment
required, local govern-
ment approval to meet
zoning laws.
Volume discount.
Preventive maintenance
done by facility person-
nel; major corrective
maintenance done either
by a single technical
department or contracted
outside service; moder-
ate cost to State.
Will have expertise in
these areas.
Will have some basic exper-
tise, but will need to be
expanded.
Low capital cost to Capital invested already,
state, deferred to oper-
ational charge.
Contractor agency will
require building in-
spection approval by
the State and local
government.
Moderate cost volume
discount.
Minor corrective
maintenance done by
facility personnel;
major corrective
maintenance done by
contracted service;
no cost to State.
Facilities available.
Each participating garage
will have to purchase equip-
ment that it does not
already have.
Preventive and minor correc-
tive maintenance done by
facility personnel; major
corrective maintenance prob-
ably done by contracted ser-
vice; no cost to State.
Quality Control and
Support Activities
Periodic confidence test-
ing and calibration func-
tions; minor repairs of
supporting equipments
done by facility person-
nel; major repairs done
by single department or
contracted; moderate cost
to State.
Periodic confidence
testing and calibra-
tion of minimum
number of stations by
state. Data process-
ing by state.
Performed by State agency.
Numerous stations to be
checked. Data processing
input from card decks.
-------
Table 3-19.
QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS (Continued)
COST CATEGORIES AND
CONSIDERATIONS
Program Management and
Functions
STATE-
OPERATED
Maintain records, sched-
ule vehicles, collect
fees, review emission re-
sults, update standards
and documentation, deter-
mine future requirements,
evaluate newer equipments,
determine budgetary re-
quirements , and other
program management func-
tions; may involve many
separate State agencies,
new and/or existing;
moderate cost to State.
CONTRACTOR-
OPERATED
Similar management
functions to State
operated program, but
with State agency
that oversees contrac-
tor administration?
moderate cost to State.
PRIVATE GARAGE-
OPERATED
Requires State to audit all
records on regular basis;
high cost to State.
Program Management and
Administration Surveil-
lance Program
Periodic certification of
existing facilities;
qualification/certi f ica-
tion of new facilities;
moderate cost to state.
Periodic certification
of contractor facil-
ities by State inspec-
tion team; moderate
cost to State.
Private-operated facilities
certified by State personnel;
high cost to State.
Initial Personnel Train-
ing and Indoctrination
Single department respons-
ibility; uniform training
policy, course content;
minimum quantity of
trained instructors,
equipment, buildings;
moderate cost to State.
Require single depart-
ment responsible for
training, etc.;
minimal cost to the
State.
Possibly many diverse training
policies, course contents,
equipment, facilities, in-
structors; requires guidance
from State agency on require-
ments; minimal cost to State.
State Qualification and
Certification
Single departmental re-
sponsibility; uniform
qualification and certi-
fication policies; mini-
mum quantity of techni-
cal and administrative
personnel; moderate cost
to State.
State responsibility to
supervise initial
operation of program;
moderate cost to State.
Mandatory that State qualify
and certify stations; high
cost to State.
-------
Table 3-19.
QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS (Continued)
COST CATEGORIES AND
CONSIDERATIONS
Vehicle Scheduling
Facility Inspection
Personnel Salaries/
wages, etc.
STATE-
OPERATED
Quality Assurance
Single departmental
responsibility.
Technical rating depen-
dent on test regime; cost
proportional to technical
requirements; salaries
and benefits must be com-
petitive to attract
higher-rated personnel;
high cost to State.
Responsible for complete
audit of all records;
complete data analysis;
adjusting confidence
limits; moderate cost to
State.
CONTRACTOR-
OPERATED
PRIVATE GARAGE-
OPERATED
Mandatory that State
be responsible.
Technical rating de-
pendent on test re-
gime requirements.
Calibration records
frequently audited by
State personnel; State
responsible for com-
plete data analyses;
moderate cost to State.
Mandatory that State be
responsible.
Technical rating depends on
test regime; cost propor-
tional to technical rating.
Difficult to implement be-
cause of instrument differ-
ences, diversified personnel;
high cost to State.
Personnel Services
Hiring/Firing Practices
Public Attitude
Industry Attitude
Strict use of civil ser-
vice personnel.
Requires lengthy review
periods before workers are
hired or fired.
Greater public acceptance
and credibility of program
objectives.
Low - industry may perceive
this as another state pro-
gram and fail to see pro-
gram objectives.
May use part-time em-
ployees during periods
of high-use.
Immediate - based on
need and personnel per-
sonnel performance.
Unknown.
Unknown.
May use part-time employees.
Immediate - based on need
and personnel performance.
Low - distrust of private
business operations.
Low - industry has seen other
I/M programs has ineffective
and costly to vehicle.
-------
Table 3-19.
QUALITATIVE COMPARISON OF ADMINISTRATIVE PROGRAM OPTIONS (Continued)
COST CATEGORIES AND
CONSIDERATIONS
Federal Legislation
STATE-
OPERATED
Requires revision of SIP
for centralized systems.
CONTRACTOR-
OPERATED
PRIVATE GARAGE-
OPERATED
Requires revisions for
for centralized systems.
Requires revisions to SIP
for decentralized systems -
additional Federal provision
required.
State Legislation
Must provide provisions
that include regular
periodic inspections,
maintenance and retest,
quality control, and
emissions reduction.
Provide provisions for
SIP revisions that in-
spections , maintenance
and retest, quality
control and emissions
reduction.
Requires additional provi-
sions for licensing of in-
spection facilities, must
met program requirements
(e.g., instruments, provide
personnel with adequate
training).
State Liability
00
01
State assumes complete
financial and operational
liability for I/M program.
Contractor assumes
financial and opera-
tional liability.
State oversees program
management and opera-
tions .
Private contractor assumes
financial responsibility.
State oversees program
management of quality control
and test data analysis.
-------
LEGAL
ENVIRONMENTAL
PERSONNEL SERVICES
Figure 3-5.
Functional Administrative Chart
-------
FIELD OPERATIONS
ADMINISTRATOR
FIELD OPERATIONS
ADMINISTRATOR
CONTRACTOR-OPERATED
PRIVATELY-OPERATED
00
00
1
1 r
OPERATIONAL
CONTROL
1
i
INSPECTION
CENTER
1
INSPECTION
CENTER
2
INSPECTION
CENTER
n
i
1
PRIVATE
GARAGE
1
PRIVATE
GARAGE
2
PRIVATE
GARAGE
n
Figure 3-6. FUNCTIONAL AMDINISTRATIVE CHART - CONTRACTOR OPERATED AND PRIVATE GARAGE
-------
This functional outline, rather than a strict organizational plan, is
intended as a guide for South Carolina. The above mentioned agencies and/or
departments are typical of most state organizations, however, they may be
replaced with others more suitable to the particular requirements of South
Carolina.
89
-------
G. IDLE-MODE TEST
The idle-mode test is a measurement of the exhaust emissions with the
vehicle in a neutral gear and the engine at idle. Often, hydrocarbon (HC) and
carbon monoxide (CO) levels are recorded at both a normal and high idle speed.
The test at the normal idle speed is taken at the manufacturer's recommended
idle, measured in revolutions per minute (rpm), and then the engine speed is
increased to 2,500 rpm for the high idle speed test.
The overall test procedure includes the collection of vehicle identifica-
tion data (year, make, model, license number, vehicle identification number,
etc.), visual inspection of the exhaust system and emission control devices,
the exhaust emission test and recording of the test data.
The idle inspection and repair flow diagram, Figure 3-7, illustrates the
following sequence of events. Based on the exhaust emission test data a
pass/fail decision is made and discussed with the vehicle owner. Passed
vehicles are certified, and if indicated by the emission data, impending
malfunctions are discussed with the owner. The vehicle is then released.
Failed vehicles are diagnosed for probable cause of failure and released to
the owner for repair. After the repair(s) is performed, the vehicle is returned
to the facility and retested. The idle inspection and repair flow diagram,
Figure 9, illustrates this sequence of events.
The general characteristics of idle mode testing are as follows:
o Simple test procedure that requires minimum training for inspectors.
o Carburetor adjustments can be made during test.
o Diagnosis of some engine maladjustments and malfunctions.
o Can be duplicated by either public or private test systems.
o Requires minimal test time and equipment.
o Malfunctions that occur under loaded conditions may not be detected.
o NO testing cannot be performed.
90
-------
RECEIVE
INSPECTION
VEHICLE
l , .
^
REVIEW AND
RECORD 10
DATA
DIRECT VEHICLE
OWNER TO
WAITING AREA
MEASURE
EMISSION
LEVELS AT
2500 RPM
MEASURE
EMISSION
LEVELS AT
ENGINE IDLE
hr*
ADJUST IDLE
PARAMETERS
AS REQUIRED
IS T4
IJ
INSPECT
VISUALLY.
-¥
CONNECT,
CALIBRATE
TEST
EQUIPMENT
DISCONNECT
EMISSION
TEST
EQUIPMENT
-~
COMPLETE
INSPECTION
FORM
DISCUSS
TEST RESULTS
WITH OWNER
PERFORM
REQUIRED
SERVICE AND
REPAIR
MD 1
i
i
i
i
J
RELEASE
VEHICLE FROM
FACILITY
RECEIVE
NEXT
VEHICLE
PRIVAI
STATIONS
ONLY
i?V
NS 1
_J
Figure 3-7.
IDLE INSPECTION AND REPAIR FUNCTIONS
-------
Idle Inspection Test Mode
In this inspection and test regime, the tested vehicle is operated until
proper engine temperature is achieved. While the vehicle is operating at
idle, a sample of the exhaust is analyzed for HC and CO concentration in the
gas analyzers, and the results are recorded. If the vehicle does not pass the
established emission limits, the vehicle is required to receive corrective
action.
The term "idle inspection" is somewhat misleading since the vehicle is
also operated at higher rpm (2,500) as part of the inspection test cycle. The
test mode is more accurately described as a static or light-load test, as the
vehicle engine is operated without benefit of vehicle road loads. The sensi-
tivity of idle testing is improved by performing this additional testing at
higher engine speeds. The engine loads experienced during higher rpm operations
provide an opportunity to measure effectiveness of off-idle carburetor circuits
and to detect additional malfunctions that may contribute to high emissions.
During the idle test procedure, engine operations and emission measurements
are accomplished at 2,500 rpm prior to performing idle measurements. This
sequence provides the opportunity for engine temperature stabilization.
The following is a description of a typical idle test sequence and diag-
nostic information when the vehicle fails:
° 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 instruction.
92
-------
° Test
Perform HC/CO and rpm measurements and compare to idle test standards.
2,500 rpm - Operate engine in neutral at 2,500 rpm, record
HC/CO.
Idle rpm - Operate engine at idle rpm (in drive if automatic
transmission), record measurements.
o Postr Test
Make pass/fail decision and discuss results with vehicle owner.
Passed Vehicle - Certify and release.
Failed Vehicle - Diagnose for probable cause of failure and
instruct vehicle owner in retest procedure.
Idle HC/CO failure/malfunction truth table can be used as a guide to
identifying failures (see Table 3-20). A functional flow diagram for the idle
test regime is shown in Figure 3-8.
93
-------
Table 3-20.
MALFUNCTION TRUTH TABLE FOR IDLE TESTING
H£ CO ROUGH
MALFUNCTION High Very High High Very High IDLE
PCV Valve Diruty/ X X
Restricted
Air Cleaner Dirty/
Restireted
Choke Stuck
Partially Closed
Carburetor Idle X
Circuit Malfunction
Intake Manifold Leak X X
Ignition Timing
Advanced
Leaky Exhaust Valves
ignition System
Misfire
94
-------
/ 1 MIN
1 MIN
1 MIN
1 MIN
1 MIN
1 MIN
1 MIN
1 MIN
, 1 ,
1 MIN
1 MIN
1 MIN
1 MIN
1 MIN
I
1 1 i-J
. 1 ¦"/ 1
i 1 i
1 i 1
1 1 1 .
i 1_i—
I I t..
i 1 I
i ! 1
1 1 1
STATION FUNCTIONAL FLOW
SINGLE LANE
PRETEST ±
CAR 1*
IDLE MODE
TEST 1
POST-
TEST 1
PRETEST
CAR 2
IDLE MODE
TEST 2
POST-
TEST 2
PRETEST
CAR 3
IDLE MODE
TEST 3
SINGLE
LANE
I-MAN
SINGLE
LANE
2-MAN
PRETEST
CAR 2
IDLE MODE
TEST 2
POST-
TEST 2
PRETEST
CAR 4
IDLE MODE
TEST 4
POST-
TEST 4
PRETEST
CAR 6
IDLE MODE
TEST 6
IDLE MODE
TEST 1
POST-
TEST^
PRETEST
CAR 3
IDLE MODE
TEST 3
POST-
TEST 3
PRETEST
CAR S
IDLE MODE
TEST 6
POST-
TEST 6
PRETEST
CAR 7
T
IL
TIME
vo
U1
STATION FUNCTION FLOW
SINGLE LANE
DOUBLE LANE
TEST CREW SIZE
1
2
3
4
VEHICLES PER HOUR
17
34
51
68
AVG TIME PER VEHICLE (MIN)
3.75
1.8
1.25
.9
SLACK TIME PER HOUR
0
0
0
0
PRETEST TIME
1.5
TEST TIME
1.5
POST-TEST TIME (PASS)
.25
POST-TEST TIME (FAIL)
1.25
POST-TEST TIME (AVERAGE)
.75
Figure 3-8.
IDLE TEST STATION FUNCTIONAL FLOW
'nUMERICALS INDICATE SEQUENTIAL ORDER OF VEHICLE TESTING.
INDICATES VEHICLE OUTPUT.
¦I
SYSTEMS CONTROL, NC. -
ENVIRONMENTAL ENGINEERING division
-------
Section 4
DETAILED ANALYSIS OF PREFERRED OPTION/PRIVATE GARAGE
A. PROGRAM DESCRIPTION
The purpose of this section is to outline the details of the preferred
I/M program option. The State of South Carolina has established that the
following scenario will be implemented:
o Program to start in 1982, as a goal
o Idle-mode testing
o Four-county area
Berkeley
Charleston
Richland
Lexington
o Tests to be administered by private garages subject to state quality
control
o Annual spection
o No control of out of county vehicle trip effects
o Vehicle categories - LDV, LDT
o Enforcement - vehicle registration
o Emissions checked HC, and CO
o Stringency factor 30 to 35 percent.
1. Program Administration
The preferred test administrative option designated by South Carolina is
the private garage. However, the State will assume certain responsibilities.
96
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For instance, referring to the organizational chart presented in Figure 3-5,
Section 3.F, the State would maintain a Motor Vehicle Emission Control Office.
This office would be responsible for coordinating efforts in public relations,
quality assurance, facility certification and consumer protection investigations.
A state testing center would be maintained by the State to provide a capability
for special complaint and problem resolutions.
a. Private-Garage Operation
The preferred option approach may require State-operated regional offices,
but all inspections would be performed by private garages. Each private
garage operator would be responsible for submitting necessary data to the
State of South Carolina for data processing and statistical report generation.
2. Test Mode
An idle test mode has been designated as the preferred test mode option
by the State of South Carolina. In this inspection and test regime, the
tested vehicle is operated until proper engine temperature is achieved. While
the vehicle is operating at idle, a sample of the exhaust is analyzed for HC
and CO concentration in the gas analyzers, and the results are recorded. If
the vehicle does not pass the established emission limits, the vehicle then
will be required to receive corrective action.
The term "idle inspection" is somewhat misleading since the vehicle is
also operated at higher rpm (2,500) as part of the inspection test cycle. The
test mode is more accurately described as a static or light—load test, as the
vehicle engine is operated wxthout benefit of vehicle road loads. It has been
demonstrated that vehicle system malfunctions, which result in high emission
characteristics at idle rpm, frequently contribute to high emissions over a
typical load/speed range as measured by the standard Federal test. However,
the sensitivity of idle testing can be improved by performing additional
testing at higher engine speeds. The engine loads experienced during higher
rpm operations provide an opportunity to measure the effectiveness of off-idle
carburetor circuits and to detect additional malfunctions that may contribute
97
-------
to high emissions. During the idle test procedure, engine operations and
emission measurements are accomplished at 2,500 rpm prior to performing idle
measurements. This sequence provides the opportunity for engine temperature
stabilization.
Instrumentation for the idle test function consists of the following
equipment for each lane:
o Nondispersive infrared (NDIR) instruments with two detectors operated
in parallel; one measuring HC, and the other CO.
o Gas sampling and handling equipment including a tail pipe probe,
sample line, vapor condensor, particulate filter(s), sample pump,
and appropriate valves for the check and calibration cycles and for
purging the system. More detailed equipment specifications are
given in Section 3-G of this report, dealing with quality assurance.
The following is a description of a typical idle test sequence and diag-
nostic information when the vehicle fails.
a. Pre-Test
Prepare vehicle and equipment for the test.
1. Test Equipment - Service, warm up, and calibrate HC/CO test equipment
per manufacturer's specifications.
2• Test Vehicle Verify engine is at normal operating temperature
(warm up as required).
3. Hook-Up - Insert probe in exhaust pipe (driver's side if dual exhaust);
hook up tachometer per manufacturer1s instructions.
b. Test
Perform HC/CO and rpm measurements and compare to idle test standards.
98
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2/500 rpm - Operate engine in neutral at 2,500 rpm; record HC/CO.
2. Idle rpm - Operate engine at idle rpm (in drive if automatic trans-
mission); record measurements.
a. Diagnostic Information
1. High HC - Indications are 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 timing light. Valve failure is indicated
by cylinder balance testing with compression test verification.
Lean misfire is caused by a too lean idle mixture setting or manifold
vacuum leaks.
2. High CO - This can be caused by an abnormally restricted air cleaner,
a stuck or partially closed choke, or a carburetor idle circuit
failure. Rough or erratic idle can be caused by a PCV valve malfunc-
tion. Idle HC/CO failure/malfunction truth tables can be used as a
guide to identifying failures.
3. Frequency of Inspection
All vehicles will be inspected on an annual basis as a part of the yearly
registration procedures. This frequency is justified on the basis that it
minimizes costs and maximizes public acceptance while maintaining a reasonably
high level of emission reductions. The vehicle normally deteriorates to its
pre-maintenance lvels in 6 to 9 months. (Ref. 15).
4. Types of Vehicles to be Tested
Initially, the coverage of the I/M program will include only the following
LDV vehicle categories:
o Light-duty gasoline-powered automobile*
^Passenger cars or passenger car derivatives capable of seating 12 passenger or
less.
99
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o Light-duty gasoline-powered trucks, LDT^ (less than 6,001 pounds)
o Light-duty gasoline-powered trucks, (less than 8,501 pounds)
All heavy-duty vehicles (greater than 8,500 pounds), diesel-powered
light-duty vehicles, and motorcycles will be exempted from the I/M requirements.
A provision may also be included to exempt vehicles from the required mainte-
nance phase of the program if the necessary repair work would cost over $100
(1976 dollars). The effect of this exemption on the program, in terms of
emission reduction benefits, is minimal as shown in Table 4-1.
5. Stringency Factor
Cost and benefit data presented in this report are based upon an initial
stringency factor (or failure rate) of 35 percent. This implies that 35 percent
of the vehicles tested will fail to meet standards and will require corrective
repair work and retesting. A comparative study, cost and benefit information
have also been presented for a various stringency factor (see Section 3-E).
The determination of test standards which will produce the desired failure
rate is discussed in detail in Section 3-E of this report. For implementation,
the setting of standards will require an iterative approach in which initial
standards are chosen from a previously operated program, such as California or
New Jersey. As results of the program in South Carolina become available, the
actual failure rate will be determined, and the standards should be adjusted
accordingly.
6. Data Handling
Data will be collected with regard to emissions levels, repair activities
and facility operations. Analysis of these data will be performed to ascertain
emissions reduction cost-benefit relationships, patterns of malfunctions, the
adequacy and accomplishment of required maintenance, the effectiveness of
failure diagnosis based on emission reduction calculations and on the review
of remarks received from the repair garages, and operational effectiveness.
Each inspection station will be required to submit weekly records which provide
statistics concerning inspections completed, vehicles rejected, complaints
received and maintenance tasks performed. Data on repair costs and services
performed would also be collected from the private garage sector. A statistical
sample of these data will be collected, keypunched, and processed by means of
100
-------
MAXIMUM
REPAIR COST
$150
$140
$130
$120
$110
$100
$90
$80
$70
$60
$50
$40
$30
$20
Table 4-1
EFFECT OF REDUCING THE MAXIMUM REPAIR COST (IN 1976 DOLLARS)
PERCENT OF
FAILED REPAIRED
Idle
Loaded
AVERAGE
REPAIR COST
Idle
Loaded
(Ref. 2)
AVERAGE FUEL
ECONOMY IMPROVEMENT
Idle Loaded Idle
TOTAL EMISSION REDUCTION
HC
Loaded
CO
Idle
Loaded
100%
100%
100%
100%
100%
100%
100%
100%
100%
100%
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
99
100
100
100
100
100
100
100
99
100
94
100
100
100
99
100
99
100
98
100
92
100
100
100
98
100
98
99
97
97
90
99
100
99
97
100
98
97
96
91
87
96
92
96
93
97
95
97
94
91
82
96
83
96
90
97
87
96
92
88
76
93
76
94
87
95
81
94
88
85
60
91
77
93
83
92
76
88
84
75
64
85
63
90
78
85
68
86
77
72
56
85
70
81
65
82
63
67
69
60
50
51
67
53
49
69
57
At 100 percent all repair costs were included in establishing the average repair cost. Below 100 percent
the maximum repair included only the noted percentage of repairs.
At the stated maximum repair cost, the noted percentage of fuel savings was included in the average calttnla-
noted percentage^"1 Xit^ * in ^ * <*• »«„ee„ 100 ™"Jd Jhe
-------
a centralized computer facility. Data summary reports will be generated and
distributed to interested personnel in the State of South Carolina and the
EPA.
7. Phasing Considerations
It is important to consider the necessary phasing of the implementation
of an I/M program. The phasing considerations are constrained by the Clean
Air Act Amendments according to the following key dates (Ref. Appendix A):
a. January 1, 1979 - Submittal of I/M State Implementation Plan (SIP)
revisions
- Adoption of adequate legal authority for I/M
b. June 30, 1979 - Adoption of legal authority for states where legis-
lature meets in early 1979
c. July 1, 1980 - Latest possible extension date for adoption of legal
authority
d. December 31, 1980 - Implementation of mandatory inspection and repair for
states which adopted legislation by 6/30/79 and are
implementing a decentralized program. Preferred
private-garage option is in this category if they
adopt legislation by June 30, 1979.
e. December 31, 1981 - Implementation of mandatory inspection and repair for
states which 1) adopted legislation by 6/30/79 and
are implementing a new centralized program, or
2) adopted legislation by July 1, 1980 and are not
implementing a new centralized program (preferred
option (private-garage) is in this category.
f. July If 1982 - Submittal of SIP revisions if standards are not going
to be met by 12/31/82 (must contain provisions for
I/M implementation)
102
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g. December 31, 1982 - Implementation of mandatory inspection and repair for
states which adopted legislation by 7/1/80 and are
implementing a new centralized program
- Attainment of all standards except photochemical
oxidant and/or CO
h. December 31, 1987 - Attainment of all standards
Another consideration which should be investigated for program phasing
would be the possibility of establishing pilot test stations and an initial
voluntary I/M program. A pilot program would allow: 1) evaluation and revision
of the design study recommended inspection procedures and equipment specifica-
tions, 2) validation of the effectiveness of the diagnostic procedures in
detecting causes for excessive emissions, and 3) refinement of the maintenance
and repair procedures. Data required for these analyses could be provided by
inspecting vehicles and evaluating selected samples of repaired vehicles.
Additionally, the trial program data would be used to refine the exhaust
emission standards established by the State of South Carolina, to provide the
data base necessary to establish stringency standards for newer vehicles
(e.g., 1978-1979 model years), and to supplement existing data on emission
control problems such as tampering and special problems. The program could
provide actual data on failure regimes and their changes because of local
weather conditions. These data are necessary to realistically define I/M
program manpower requirements. Throughput rate curves could be developed.
The pilot program would also provide detailed local data on:
o The qualifications of emission repair personnel to understand the
inspection lane diagnostic statements and recommended repair
procedures.
o The qualification requirements of emission repair personnel
o Whether dealer, independent and service mechanics are sufficiently
qualified to perform emission repairs.
103
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o The identification of areas of deficiency and the development of
requirements on the contents of training seminars to eliminate such
deficiencies.
o It could be used at the start of the I/M program as one of the
referee stations.
A typical time schedule for implementation of a pilot program is given in
Figure 4-1.
8. Mechanic Training
The air quality benefit from the I/M program will be dependent, in part,
on the ability of the service industry to properly perform the repair work
necessary to lower emissions. Depending on the level of service industry
training, emissions could be reduced just to the levels which would pass the
I/M test or well below them. Some savings in repair costs may also result
from the training since the mechanics would be familiar with the problems and
the best solutions. Mechanics in the State of South Carolina presently have
access to emission training courses through the vocational schools in the
State. The instructors for these courses have generally received their training
through an EPA-sponsored instructional program which utilizes the Colorado
State University Motor Vehicle Emissions Control and Safety package. There is
currently no existing program for training mechanics in the field. The EPA is
currently working on a short (8-hour) course for these mechanics, but feels
that the program will take about a year to develop. This time frame will fit
in well with the requirements of I/M, and the State should fully support the
EPA program. Support of this program will satisfy the EPA's minimum require-
ments for an I/M system and, if the program is successful, additional emission
reduction credits can be claimed (Ref. 19). For a private garage system, the
EPA also requires that a representative of each station must have received
instruction in the proper use of emission testing instrumentation and vehicle
testing methods and must have demonstrated proficiency in these methods.
104
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GO AHEAD MARCH 1
TIME IN MONTHS
ACTIVITIES
1 2
3 4 5 6 7 8 9
r~i—r
Preliminary Review
10 11 12
DESIGN OF PROGRAM
ADMINISTRATION SET-UP
INSTRUMENT PROCUREMENT
INSPECTOR TRAINING
REPAIR FACILITY SURVEY
MECHANIC TRAINING
SOFTWARE DEVELOPMENT
PUBLIC RELATIONS
HEARINGS (PUBLIC)
CHECKOUT AND SHAKEDOWN
TRIAL-VOLUNTARY RUN
PRODUCTION MANDATORY TESTING
J
~
^Two years of operation
. J would provide sufficient
jdata for I/M
Complementation.
Figure 4-1
PILOT PROGRAM AT THE STATE TESTING CENTER TIMELINE IDLE TEST MODE
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9. Quality Control
The EPA has specified minimum requirements for quality control programs.
The South Carolina I/M system will provide for quality control regulations and
procedures which include the following:
o Minimum specifications for emission analyzers,
o Required calibrations on all types of analyzers, and
o Minimum record keeping.
Under the private garage I/M program option, the Motor Vehicle Emission
Control Office will also inspect each facility periodically to check each
facility's records, check the calibration of the testing equipment and observe
that proper test procedures are being followed. The agency will also implement
an effective program of unannounced/unscheduled inspections both as a routine
measure and as a complaint investigation measure. Such inspections will also
be used to check the correlation of instrument readings among all inspection
facilities. Further information on the proposed quality assurance program is
given in Section 4.E.3 of this report.
10. Public Relations
The function of a public relation program will be to familiarize the
public and the repair establishments with the I/m program. This will include
the explanation of the purpose and objectives of the program, the program
benefits, and the practical workings of the program. Under this latter cate-
gory, the actual testing procedure will be explains . _
* «*pj.ainea. In addition, information
regarding station locations, inspection times, and consumer protection measures
will be made available. Ihe public relations program will take a variety of
forms. Advertisements, public service announcement«= ™ v. j'
sumvjuncements on radio and television,
and brochures will all be used. With respect to •
^ to program phasing, the public
relations program will be started 6 months to a v«r
° a Year before mandatory testing
is begun in order to allow vehicle owners to become
come accustomed to the concept
of I/M.
106
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11. Consumer Protection
The major requirements of a comprehensive emission control consumer
protection program will include:
o designation of a lead agency for overall consumer protection
responsibility,
o implementation of a consumer protection program,
o definition of local responsibilities, and
o provision for regulation of the repair industry.
The system will be made up of a number of programs:
o warranty protection program
o after-market parts program
o modified parts program
o recall/defects program
o consumer complaint resolution (field investigators)
o repair facility certification criteria
(See Section 4.E.2 for a more detailed description of the consumer protec-
tion system.) A fleet of mobile vans will be maintained by the State to act
as "referee" testing units. Upon request of the consumer or station representa-
tive, a van will be dispatched which can perform simultaneous testing at any
location in the region.
12. Enforcement
The enforcement mechanism for the I/M program will be tied in with existing
motor vehicle registration procedures. The South Carolina Department of Motor
Vehicles (DMV) provides for a fully computerized and efficient data-handling
system that continuously processes detailed information on owner (name, sex,
age, driving history, etc.) and vehicle (make, model, year). This information
is constantly updated and is readily available to governmental agencies directly
concerned with I/M program requirements. These factors identify the vehicle
107
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registration system as a likely candidate for an emission test enforcement
control point. The vehicle registration system provides for an annual inspec-
tion process by making an emission test a necessary prerequisite for the
successful completion of the registration process. Upon receipt of vehicle
registration renewal application, the owner must obtain a Certificate of
Compliance from a Certified Emission Test Station within a specified period of
time (e.g., 90 days). A condition of noncompliance will result if the vehicle
owner:
o ignores emission test requirements
q fails to pass established emission test standards
o after failure of emission test, does not obtain the necessary repairs
and retest.
Noncompliance will result in nonregistration of vehicle and, in effect,
deny the right to operate the vehicle.
13. Legislative Requirements
The State of South Carolina will be required to enact legislation which
enables the enforcement of an I/M program. In general, this legislative
package will include two provisions. The first is a legal requirement that
the owner or operator of a motor vehicle should not deliberately remove or
inactivate the emission control devices presently required of automobile
manufacturers. The second provision establishes a system of inspection and/or
maintenance programs. This provision would address specific issues (i.e.;
legal authority, fees, penalties) that should be incorporated into the enabling
legislation.
B. COST METHODOLOGY AND DATA BASE
This section provides a description of cost methodology used in estimating
all costs of implementation of an I/M program and the data base which were
used for cost and benefits calculations.
108
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1. Cost Methodology
I/M program costs were grouped into five categories, as shown in Table 4-2;
major cost items of each category were also listed. Cost categories I, IV,
and V included those resources and functional costs that were related to
initial investment, capacity expansion and implementation. Operating costs
covered the annually required costs that are necessary to operate the I/M
program. Consumer protection costs covered costs of mechanic training program,
public information program and enforcement.
General descriptions of each cost category are presented in the following
paragraphs.
a. Test Equipment Costs
Equipment selected and recommended for the particular test methodology
must be purchased and installed. Acceptance tests must be conducted before
the facility certification. The test documentation would be supplied by the
program management office. Additionally, it may be advisable for a team of
qualified and trained technical inspectors to be available for guidance.
b. Annual Operating Costs
Annual operating costs include all costs associated with the actual
operation of the I/M program. For the purpose of analyses, consumer protection
costs are not included; rather they are identified as a separate cost category.
Facility Operation - For a private-garage operated facility, the operation
cost include wages and overhead. Wages are compensation for personnel who
inspect and test vehicles. The overhead need to cover equipment, facility
maintenance, utilities, supplies, and taxes.
Support Costs - The costs included in this group reflect the overall
program administration effort. Specifically, salaries of administrative
personnel, office supplies, office rental, and data analysis cost are included.
109
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Table 4-2
OUTLINE OF PROGRAM COST CATEGORIES AND ELEMENTS
I. TEST EQUPMENT COSTS
1. Instrumentation Costs
a. Primary test equpment
b. Ancillary equipment
c. Maintenance equipment
II. ANNUAL OPERATING COSTS
1. Facility Operation
a. Personnel costs
b. Maintenance and miscellaneous item costs
1. facility
2. equipment
2. Support Costs
a. Administration
b. Data analyses
c. Training
3. Quality Control Costs
a. Administrative supply costs
b. Maintenance and operation costs
c. Personnel costs
III. CONSUMER PROTECTION COSTS
1. Public Information Program
2. Complaint Follow Up
3. Spot Check
4. Vehicle Test Scheduling Costs
IV. INITIAL IMPLEMENTATION COSTS
1. Bids Preparation and Evaluation
2. Training Plan Development
3. Document Preparation
4. Administrative Support
5. Initial System Certification
V. OTHER CAPITAL COSTS
1. Administrative Office Equipment
2. Quality Control Equipment
3. Consumer Complaint
4. Vehicle Test Scheduling
110
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Quality Control Costs - Quality control cost consists of certification
and recertification of test stations, mobile unit operation, instrument
flfl&ifrtenance, personnel costs, supplies, data analysis, and admininstrative
cost pertinent to quality control operation.
Prior to receiving the first inspection vehicle, the total facility must
be qualified and certified. It was previously stated that the approved equip-
ment is certified after installation. Additional tests would be conducted on
the total system of equipment, personnel, procedures, and documentation to
assure uniformity on a statewide basis.
The quality control program requires mobile vans to calibrate all test
equipment in each facility.
c. Consumer Protection Costs
This cost category include operating expenditures for mechanic training,
public information, and enforcement programs.
Mechanic Training - The air quality benefit for an I/M program is depen-
dent, in part, on the ability of the service industry to properly perform the
repair work necessary to lower emissions. Thus, a proper training program
would enhance benefits of emission reductions.
The cost of mechanic training can be defrayed through a charge for the
training course. In the cost analysis, it is not included in the program
cost.
Public Information - The experience with I/M program operation shows that
there is a definite requirement for a vigorous public information effort.
Cost of public information covers newspaper, television, and radio advertise-
ments, pamphlet distribution, and public speech, etc.
Enforcement - Costs of enforcement include spot checks of in-use vehicles,
salaries of enforcement officers, operation cost of enforcement vehicles.
Ill
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d. Iniitial Implementation Costs
Implementation of an I/M program will require the expenditure of monies
for noncapital items and services on a one-time basis prior to the actual
start-up. Costs of this nature are difficult to define. They generally
include initial administrative effort, development of standards and specifica-
tions, system checkout, and personnel training.
e. Other Capital Costs
This category covers initial capital costs which in general are not
included in other categories. Cost items are administrative office equipment,
quality control equipment, and enforcement.
This cost analysis will include estimation of costs in each category in
Table 4-2 over 10 years. In order to caculate consumer fee charge, program
cost that comprise the costs categories in Table 4-2 will be converted into
uniform annualized cost. The fee is then calculated by dividing the total
annualized costs by the average of vehicle population over 10 years. The fee
assumes a free reinspection for each of the failed vehicles. The fee along
with all other costs is expressed in 1978 dollars. To get fee in actual
dollars, one must adjust for inflation. Detailed discussion is presented in
Appendix E.
2. Data Base
The section is organized to provide detailed background data on program
costs, geographical areas, personnel requirements, vehicle categories, test
mode, enforcement, public relations, and benefits.
a. Unit Cost Related Data
The cost functions and their elements are presented in Table 4-2. All
costs are based upon 1978 dollars. Where program costs are specified they are
stated in constant dollars. They do not reflect an inflation factor.
112
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Equipment Costs - Equipment recommended for a particular test methodology
must be purchased and installed. The equipment and support instrumentation is
interdependent with, and must be defined in terms of, the test regime and
applicable exhaust emission standards. The inspection system for an idle mode
testing facility should include an exhaust sample handling subsystem and
analytical instruments.
Exhaust gases are extremely complex mixtures of hydrocarbons (HC), carbon
dioxide (CO ), carbon monoxide (CO), oxides of nitrogen (NO ), aldehydes,
^ X
particulates, water, nitrogen (NO), oxygen, hydrogen, and many other compounds.
To accurately measure any single pollutant, the application of proper gas
sampling techniques and careful sample handling treatment prior to instrument
analysis are required. The basic consideration must be to obtain a sample of
exhaust gas which is completely representative of the vehicle exhaust for the
operating condition of interest.
It becomes necessary to selectively remove those materials and compounds
that affect the absolute measurement of the subject pollutant without changing
the concentration or characteristics of that pollutant. In a practical sense,
this generally means reducing the water vapor level in exhaust gases and
filtering out the particulates before passing the gas sample through a measuring
instrument. Additionally, the sample handling system must also provide for
the periodic input of zero and span check gases and calibration gases.
Sampling System Selection - The sample system for an idle inspection test
mode may consist of a tail pips probe, sample line, vapor condensor, particu-
late filter(s), sample pump, appropriate valves for the check and calibration
cycles, and for purging the system.
The vehicle emissions pollutants that require monitoring are:
o Carbon Monoxide - The most commonly used method for CO measurement
involves the use of nondispersive infrared (NDIR) instrument. These
instruments are based on the principle that the infrared absorption
spectrum of CO gas is sufficiently unique, compared to any other
113
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exhaust component gases, such that the measurement of infrared
energy absorption is proportional to the concentration of the compo-
nent of interest in the presence of other gases.
o Hydrocarbons - The analyses of hydrocarbons in automotive exhaust
gas is complicated by several factors. Hydrocarbons are a complex
mixture and their concentrations vary over an exceptionally wide
range. The NDIR technology is the primary method presently in use
for hydrocarbon measurements.
The equipment cost estimates used in this study were developed primarily
from interviews with manufacturer's representatives. These interviews focused
on identifying the equipment (i.e., type and model) required and the general
level of skill needed to operate and maintain each. Specific costs are pre-
sented in Table 4-3. In the cost analysis, an average cost of $3000 will be
assumed.
Annual Operating Costs - The annual operating costs of an I/M program
include those costs associated with:
o Facility operation costs
o Quality control costs
o Support costs
These costs consist of the following break outs:
o Facility operation costs
-Personnel costs
-Utility costs
-Facility maintenance
-Supplies
-Insurance
-Property tax
-Equipment maintenance
114
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Table 4-3
ADVERTISED PERFORMANCE SPECIFICATIONS OF EXHAUST EMISSION ANALYZER
MODEL MANUFAC.
Mexa
300A Horiba
Barnes
1836 Eng. Co.
Barnes
8335C Eng. Co.
OPERATING
PRINCIPLE
NDIR
NDIR
NDIR
590 Beckman NDIR
EPA
75 Sun
2001 Sun
NDIR
NDIR
NDIR
SPECIFICITY
HC/CO
HC/CO
HC/CO
HC/CO
HC/CO
HC/CO misc.
computer
RANGE
ACCUR.
TEMPERATURE INITIAL
RANGE HUMIDITY SAMPLE SYSTEM COST
7050C Autoscan thermocouple HC/CO
23170 Allen
NDIR
200 Hamilton
Auto- Test
sense Systems NDIR
42-076 Marquette NDIR
400 Beckman FID
951 Beckman Chemi
HC/CO
HC/CO misc.
computer
HC/CO
0-400/2000ppm
0-21/10%
0-400/2000ppm
0-2/10%
0-400/2000ppm
0-2/10%
0-400/2000ppm
0-2/10%
0-500/2000ppm
0-2.5/10%
0-2000ppm
0-10%
0-500/2000ppm
0-2/10%
0-500/2000ppm
0-2.5/10%
0-2000ppm
0-10%
0-500/2000ppm
0-2.5/10%
32°F to
3% FS 105°F
30°F to
±3% FS 120°F
30°F to
±3% FS 120°F
12ppm 35 F to
0.06% 110°F
±2.5% 32°F to
FS 120°F
±3% FS
+2% FS
3% FS
35°F to
±3% FS 110 F
35°F to
±3% FS 110°F
Total HC 0-1/10/100/lOOOppm ±1&
32°F to
110°F
NO/NO
x
+0.5%
0-10/25-10,OOOppm FS
Filter water
95% RH separator $ 2,395
Filter 2,356
Filter 2,494
Filter water
trap 2,300
2 filters
water trap 2,750
2 filters
2 water traps 17,440
10% to
90% RH
85% RH
Filter
2 filters
water traps
Filter
water trap
Filter
water trap
95% RH Filter
2,425
2,371
16,000
2,425
2,820
6,200
-------
o Quality control costs
-Administrative supply costs
-Mobile unit operational costs
-Equipment maintenance costs
-Equipment replacement costs
-Personnel costs
o Support costs
-Administrative supplies
-Administrative personnel
-Administrative office rent
-Data analyses
-Fee collection and vehicle registration processing
-Consumer complaint3
a
-Public information program
. . a
-Mechanic training
-Enforcement
-Personnel intermechanical training
aThese costs are covered under consumer protection and enforcement.
Test Station Operating Cost - Current shop rate in the State ranges from
$14 per hour to $22 per hour. An average of $18 per hour will be used in the
analysis. This shop rate includes wages and overhead.
To estimate test station operating cost, the average output rate should
be determined. For idle emission test, the average time for one vehicle
inspection is 3.75 minutes (see Section 3.G). The operating cost is the
product of shop rate and total number of vehicle inspected (including reinspec-
tion of failed vehicles) divided by the inspection time per vehicle.
Quality Control Operating Costs -
o Administrative - Supply Costs - Annual supplies for the quality
control administration are estimated at $100 per person.
116
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s = M (100)
c P
= $200 (# mobile units)
where:
Sc - supply cost
= mobile unit personnel
° Maintenance and Operation Costs - Annual costs for operations of
mobile vans is based upon 25,000 miles per van at $.15 per mile.
M = 25,000 ($.15) # mobile vans
m
= $3,750 x # mobile vans
o Personnel Costs - Presented in Section 4.B.2.b.
Support Costs -
o Administrative Supplies - Annual supplies for the adminstrative
personnel are estimated at 2100 per person. For 20 administrative
personnel the total cost is then $4,000.
o Administratrative Office Rent - Annual cost for rental space is
$0.40 per square-foot per month. The square-foot requirements per
person is approximately 100-square feet at a monthly cost per person
of $40.00, or a yearly cost of $480. For the 17 administrative
personnel total yearly cost is estimated at $8,200.
o Administrative Personnel Costs - The administrative personnel costs
are presented in Section 4.B.2.b.
o Data Analyses - Emission data collected will have to be reviewed and
reports prepared covering various subjects as the State of South
Carolina may recommend. Such coverage are:
-Repair cost and status data-(current repairs, emission repairs, etc.)
117
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-Emissions data status HC and CO
-Failure rates
-Warranty failures
-Complaint data
-Recall action
-Vehicle data
-Failure cause
-Retest status
-County status on emissions
-Operations effectiveness
From such a list it appears that monthly, quarterly, or yearly
reports would involve a sizeable expense. To process all data
associated with the above would cost in the order of $11,000 to
$15,000. The associated cost to formalize the report are:
Technical layout and discussion $50 per page
Typing and editing $7 per page
Printing and collating $0.10 per page
A 250-page report would cost $15,500 for preparation and publishing
50 reports. Total cost for complete quarterly reports with all
noted items would be approximately $30,000 to $35,000. This could
be reduced by publishing one major report with quarterly supplements.
The annual cost would be approximately $80,000.
Fee Collection and Vehicle Registration - The fee collection of
vehicle registration costs would be negligible after initial imple-
mentation costs, since they integrated into the vehicle registration
costs.
Trainin9 ' Personnel training is a continuing process, it is required
to:
-Indoctrinate/train new and replacement personnel
118
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-Upgrade inspection personnel in new techniques and automotive changes
The costs noted here are for continuing instruction only, and costs
are estimated as $200 per employee per year.
o Public Relations Costs - The costs for public relations is covered
under Consumer Protection.
Consumer Protection Costs - This section presents estimated start-up and
operating expenditures for public information and enforcement programs. Each
program element will take advantage of existing state resources in the form of
personnel services, equipment, and procedures. This will reduce the initial
cost burden to institute needed consumer protection measures. The mechanic
training is discussed in Section 4.E.5.
The organization of this section consists of three major subsections that
separately examine consumer protection program elements. These subsections
are arranged as follows:
o Public information program
o Complaint follow-up
o Spot-check program - enforcement
o Test scheduling and fee collection
Public Information Programs - To estimate the costs associated with a
public information program, all states with experience in I/M public information
programs were contacted. From contacts and additional research, a full range
of possible activities was established and basic cost figures derived (Table 4-4).
It is important to realize that the range of possible activities and compre-
hensiveness of public information programs varies considerably.
There are essentially two program elements that are widely used as I/M
public information techniques. One element is the use of radio and television
public service announcements, and newspaper advertisements. A second technique
is the development of an information phamplet that is mailed, along with
vehicle registration form to vehicle owners.
119
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Table 4-4. INITIAL/ONGOING PUBLIC INFORMATION PROGRAM FOR ONE YEAR
PROGRAM TYPE
COST DESCRIPTION
A. ADVERTISEMENTS
1. Public Service Announcements
Newspaper
Television
Radio
2. Pamphlet
Development/preparation
Printing
3. Bumper Sticker
4. Transit aids
Full page advertisement 172-inch @ 1.65
per inch.
1-minute public service announce-
ments § $40 per 10-second or $240 per
minute.
1-minute service announcements @ $200
per minute includes radio and commission.
Artist (logo and cover design) plus com-
mission § 20 hours.
Pamphlet printed on 20 lb paper, 1 color,
foldout 7-1/2" x 11" (6 million copies).
Printed on 6 lb all weather paper,
1 color. $60,000/4.5 million vehicles.
Space cost on 35 buses, $102 per month
per bus (both sides).
B. PRESENTATIONS
1.
Films
2.
Slide
Shows
3.
Guest
Speakers
Film development (30-minute information
film) . $25,000.
Slide show development $500.
Use of existing public relations per-
sonnel minimizes cost.
120
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To subsidize an initial and ongoing I/M public information program; it
has been estimated that $0.25 per vehicle would generate revenues in excess of
$134,596. These funds would finance various combinations of public information
program.
Complaint Follow-up - Two major support services provided by the Consumer
Affairs Office would involve complaint follow-up, and service industry field
check. Annual cost estimates in providing such services are shown in Table 4-5.,
Estimated cost data include only major program considerations such as computer
time sharing, personnel, investigative services, etc.
In order to estimate program costs, it was assumed that approximately
2500 consumer complaints would be registered annually. Most complaints would
be resolved directly over the telephone. The more difficult complaints would
require direct contact with a field investigators and the complaintant.
Spot-Check Program - If a random spot-check program was implemented, the
estimated cost expenditures are shown in Table 4-6.
Table 4-6. ESTIMATED ANNUAL COST EXPENDITURES FOR STATE-OPERATED
SPOT-CHECK PROGRAM
COSTS
COST CONSIDERATIONS (Thousands of Dollars)
Capital Costs
i) Inspection vans
ii) Extra analyzers
Subtotal
Operating Costs
i) Personnel
2 state officers
4 inspectors
ii) Vehicular Expenses
Subtotal
It was assumed that a 5 percent pullover rate would provide
adequate samples of the in-use vehicle population. This implies
mately 25,000 vehicles would be sampled every year.
42
_6
48
37.9
50.5
3.1
91.5
statistically
that approxi-
121
-------
Table 4-5
CAPITAL/OPERATING COSTS ASSOCIATED WITH CONSUMER
COMPLAINT FOLLOW-UP AND SERVICE INDUSTRY FIELD CHECK
COST CONSIDERATIONS
COSTS
1. Captial
(3) Complaint inspection cars
$ 5,000
2. Operating
a. Computer time sharing $600 per month
b. Personnel .
b
1 field investigators
1 statistician
1 clerks
c. Vehicular
gas/oil
insurance
Subtotal
7,200
18,800
15,800
10,400
1,000
300
$53,500
aBatch time sharing plus analyses.
^Minimum personnel required for handling consumer complaints over the
telephone and investigating.
122
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In order to calculate the number of mobile units required to test 5 per-
cent of the vehicle population, it was estimated that an inspection team
1) state patrol officer and 2) emission inspectors could test 72 vehicles per
day, or 18,720 vehicles inspections per year. This requires two mobile vans
for an estimated $48,000 capital cost investments.
Manpower requirements include 2 police officers and 4 inspectors. Per-
sonnel operating expenses are $88,400 per year. Additional expenses include
those operating expenditures associated with mobile vans are for vehicle
servicing.
Vehicle Test Scheduling Costs
Table 4-7 enumerates capital and operating cost expenditures associated
with vehicle notification, vehicle scheduling, etc. Capital expenditures
would include only software development, since existing computer services
would be utilized. Computer software includes programming time, batch process-
ing, etc. Operating costs include processing registration files, computer
time, vehicle owner notification and postage.
Table 4-7. ASSUMED COST EXPENDITURES FOR VEHICLE TEST SCHEDULING
COST CONSIDERATIONS C°ST
a
A. Capital Expenses
Software development ^ $ 25,000
B. Annual Operating Expenses
Processing files
2,700
81,000
Computer time
5,400
18 hrs x $300/hr
Notification, IBM cards
538,400 cards
67,000
Postage
43,000
$0.08/notification
Subtotal of
operating expenses
$196,400
implementation cost only.
^Vehicle registration costs are not included in our analysis. These
costs are considered in the current vehicle registration fee.
123
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Implementation One-Time Costs (Start-Up) - This section identifies and
estimates implementation one-time costs. These costs are those required
during the planning and development phase of an I/M program.
o Bids Preparation and Evaluation - Costs were developed for prepara-
tion of equipment specifications, reviewing manufacture literature,
contacting supplier, and for preparation and review of bid packages.
Idle Mode
-Equipment specification $3,000
-Bid package and distribution 2,500
-Bid reviewed and selection 3,750
Total Cost $9,250
o Training Plan Development - Costs are for personnel planning, curric-
ulum development, and class scheduling.
Idle mode $3,500
Data were developed from course development in the State of California
and from various training centers.
o Document Preparation - Costs are clerical, editorial, and reproduction
assistance in preparing a document to record the plans, schedules
and analytical results associated with the planning and development
phase.
Document Preparation
450 manhours x $20 per hour
Reproduction
= $ 9,000
= 1,000
$10,000
124
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° Administrative Support - Cost including administrative personnel
support tasks during equipment purchase, personnel selection, system
installation and checkout as:
250 hours x $30 per hour = $ 7,500
o Initial System Certification - Prior to receiving and
testing the first vehicle, the entire inspection system
must be evaluated and tested to establish conformity to
performance specifications. Station certification would
consist of a statistical sample vehicle run to ensure
satisfactory performance. The costs associated for
initial system certification by test mode are as follows:
Idle Mode
1,250 manhours x $25 per hour = $31,250
Other Capital Costs - Other capital costs presented are:
o Administrative office equipment
o Quality control equipment
o Consumer complaint
o Vehicle test scheduling
Administrative Office Equipment - The capital costs associated with
administrative office equipment (e.g.; desks, chairs, typewriters, bookcases,
reference tables, etc.) is approximately $500 per person.
Quality Control Equipment -
o Mobile Unit - The mobile inspection audit system costs per vehicle
are presented in Table 4-8. The mobile inspection system could also
be used to:
-Support spot-check operation during van downtime.
125
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-Referee activity in urban areas.
Table 4-8. MOBILE UNIT COSTS PER UNIT
EQUIPMENT
COSTS
1. Van
2. Van conversion (electrical, cabinets, etc.)
3. Analyzer (NDIR)
4. Working gas (2-blend)
5. Tachometer
6. Gravity master gas cylinders (5)
7. Tachometer calibrator
8 Hand tools
9. Digital voltmeter
$12,000
4,000
2,540
66
200
740
200
Total
1,000
200
$20,946
The calibration check will include a 5-point curve check using
1 percent gravimetric master gases, and correlation tests using the
van engine and state-owned analyzers. The state-owned analyzers
will have the same capability as the station analyzers. The costs
as noted were developed from a dealer survey.
o State Testing Center and Referee Stations - Customer complaints will
arise regarding the reliability of emission test results, especially
in cases where a vehicle fails an emission test after the recommended
repairs have been performed. In order to resolve complaints of this
nature a referee station can be used. The use of a referee station
will also provide an additional check on emission test facility
instrumentation, engine diagnosis, and mechanic capability. The
mobile test units would be used as the referee station. Upon receipt
of a customer complaint and request for verification of emission
test results, an appointment will be made to conduct the verification
test at the test facility in question.
To avoid an overload on the system, specific criteria will have to
be developed to single out complaints of possible validity for
verification testing. For example, vehicles which have failed after
the recommended repairs were performed and/or vehicles for which the
126
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recommended repair costs are above some predetermined level would be
eligible for verification testing.
The costs of a the testing center is presented in Table 4-9. This
unit is used in the costing of this report.
Table 4-9. STATE TESTING STATION EQUIPMENT COSTS
EQUIPMENT
MINIMUM SYSTEM
(Load/Diag.)
Dynamometer with road load inertia weights
Driver's Aid
Analyzer bench
Gases
Miscellaneous-barometer, wet & dry bulb
$16,453
5,000
16,000
870
850
Total
$39,173
Capital costs for consumer complaints and vehicle test scheduling are
presented in previous sections.
b. Personnel
Private garage-operated option has been selected for program implementa-
tion. However, the Department of Highway and Public Transportation would be
the overall administrative authority. This office would be responsible for
quality control and direct or indirect administration of the field stations as
appropriate.
Administrative - This category includes primarily administrative support
in the form of manpower, equipment, and supplies. There is one I/M program
administrator. This program administrator will administer the inspection
program with the support of a quality control administrator and a test
administrator.
The Program Administrative Office would coordinate following functions as
provided by the South Carolina Department of Highways and Public Transportation,
or other departments as appropriate.
127
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o Legal activity
o Financial including purchasing, contract development, and accounting
o Public relations and information program
o Technical reports development
o Mechanics training
o Operations and administrative personnel training
o Consumer complaint
o Fee collection and vehicle owner notification
o Certification/licensing of mechanics
The personnel required are presented in Table 4-10. The administrative
personnel include the Program Administrator and staff, the Quality Control
Administrator and staff, and the Testing Administrator and staff.
Quality Control Field Support - In addition to the administrative quality
control staff, the quality control section would require the field personnel
complement presented in Table 4-11.
Table 4-11. QUALITY CONTROL FIELD PERSONNEL AND YEARLY COSTS PER UNIT BASIS
NUMBER SALARY + 25%
PERSONNEL CATEGORY REQUIRED BENEFIT FACTOR TOTAL
Mobile Control Unit (Per Unit)
Lead technician (instrument) II* 1 $15,568 $15,568
Technician I* 1 10,665 10,665
Total $26,233
*Inspection Agents.
The mobile quality audit personnel requirements are necessary to provide
the following service:
o Quality control audit of each station at least once every 3 months.
The following methodology was used to establish personnel requirements:
o A minimum of four stations would be checked per day. This based
upon 1/2-hour test time and 2 hours travel time per station.
128
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Table 4-10
I/M STATE PERSONNEL REQUIREMENTS AND SALARIES - FOUR-COUNTY
NUMBER SALARY + 25%
PERSONNEL CATEGORY REQUIRED BENEFIT FACTOR TOTAL
Program Administrator
1
30,500
30,500
Secretary
1
13,000
13,000
Clerk
2
11,000
22,000
Environmental Engineer II
1
27,000
27,000
Assistant Program Administrator
1
29,000
29,000
(Quality control)
Clerk
1
11,000
11,000
Statistician
1
27,000
27,000
Assistant Program Administrator
1
29,000
29,000
(Testing)
Clerk
1
11,000
11,000
Inspection Agents
2
15,000
30,000
(Administrative)
Inspection Agents
8
*
*
(Field personnel)
~Reference Table 4-11 for Field personnel salaries.
129
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o
Each mobile unit requires:
-One lead instrument technician
-One support technician.
o The number of mobile quality control units would depend upon the
number of stations required to service the vehicles in the 4 non-
attainment counties.
The quality control referee lane is required to provide the following
services:
o To investigate consumer complaints.
o To institute development practices to improve operation effectiveness.
o To initiate new practices related to new control devices.
o To provide a diagnostic routine for establishing repair effective-
ness and special problem review.
Support Personnel - Support services are required from the following
areas:
o Highway Department Analysis Section (emissions analysis and yearly
report activities).
o Consumer Affairs Office.
o Attorney Generals Office
o Public Relations Department
o Computer Services
130
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o Personnel Department
-Recruitment
-Training service
o Public Safety Department
-Spot-check
The support service costs are presented in Table 4-12.
c. Geographic Area
The State of South Carolina has designated the following four counties as
possible areas required an I/M program. These four counties are:
1. Richland
2. Lexington
3. Charleston
4. Berkeley
Air Quality - The State of South Carolina has provided background documenta-
tion that identifies geographic areas that presently violate air quality
standards for photochemical oxidants (0^), (Ref. 8).
The Clean Air Act Amendments (CAAA) of 1977 requires attainment of the
primary ambient air quality standards for ozone and carbon monoxide by 1982.
However, if these standards cannot be attained by 1982, an I/M program must be
implemented and the standard attained by 1987.
d. Vehicle Projections
Vehicle registration data was analyzed and is presented in Table 4-13.
The data was used as basis for vehicle population projections for 1982 through
1992.
131
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SUPPORT SERVICE
Analysis - yearly
report
Consumer affairs
Attorney general3
Table 4-12
SUPPORT SERVICE COSTS
OPERATIONS COSTS
Ref. Page
Ref. Page
$15,000 per year
PERSONNEL COSTS
Included in operations
costs
Included in operations
costs
Included in operations
costs
Public information
Central computer
Personnel*3
-recruiting
-training
Spot check
Ref. Page
Ref. Page
1 person 25% of the time at
a cost of $l,200/month
Included in operations
costs
$300 per new hire Included in operations
1. .15 x # of personnel costs
x $125
1. # of personnel x $50
Ref. Page
Included in operations
costs
Mechanics training
Ref. Page
Course fee charged but no
cost to program
Purchasing
As required.
Accounting including
payroll
As cequired.
Seven referrals per year each referral would require approximately 2 days of
activity with one court appearance in 2 years - attorney cost are $200/day
+ court costs for a total cost of $15,000/year.
b15% Personnel turnover and $50 per personnel continuing training (the salary of
personnel is not included).
132
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Table 4-13. LIGHT-DUTY VEHICLE REGISTRATION DATA AND PROJECTION
COUNTY
1977
,a
1982
b
1986
1991'
Lexington
Richland
Berkeley
87,795 113,306 134,565 164,800
155,428 188,208 215,525 253,100
42,706 57,207 69,289 86,900
151,907 179,666 202,805 234,200
437,836 538,387 622,184 739,000
Charleston
Total
a
Registration data.
b
Extrapolated from year 1986.
Source: State of South Carolina, Department of Highways
and Public Transportation.
Vehicle projections are provided for 1982, 1987 and 1992. The projections
are carried out to 1992 for the purpose of cost analyses (based upon 10-year
operation) projected data were interpolated and extrapolated to get vehicle
population from 1982 through 1992.
e. Test Modes
The emission test mode identified by the State of South Carolina is the
idle test mode. The idle inspection and repair flow diagram, Figure 4-2,
illustrates the following sequence of events. Based on the exhaust emission
test data a pass/fail decision is made and discussed with the vehicle owner.
Passed vehicles are certified, and if indicated by the emission data, impending
malfunctions are discussed with the vehicle owner. The vehicle is then released.
Failed vehicles are diagnosed for probable cause of failure and released to
the owner for required repair(s). After the repair(s) are performed, the
vehicle is returned to the facility and retested.
The general distinguishing characteristics of idle mode testing are as
o Simple test procedure that requires minimum training for inspectors.
o Carburetor adjustments can be made during test,
o Diagnosis of some engine maladjustments and malfunctions,
o Can be duplicated by either public or private test systems.
follows:
133
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RECEIVE
INSPECTION
VEHICLE
¦5
I
I
I
L
^
REVIEW ANO
RECORO 10
DATA
DIRECT VEHICLE
OWNER TO
WAITING AREA
MEASURE
EMISSION
LEVELS AT
2500 RPM
MEASURE
EMISSION
LEVELS AT
ENGINE IDLE
ADJUST IDLE
PARAMETERS
AS REQUIRED
0*
INSPECT
VISUALLY.
>
CONNECT,
CALIBRATE
TEST
EQUIPMENT
DISCONNECT
EMISSION
TEST
EQUIPMENT
-~
COMPLETE
INSPECTION
FORM
1
OISCUSS
TEST RESULTS
WITH OWNER
-rH
PERFORM
REQUIRED
SERVICE AND
REPAIR
5
RELEASE
VEHICLE FROM
FACILITY
RECEIVE
NEXT
VEHICLE
*There would be
additional charges
for this service
above the fee.
Figure 4-2
IDLE INSPECTION AND REPAIR FUNCTIONS
-------
o Requires minimal test time and equipment.
o Malfunctions that occur under loaded conditions may not be detected.
° NOx test^-n5 cannot be performed.
f. Administrative Option
The State of South Carolina has designated that the testing will be
administered by the private garage (decentralized system).
The problem inherent in this program is that the parties doing the test-
ing and repair is the same person. Inherently if one separates the two you
have a quality control check of the operations. To overcome this problem, the
State of South Carolina should institute a vigorous quality control check of
all safety inspection stations. This inspection should be on random basis and
should be completed at least four times per year.
Personnel Requirements - The state personnel requirements are minimal and
are noted in Table 4-10.
Program Flexibility - Regarding personnel policies, great flexibility
exists with private garage systems. If program manpower requirements change,
a private garage responds readily.
g. Enforcement
The enforcement mechanism for the I/M program will be tied in with existing
motor vehicle registration procedures. The State of South Carolina Motor
Vehicle Division provides for an efficient data-handling system that contin-
uously processes detailed information on owner (name, sex, age, driving history,
etc.) and vehicle (make, model, year). This information is constantly updated
and is readily available to governmental agencies directly concerned with I/M
program requirements. These factors identify the vehicle registration system
as a likely candidate as an emission test enforcement control point. The
vehicle registration system provides for an annual inspection process by
making an emission test a necessary prerequisite for the successful completion
135
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of the registration process. Upon receipt of vehicle registration renewal
application, the owner must obtain a Certificate of Compliance from a certified
emission test station within a specified schedule period of time of 1 month.
A condition of noncompliance will result if the vehicle owner:
o Ignores emission test requirements
o Fails to pass established emission test standards
o After failure of emission test, does not obtain the necessary repairs
and retest.
Noncompliance will result in nonregistration of vehicle and, in effect,
deny the right to operate the vehicle.
An optional random spot-check program provides an additional enforcement
measure by incorporating vehicle pullover techniques with emission testing.
This program may provide statistically adequate samples of the in-use vehicle
population in order to gain information on tampering and program effectiveness.
h. Public Information
The function of a public information program is to familiarize the public
and repair establishments with an I/M program. This would include explanations
of the purpose and objectives of the program, the program benefits and the
operation of the program. Under this latter category, the actual testing
procedure should be explained. In addition, information regarding station
locations, inspection hours, and consumer protection measures should be
presented.
The public information program could take a variety of forms. Advertise-
ments, public service announcements on radio and television, newspaper, and
information pamphlets. Table 4-14 presents estimated cost data relating to:
o Pamphlet preparation and distribution
o Advertisements (e.g., billboards, newspaper, ads, etc.)
o Presentations (e.g., speeches, films, etc.)
136
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In addition, funds needed to finance a comprehensive informational program
was placed on a per vehicle basis.
i. Benefits Data
Emissions Standards - The I/M emission standard (cut point or stringency
factor) was established by communications from the State of South Carolina at
30 to 35 percent.
The Appendix N (FR 24(89): 22177-22183, May 2, 1977; Ref. 19) sets forth
the emission reductions for carbon monoxide (CO) and hydrocarbons (HC).
Table 4-14 presents a typical HC emission factors derived from Mobile 1
Program (Ref. 20) using 49-State data.
The methodology used to calculate emissions reductions is as follows:
n
Total No. Vehicles Emissions x Average x
Emissions = Each Class X Credits Emissions Miles/Year
Reductions i 907,184 gr/ton
where n is class of vehicle, LDV, LDTl, and LDT2, (category of vehicle esta-
blished by the State of South Carolina).
The average emissions as established through Mobile I routine is adjusted
for the following features:
o Emission factor data
o Vehicle types
o Temperature - 75°F
o Speed input
o Vehicle miles traveled
o Speed/temperature/operating mode correction factors
137
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Table 4-14
MOBILE 1 OUTPUT FOR EMISSION FACTORS FOR THE YEAR 1987
Total HC Emission Factors Include Evap. HC Emission Factors
Cal. Year: 1987
Region: 49-State
Veh. Type: LDV LDT1 LDT2 HDG HDD MC
Temp: 75.0(F) .803/ .058/ .058/ .045/ .031/ .005
19.6:19.6/19.6/19.6 MPH (19.6) 20.6/ 27.3/ 20.6
Composite Emission Factors (gin/mile)
Total HC
EVAP HC
Exhaust CO
Exhaust NOx
LDV
2.24
.31
20.46
1.64
LDTl
3.71
.41
40.19
1.97
LDT2
5.12
.73
50.17
2.59
HDG
13.11
.83
166.44
8.15
HDD
3.41
0.00
27.76
13.56
MC
1.40
.03
6.96
.25
ALL MODES
3.02
30.06
2.37
Hot Stabilized
Idle
HC:
.53
1.15
1.71
2.86
.30
.61
.73
Idle
CO:
5.99
10.77
17.92
38.29
.67
1.67
8.23
Idle
NOx:
.47
.21
.20
.02
.67
.02
.42
138
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o Credit allowance from Appendix N
-air conditioning
-extra loading
-trailer loading
-humidity
o Vehicle age distribution
C. COST ANALYSIS
This chapter presents cost analysis for a private garage-operated idle
mode test facility system for the South Carolina's vehicle I/M program. The
geographic areas consist of 4 counties as selected by the State Vehicle cate-
gories under the I/M program include passenger cars, light-duty trucks (<8,501 lb).
HC and CO emissions would be checked against an emission standard established
to correlate to a 35 percent stringency factor. The enforcement mechanism is
the annual vehicle registration.
The analysis assumed that existing privately-owned facilities would
perform vehicle emission inspections under license from the state. Automotive
service could be performed on-site if requested by the vehicle owner. Indivi-
dual garages would purchase the prescribed test equipment and would perform
the required emissions test for a fee regulated by the state. The fee charge
should be sufficient to cover personnel cost, depreciation, and appropriate
overhead costs associated with the emission inspection facility.
1. Facilities Requirements
a. Facility Capacity
The State of South Caroline has an on-going vehicle safety inspection
program that is performed in the private garages. At present, there are 330
privately—owned service stations in the safety program in areas of Berkeley
and Charleston Counties, and 318 stations in areas of Lexington and Richland
Counties. Current safety inspection fee is $2.50 per vehicle.
139
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b. Mobile Van Requirements
There will be four equipped mobile vans required for quality control
purposes.
c. State Testing Center
One state testing center will be established to handle consumer complaints
which require diagnostic inspections.
2. I/M Program Costs
a. I/M Program Costs
The major cost components for the four-county and statewide options are
summarized in Table 4-16. The costs are identified as to state costs necessary
to administer and conduct surveillance of the private-garage program, and
operation and capital costs assigned to the private garage.
1. Four-County Option - It has been estimated that 671 private garages,
distributed in the four counties as noted in Table 4-15 will actively
participate in the I/M program. This will require a 10-year expendi-
ture by the private garages of $4.0 million and $9.9 million for
test equipment and facility operations, respectively. During this
same period, the State will expend $4.9 million for capital, operation,
and implementation costs. Total I/M expenditures by state and
private garages for a 10-year program duration is estimated at
$18.9 million.
The private garage capital/expenditure of 4.0 million is the accumu-
lated first time instrumentation costs of $3,000 and a 5 year replace-
ment cost for a total of $6,000 per private garage - (6,000 x 671 =
$4 million). The private garage-operation cost of 9.9 million are
for the 671 private garages over the 10-year program at an operating
cost per private garage over the 10 years of $14,800 or an average
140
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Table 4-15.
COSTS OF SOUTH CAROLINA I/M PROGRAM - FOUR COUNTIES OPTION
($1,000 1978 Dollars)
1982-1986
1987-1991
TOTAL
CATEGORY
I Test Equipment Costs
II Operating Costs
Facility Operation
Administrative Support
Quality Control
III Initial Implementation Costs
Public Information
State
0
1,616.5
612.0
61.5
200.0
Private
Garage
2,013.0
4,562.9
0
0
0
0
State
0
1,616.5
612.0
0
0
Private
Garage
2,013.0
5,351.6
0
0
0
0
State
0
3,233.0
1,224.0
0
0
Private
Garage
4,026.0
9,914.5
0
0
61.5
200.0
IV Other Capital Costs
Administrative Office
Equipment
Quality Control Equipment
Consumer Protection
TOTAL
TOTAL STATE & PRIVATE GARAGE
8.5
119.0
78.0
0
0
0
2,695.5 6,575.9
9,271.4
0
0
0
0
0
0
2,228.5 7,364.6
9,593.1
8.5
119.0
78.0
4,924
0
0
0
13,940.5
18,864.5
Number of private garages participations in the program are:
Berkeley County 47
Charleston County 235
Lexington County 124
Richland County 265
Facility operation costs increased to compensate for increase in the vehicle population.
-------
of $1,500 per year. Therefore, the total average cost per private
garage per year is $2,200.
The state costs of $4.9 million or an average of $40,000 per year
over the 10-year program is for 3.2 million operating costs for
administrative support analysis of data, prepare reports and adminis-
ter the program including consumer protection, 1.2 million for
quality control of 671 private garages, $200,000 for one time public
information program, 1.2 million for quality control equipment,
8.5 thousand for office equipment, $78,000 for vehicle for complaint
investigation and software development for vehicle scheduling, and
one time cost associated with vehicle scheduling.
3. Consumer Fee Calculation
The ideal fee should be justified on the basis that it is sufficient for
the state and private garages to cover all necessary expenses for the manage-
ment and operation of the I/M program. The consumer fee charge determined in
this report will be the total annualized cost burden shared by each vehicle
owner.
Annualized costs of the I/M program option are determined by amortizing
capital-related costs, test equipment, initial implementation, and other
capital as defined in Table 4-16. Since test equipment has an average of 5
years of life expectancy, it is amortized over 5 years. Other capital-related
costs are amortized over 10 years of the I/M program.
Assuming that the state's cost of capital is 6 percent per year, amorti-
zation factor is 0.2374 for test equipment and 0.1359 for other capital-
related items.
Table 4-16 presents annualized costs of the I/M program. Total annualized
cost would be $1.98 million per year. The state would be required to spend
$0.51 million, while the private garages would expect annual cost of $1.47
million.
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Table 4-16. ANNUALIZED COSTS OF I/M PROGRAM
(1978 DOLLARS)
a ,b
- FOUR COUNTIES
CATEGORY
Test Equipment Cost
private garage
TOTAL AMORTIZED COST
$2,013,000 x 0.2374 x 5" +
$2,013,000 x 0.2374 x 5 = $4,779,900
AVERAGE ANNUALIZED COST ($/YR)
$4,778,862/10 = $477,900
II. Operating Costs
private garage
state
III. Initial Implementation
Costs - state
IV. Other Capital Costs -
state
$61,500 x 0.1359 x 10 = $83,600
$200,000 x 0.1359 x 10 = $272,000
(8,500 + 119,000 + 78,000) x 0.1359
x 10 = $279,300
Total - State
Private Garage
State and Private Garage
lAll costs are rounded off to hundred dollars
°Basic cost data is taken from Table 4-15.
Amortization factor (F) is determined by the formula
$9,914,500/10 = $991,500
$3,233,000 + 1,224,000/10 = $445,700
(83,500 + 72,000)/10 = $35,600
$279,300/10 = $27,900
27,900
$ 509,300
$1,469,400
$1,"978,000
2(l+i)n
p = where i is the cost of capital (=6%) and n is the number of years
(l+i)11"1
For equipment amortization of 5 years, F = 0.2374
For capital amortization of 10 years, F = 0.1359
^The equipment life is considered to be 5 years, therefore, it is required to replace equipment after
5 years.
NOTE: Fee Calculation
private garage share =
state share =
$1,469,400
622,200 vehicles
$509,300
622,200 vehicles
= $2.36
= $0.81
TOTAL FEE $3.17
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Using the vehicle population of 622,200 in year 1986, consumer fee
(as presented in Table 4-17) was calculated by dividing annualized cost
Table 4-16 by the average vehicle population.
Table 4-17. CONSUMER FEE
Fee State's Share Private Garage's Share
$3.17 $0.81 $2.36a
aThis fee does not include any service to the
vehicle being inspected.
D. BENEFITS
This section presents an analyses of benefits derived from private garage-
operated I/M program. Particular attention is given to the following:
o Expected reductions in emissions
o Fuel savings
o Effect on vehicle performance and vehicle life
o Failure rates and emissions reductions
o Estimated repair costs
o Value of warranty repair work, performed
The primary objective of an I/M program is to reduce HC/CO emissions in
response to nonattainment air quality levels for oxidants. Important secondary
benefits as noted above would result from improved maintenance to the motor
vehicles inspected in the program.
1. Emissions Reduction
The major benefit derived from the implementation of an I/M program is
the reduction of hydrocarbon and carbon monoxide emission from motor vehicles
in nonattainment air quality areas. The option studied and their predicted
results for Berkeley, Charleston, Lexington, and Richland Counties were as
follows:
charge
from
144
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o
Private garage-operated emission test stations.
o Implement an in-use mechanic training program - 4 percent greater
hydrocarbon reduction and 10 percent greater CO reduction than the
basic I/M configuration.
The methodology used to estimate average emission reduction was based on
available computer algorithms, specifically Mobile 1 Routine (Ref. 20). The
Mobile 1 computer package was tailored to the needs of South Carolina by
adjusting the following features (Ref. 16):
o Emission factor data - 49 state
o Vehicle types - LDV, LDT1, LDT2
o Temperature - 75°F
o Single-speed input - variable
o Vehicle miles traveled - South Carolina data
o Speed/temperature/operating mode correction factors - South Carolina
data
o Credit allowance from Appendix N
-air conditioning 0.66
-extra loading -04, 0.20, 0.25
-trailer loading .02
-humidity 75 percent
o Vehicle age distribution - South Carolina distribution
A recent report by Engineering Science entitled "South Carolina Highway
Emissions" (Ref. 21) provides estimated emission reductions using Mobile 1
Programs. Table 4-18 illustrates the typical program output.
145
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Table 4-18. MOBILE EMISSION FACTORS BERKELEY COUNTY, 1977 NO I/M
Veh. Type: LDV LDT1 LDT2 HDG HDD MC
Year: 1977 Temp: 75.0(F) 0.716/0.077/0.037/0.035/0.134/0.001
Region: 49-State 50.0:50.0/50.0/50.0 MPH (50.0) 10.0/ 10.0/ 10.0
AC: 0.66 XLoad: 0.04 0.20 0.25 Trailer: 0.02 ABSHUM: 75.00
COMPOSITE EMISSION FACTORS (GM/MILE)
No rune th HC
EVAP HC
Exhaust CO
Exhaust NO
Emission levels developed by MOBILE 1 program, presented in Tables 4-19 and
4-20, detail HC/CO emission levels without I/M; with I/M; and percent emission
reduction from I/M implementation; for county and statewide geographic options.
This information was provided for 1982 and 1987 I/M program years using
1977 as a base year. The second column for HC and CO shows total emissions in
1977. The third and sixth columns show emissions expected in 1982 and 1987
without an I/M program. The lower figures for both years are attributable to
the Federal Motor Vehicle Emission Control Program (FMVCP). The fourth and
seventh columns show the amount of emission reduction that would occur with
FMVCP and an I/M program. The fifth and eighth columns show the actual percent
emission reduction that may be achieved through implementation of an I/M
program. In all instances, the percent reduction for each county closely
approximates percent reduction values achieved over the entire state.
2. Fuel Savings
The amount of fuel saved by instituting a mandatory vehicle inspection
and maintenance program is a function of many variables. The following
parameters are of particular importance; vehicle miles traveled (VMT), fuel
efficiency, total vehicle population and stringency factor.
A 3.8 percent fuel economy improvement, per failed vehicle per year (as
established from California programs), was used in this study to calculate
fuel and dollar savings for the I/M program options.
LDV LDT1 LDT2 HDG HDD MC ALL MODES
4.37 4.75 6.50 10.75 2.35 6.28 4.43
2.06 2.22 3.23 2.56 0.0 1.60
28.51 30.31 32.22 138.15 14.14 18.01 30.69
4.22 4.20 6.82 13.46 23.87 0.16 7.26
146
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Table 4-19. HC EMISSION SEDUCTION WITH AND WITHOUT IMPLEMENTATION OF I/M PROGRAM FOR
1977 (Base Year), 1982, AND 1987 (Tons Per Year)
1977 1982 1987
COUNTY WITHOUT I/M WITHOUT I/M WITH I/M % REDUCTION WITHOUT I/M WITH I/M % REDUCTION
1. Lexington 5,961 3,962 3,748 5 2,313 1,793 22*
2. Richland 10,376 6,148 5,790 6 3,499 2,670 24*
3. Berkeley 2,421 1,527 1,434 6 919 697 24*
4. Charleston 9,205 5,335 5,028 6 2,920 2,216 24*
Total 27,963 16,972 16,000 6 9,651 7,376 24*
Statewide 89,662 56,086 52,785 6 31,870 24,358 23*
SOURCE:: Ref. 5
~Although the 1987 percent reduction does not meet the EPA reduction of 25 percent as specified in
Reference 1, the percent reduction could be within the error potential of the M0BILE1 program and
the State of South Carolina should not have any difficulty in meeting the required percent reduction
with the planned I/M program.
Table 4-20. CO EMISSION REDUCTION WITH AND WITHOUT IMPLEMENTATION OF I/M PROGRAM FOR
1977 (Base Year), 1982, AND 1987 (Tons Per Year)
1977 1982 1987
COUNTY
WITHOUT I/M
WITHOUT I/M
WITH I/M
% REDUCTION
WITHOUT I/M
WITH I/M
% REDUCTION
1.
Lexington
43,973
38,548
32,552
16
25,903
17,459
33
2.
Richland
79,829
60,983
51,112
16
39,160
25,944
34
3.
Berkeley
17,581
14,684
12,278
16
10,116
6,609
35
4.
Charleston
71,793
53,356
44,626
16
32,715
21,456
34
Total
214,176
167,571
140,568
16
107,894
71,468
34
Statewide
683,540
552,835
463,754
16
356,300
236,010
34
SOURCE: Ref. 5
-------
These parameters are related in the following way.
where:
['
G = (V /F ) X F x (T x S )
s m e c v f
G = Fuel gallons saved
s
V = Vehicle miles traveled per year
m
F = Fuel efficiency, miles per gallon, fleet average
e
F = Fuel consumption per failed vehicle = 0.038
c
T = Total vehicle population
v
Sf = Stringency factor =35 percent
The estimated number of gallons saved are then used in the following
calculation to determine fuel savings in dollars.
F = (G ) x (G )
s s p
where:
F = Fuel savings in dollars
s
G = Gallons saved
s
G = Estimated price per gallon ($0.70/gallon)
P
Differences in the above variables will directly influence fuel savings,
therefore, the following assumptions are noted:
o 11,500 miles traveled per year (V )
m
o 15 miles per gallon (Fg) fleet average in 1982, 24 miles per gallon
fleet average in 1987
As shown in Table 4-21, the four-county I/M option would save 5.48 mil-
lion gallons of fuel in 1982 and 4.07 million gallons in 1987. At $0.70 per
gallon, vehicle owners would save $3.84 million and $2.85 million for 1982 and
1987, respectively. If coverage is extended to include the entire state,
motorists would save 18.10 million gallons in 1982 and 13.45 million gallons
in 1987. This amounts to $12.67 million and $9.41 million for 1982 and 1987,
respectively.
148
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Table 4-21. ESTIMATED ANNUAL FUEL ECONOMY BENEFITS FOR FAILED VEHICLES
1982 SAVINGS 1987 SAVINGS
Fuel $ Per Fuel s P
OPTION Mil. Fal Million Vehicle Mil. Gal Million Vehicle
1. Four-County 5.48 $ 3.8 $7.14 4.07 $2.85 $4.46
(Lexington,
Charleston,
Berkeley,
Richland)
2. Statewide 18.10 $12.67 $7.14 13.45 $9.41 $4.46
In terms of fuel savings per vehicle, it would be $7.14 in 1982 and $4.46
in 1987. Less fuel savings per vehicle in 1987 is anticipated because of
higher fuel efficiency of automobiles. Moreover, the motorist who repairs his
failed vehicles will realize a saving in fuel cost as an offset to the repair
cost.
3. Effect on Vehicle Performance and Vehicle Life
The impact of I/M on these considerations is difficult to quantify. The
studies to date have not been conclusive. They have centered on the way I/M
affects short and long run vehicle deterioration curves. The short run
deterioration curve reflects the rate at which a vehicle deteriorates after it
has been tuned (Figure 4-3), while the long run curve reflects the overall
degradation in vehicle performance that occurs as it ages (Figure 4-4). Both
curves, especially the short run deterioration curve, influence vehicle
performance while the slope of the long run curve is more likely to be the
primary determinant of vehicle longevity. To the extent that I/M influences
the short run curve, it should have a positive impact on vehicle performance.
If an engine remains within the manufacturer's specifications, it should
perform at a higher level due to I/M.
The influence on performance and longevity resulting from I/M's impact on
the long run deterioration curve is unknown. It seems sensible that a properly
maintained vehicle will experience less wear than if it is not maintained to
manufacturer's specifications. Assuming this relationship is true, I/M should
have a positive effect on vehicle life. The repair of a vehicle can reduce
149
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EMISSIONS
RAPID
DETERIORATION
LINEAR
DETERIORATION
SLOW
DETERIORATION
TIME
Figure 4-3
POSSIBLE POST MAINTENANCE DETERIORATION FUNCTIONS SHORT RUN
-------
Figure 4-4
ACTUAL EXHAUST HYDROCARBON
LEVELS VERSUS MPC* LEVELS
Cars With Exhaust Controls
101-
a>
O)
t/t
o
fa
o
o
Actual Emission Level
Base Failure
*o
>¦»
4
1972 3.4
— 30% Rejection
-1972 FTP (CVS)
•XvX'IvXv.v.v • * •
•.y.'.v
(2-975 1.5 _
20 40 W 80
Cumulative Percent of Cars
100
"Minimum Pollution Capability - Life cycle deterioration curve
without any major repair.
NOTE: The MPC l«evel curve can vary drastically from vehicle-to-
vehicle. It depends upon abuse of the vehicle over heating,
over loading, etc.
151
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emissions to minimum pollution capability (MCP) line after repair to manu-
facturers' specification level.
4. Retest of Failed Vehicles
The benefits that will accrue from a retest of a failed vehicle after
repair are:
o An assurance that the repair has been accomplished.
o Provision of information leading to minimum repair costs and the
reduction of unnecessary repairs through the analysis of the data by
the State of South Carolina. From the data analyzed, the State can
evaluate and define procedure for performance of emissions-related
repairs.
o Provision of information for the Quality Assurance Section so that
they may establish the effectiveness of the program and the ability
of the private garage to accomplish the repair.
o The provision of data with regard to the repair industry. The
repair station may be required to be licensed and to have certain
test equipment and licensed repair personnel.
o An assurance to the vehicle owner that the repairs as completed have
corrected the malfunction and misadjustments.
o Support information for the follow-on mechanic course development
and necessity for such courses.
The California Vehicle Inspection Trial Program in 1975 to 1976 presented
the following statistics:
o 82 percent failed vehicles passed the retest
o 6 percent passed the subsequent reinspection
152
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o 64 percent had correct repairs to correlate with failure status
o The California Air Resourcs Board Surveillance Program indicated
that mechanics experienced considerable confusion in interpreting
and carrying out the repairs procedures.
From this data it is evident that there is a necessity to follow-up on
repair activities and to ensure that the repairs are accomplished in a manner
which will correct the failure mode.
a. Cost for Retest
The cost for retest have been included in the initial fee. Thus, the
retest would be carried out without supplementary costs. The retest load
would be in line with the stringency factor used. For example: 35 percent
stringency factor; Total Test Load = number vehicles to be inspected x 1.35.
It is assumed that only one retest would be required.
5. Value of Warranty Repair Work Performed
Section 207 of the Clean Air Act mandates a new vehicle and engine emis-
sions warranty which includes a general defects warranty in 207 (a), a perfor-
mance warranty in 207(b)* and an enforcement and recall provision in 207(c).
207(a) has generally been interpreted to require manufacturers to warrant
vehicles or engines to be free from defects in materials and workmanship that
will cause them to violate applicable regulations, including applicable
emissions standards.
A list of applicable emissions control items, interpreted as included
under this standard and, therefore, makes vehicle manufacturers liable for the
failure of these emissions-related part is presented in Appendix I. It is
assumed that these items could reasonable be expected to degrade the emissions
performance of a failure of the vehicle. 207 (b), which specifies a performance
warranty generally provided for in 207(a), cannot be implemented at the Federal
level until the administrator promulgates a correlatable short test on which
the performance warranty can be based. When the EPA determines that a short
^Throughout this report, "performance warranty" means a warranty that a vehicle's
emission will not exceed the certification emission standards for its useful
life, as evidenced by a correlatable short test.
153
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test is available which is "reasonably capable of being correlated" with the
official certification test, then manufacturers will be liable to correct
vehicles which fail such a test regardless of whether any specific part defects
have been identified.
Manufacturers argue that the Clean Air Act Amendments of 1977 showed that
Congress intended to limit the 207 (b) performance warranty to "hang-on" compon-
ents only (e.g., air pump, catalyst, EGR valve). Congress has diminished the
scope of the 207 (b) warranty to some extent and its interpretation needs
clarification.
It is assumed that the 207(b) warranty presently only applies to "hang-
on" components after 24,000 vehicle miles: before the 24,000 vehicle mile
point has been reached, however, 207(b) applies to a broader range of emission-
related components. This range is, as yet, undefined, since EPA has failed to
promulgate a specific list; however, it is clear that Congress intended this
list to be broader in application than the "hang-on" component definition.
Congress did not amend the scope of the 207(a) defects warranty; it still
applies to a broader range of emissions-related components (as yet undefined
on a Federal level) for the full useful life period of 50,000 miles. Warranty,
however, has limits with respect to abuse, and neglect of improper maintenance.
The repair or replacement of any emissions-related part otherwise eligible for
warranty coverage shall be excluded from such warranty coverage if the vehicle
engine, has been abused, neglected, or improperly maintained, and that such
abuse, neglect or improper maintenance was the direct cause of the need for
the repair or replacement of the part.
The State of California (Ref. 17) in 1977
• i .mi j.5// completed a surveillance test
program on 1975 to 1976 model-year vehicles. These vehicles were tested
using:
o CVS-75 test used in new car certification
o Federal highway fuel economy test
154
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o Loaded-mode test
o Acceleration/deceleration driving sequence EPA modal test
o Sealed housing evaporative determination (SHED) test
Only 9 percent of the vehicles failed because of a defective components.
These defective components may not have been covered by warranty because of:
o lack of maintenance
o abuse of vehicle
o others.
It is, therefore, evident that the subject of warranty repair work per-
formed requires further study and definition to form a basis for analysis.
For this study it was assumed that approximately 4 percent of the less
than 24,000 miles vehicle had defect parts prior to testing and would require
warranty parts replacement. The average cost of such a replacement would be
approximately $35.*
E. INDEPENDENT PROGRAM VARIABLES
1. Enforcement
a. Program Enforcement Alternatives
This section will examine proposed enforcement mechanisms that could be
adopted to compel vehicle owners to comply with requirements outlined in the
South Carolina SIP. The analysis will address two enforcement alternatives
related to light-duty vehicles, specifically, 1) withholding vehicle registra-
tion, and 2) change of ownership.
Vehicle Registration — The South Carolina Vehicle Registration System
provides for a fully computerized and efficient data-handling system that
continuously processes detailed information on owners (name, sex, age, driving
*This data is based upon a California ARB communication.
155
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history, etc.) and vehicles (make, model, year). This information is con-
stantly updated and is readily available to governmental agencies directly
concerned with I/M program requirements. These factors identify the vehicle
registration system as a likely candidate for an emission test enforcement
control point.
The vehicle registration system could provide for an annual inspection
process by making an emission test a necessary prerequisite for the successful
completion of the registration process. Upon receipt of vehicle registration
renewal application, the owner would be required to obtain a Certificate of
Compliance from a Certified Emission Test Station within a specified period of
time (e.g., 30 days). A condition of noncompliance would result if the vehicle
owner:
o Ignores emission test requirements
o Fails to pass established emission test standards
o After failure of emission test, does not obtain the necessary repairs
and retest.
Noncompliance would result in nonregistration of the vehicle and, in
effect, deny the right to operate the vehicle.
b. Change of Ownership
As a prerequisite for transferring the title, the new owner would be
required to supply a Certificate of Compliance demonstrating that the vehicle
complies with established emission standards.
156
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2. Repair Analyses and Consumer Protection
This section reviews major program components, needs, and problems associ-
ated with a comprehensive emission repair consumer protection effort. These
requirements include:
o Designation of lead agency to assume overall consumer protection
responsibility.
o Implementation of consumer protection programs and issues.
o Regional responsibility of consumer protection implementation,
a. Lead Agency Designation
Prior to I/M implementation, the South Carolina State Legislature should
expand the administrative authority of the Consumer Affairs Office (CAO) to
include a comprehensive emission repair consumer protection program. This
would enpower the CAO to develop and establish procedures to implement warranty
protection standards and guidelines requiring:
o The repair and/or replacement of emission control systems during the
warranty period.
o That vehicle manufacturers produce durable, maintenance free emission
control devices.
o Recall and field repair programs when justified by an unusual number
of failed emission control devices.
o That replacement components are available and not inferior to the
Original Equipment Manufacturer's (OEM) equipment.
The CAO could also institute procedures to review complaints that relate
to emission control component failures and would cooperate and assist other
157
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departments associated with I/M programs that are germane to consumer protec-
tion. Finally, the CAO would institute certification/qualification criteria of
service industry emission repair.
Additional responsibilities that relate to I/M program requirements and
needs include the areas of:
o Education - assists in the development of consumer education programs.
o Hearings - conducts public hearings that involve emission repair
rules and regulations.
o Promotion - promotes ethical standards of business conduct in the
emission repair industry.
o Information - Advises the public, the Governor, and the Legislature
on all matters that affect on-going I/M requirements.
o Representation - represents the consumer's interest before Federal
and State Legislative hearings and executive commissions.
b. Implementation of Emission Repair Consumer Protection Program
The proposed emission repair consumer protection program may be summarized
under the following categories:
o
Warranty protection
o
After-market parts program
o
Modified parts program
o
Recall/defects program
o
Grievance and complaint procedures
o
Certification criteria for repair facilities
o
Repair cost ceilings
o
Public information.
158
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A brief description of the scope of the emission repair consumer protection
program for each category follows:
Warranty Protection - The Motor Vehicle Emission Control Office (MVECO)
should develop and establish regulations to ensure that vehicle owners are
protected from abuses related to the 24-month, or 24,000 miles, warranty
provision set forth in the Emission Control System Performance Warranty of
Section 207(b) of the Clean Air Act 1977 Amendments. The Emission Performance
Warranty further requires the automobile manufacturer to warrant the catalytic
converter, thermal reactor or other components installed on or in a vehicle
for the sole or primary purpose of reducing emissions for a period of 50,000
miles or 5 years, whichever comes first. Appendix I list emissions-related
equipment which should be identified within this warranty coverage.
The manufacturer must bear the cost of repair of any properly maintained
and operated vehicle which fails an EPA-established emissions test within 24-
month/24,000-mile or 5-year/50,000-mile, as appropriate.
After-Market Parts Program - This program is separate and distinct, and
should be reviewed in light of the effect of such parts on emissions control.
The replacement parts manufacturer should be responsible for the original
equipment performance requirements to ensure a continuity in emissions control.
Modified Parts Program - Provisions should be made to ensure that vehicle
owners do not install equipment such as bleeder valves which may have a decided
effect on emissions. Such a program may require that equipment be certified
by the state as not having a significant effect on emissions prior to the sale
of such products within the state.
Recall and Defects Control - Consideration is required with regard to the
follow—through of recall and original manufacturer's defective parts programs
as to how each problem relates to test site operation and follow-through
assurance that the dealerships respond to the installation requirements of
related repairs. These do have a decided effect on emissions in many cases.
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Consumer Complaint Management - In the initial phases of the I/M program,
some complaints may emanate as a result of inspection procedures and personnel,
but it is more likely that the majority of complaints will be in relation to
repair actions. It is important that these complaints are processed rapidly
and acted upon within a reasonable period of time. If justified complaints
are not resolved to the satisfaction of the consumer, adverse public reaction
to the I/M program concepts may result.
The CAO could provide efficient mechanisms to process complaints concerning
warranty protection, overcharging and unnecessary repairs by individual garages,
as well as complaints about the program in general. These mechanisms would
include: 1) a statewide information and referral system available through a
toll free number, and 2) complaint forms available at each inspection facility.
Once the complaint is received through other processes, a consumer representa-
tive would attempt to resolve the problem over the telephone. If the complaint
is not resolved to the satisfaction of both parties, the consumer representative
would refer the matter to the Motor Vehicle Emission Control Office for further
arbitration.
In addition to the complaint service, the Automotive Division of the CAO
would maintain permanent records of consumer complaints on each repair facility.
If too many complaints about any one facility are received, the CAO could
investigate, and revoke the license of the garage if the claims were justified.
Certification of Repair Facilities - Ultimately, an i/m program can
accomplish emission reduction only if it increases the frequency and quality
of vehicle maintenance than would have occurred voluntarily. Clearly, the
quality of the maintenance performed in response to emission inspection failure
will have an important impact on I/M program effectiveness and cost. The
performance of service garages participating in emission repair work has been
evaluated from two viewpoints. One viewpoint has considered the capability of
repair agencies to perform emission-related work; and the second, the extent
of unwarranted repair, and the resultant unnecessary cost burden.
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A recent California study has examined the ability of repair facilities
to follow Motor Vehicle Inspection Program (MVIP) repair procedures for dealer-
ships, service stations, and independent garages. Table 4-22 presents data
indicating that of those repair facilities surveyed, approximately 26 percent
and 56 percent did not follow established repair procedures for idle and
loaded tests, respectively. Also, it was found that when repaired vehicles
were returned for reinspection, approximately 16 percent (idle) and 29 percent
(loaded) failed emission retest (Table 4-23) . This suggests that there is
need for close supervision of emission repair facilities.
In view of the above information, the Motor Vehicle Emission Control
Office would establish stringent certification and qualification criteria for
emission repair garages. Repair garages approved for emission repair work
must:
o Employ at least one mechanic certified to perform emission repair
work.
o Own or lease analyzers capable of accurately measuring HC and CO
levels.
o Provide incentives for mechanic retraining every 1 to 2 years.
In addition to the above qualifications, each garage should serve a
minimum probationary period of at least 1 year. This would include close
supervision of the repair operation using correlation vehicles and referee
stations to check the adequacy of repair maintenance.
Repair Cost Ceilings - Another responsibility of the Motor Vehicle Emission
Control Office includes the regulation of emission repair costs. This would
be accomplished by fixing maximum price ceilings on all emission repair work.
Table 4-1 examined the effect of reducing the maximum repair cost ceiling on
percentage of failures repaired, average repair cost, average fuel economy,
and total emission reduction. For example, as the maximum repair cost is
reduced from $150 to $100 ($10 increments) there are no observed reductions.
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Table 4-22. ABILITY OF REPAIR FACILITIES TO FOLLOW THE MVIP REPAIR PROCEDURES
IDLE REGIME LOADED REGIME BOTH REGIMES
Total Did Not Follow Total Did Not Follow Total Did Not Follow
Repaired Repair Procedure Repaired Repair Procedure Repaired Repair Procedure
Dealerships
34
7
(21%)
83
51
(61%)
117
58
(50%)
Service Stations
24
9
(38%)
117
57
(49%)
141
66
(47%)
Independents
87
22
(25%)
96
58
(60%)
183
80
(44%)
ALL
145
38
(26%)
296
166
(56%)
441
204
(46%)
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Table 4-23. REPAIRED VEHICLES WHICH FAILED REINSPECTION
IDLE REGIME
TOTAL REPAIRED
FAILED FIRST
REINSPECTION
WAIVED
FAILED FIRST REINSPECTION,
EXCLUDING WAIVED VEHICLES
Dealerships
34
0 ( 0%)
0
( 0%)
0
( 0%)
Service Station
24
6 (25%)
3
(13%)
3
(13%)
Independents
87
17 (20%)
8
( 9%)
_9
(10%)
ALL
145
23 (16%)
11
( 8%)
12
( 8%)
LOADED REGIME
TOTAL REPAIRED
FAILED FIRST
REINSPECTION
WAIVED
FAILED FIRST REINSPECTION,
EXCLUDING WAIVER VEHICLES
Dealerships
83
20 (24%)
10
(12%)
10
(12%)
Service Stations
117
36 (31%)
20
(17%)
16
(14%)
Independents
96
30 (31%)
13
(14%)
17
(15%)
ALL
296
86 (29%)
43
(15%)
43
(15%)
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However, if the maximum repair cost is lowered below $100 (baseline), there
are 2 percent to 4 percent reductions in every category. This seems to indicate
that there is a compromise point between what the public is willing to pay
(repair cost ceiling) and the desired level of emission reduction, fuel economy,
and average repair cost.
Once the maximum repair cost ceiling is established, vehicles with consumer
repair work exceeding the cost ceiling would be exempt. This avoids placing
undue economic hardships on owners. The cost of exempting certain vehicles
from having emissions-related repair work performed is the reduction in the
overall effectiveness of the program. Given the relatively small percentage
of major emissions-related repair work, however, it would appear that little
decrease in overall emissions reduction would result from the exemption of
some vehicles. This is based upon the fact that in Oregon and Arizona only
2 percent of the tested vehicles cost more than $100 to repair. In New Jersey,
the figure was 5.6 percent. It would appear, therefore, that the gains in
terms of public acceptance would tend to outweigh any decrease in emission
reduction resulting from the waiving of repair requirements for certain
vehicles.
Recent studies have shown that the average repair cost is estimated to be
within a range of $26 to $34 for idle/loaded test regimes, prior to year 1975
(Table 4-24a). In addition, there is a $2 to $8 overcharge that is directly
attributable to unnecessary or unwarranted repair work. This problem can be
remedied only if the inspection station provides accurate diagnostic and price
information for the consumer.
All repair costs in Table 4-24b were result from various studies. The
recent Arizona I/M experience revealed that the average cost of repairs to
failed vehicles was $23.02 during 1977. These costs ranged from zero for
warranty repairs to cover $600 for an engine overhaul. Table 4-24 presents
the average cost of repairs for various model year groupings versus facilities
performing the repairs. The analysis of total repair costs indicated that 50
percent of the vehicles were repaired for less than $11.25 (Ref. 21).
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Table 4-24a. AVERAGE REPAIR COSTS - FAILED VEHICLES'
IDLE IDLE LOADED MODE LOADED MODE
TOTAL OVERCHARGE TOTAL OVERCHARGE = DEFINE
California Study {Ref. 2)
Northrop (Ref. 3)
EPA (Ref. 4)
Olson (Ref. 5)
$21
$34
$26
$26
$2
$8
$23
$30
$28
$5
$7
35%
50%
50%
50%
Unadjusted dollar costs in various years.
Table 4-24b. ARIZONA - 1977 REPORT (REF. 21)
TYPE FACILITY 1964-1967 1968-1977 1964-1977
Franchised dealers $41.25 $26.82 $27.97
Service stations 23.06 19.81 21.14
Merchandisers 15.53 20.29 19.43
Tune-up specialists 36.19 22.86 24.72
Independent garages 21.33 27.46 26.79
"Do-It-Yourselfers" 14.27 20.61 19.08
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In turn, the consumer can go to an approved repair facility and request
specific repairs, fully confident that an established price will not be
exceeded.
Public Information Program - Many questions raised by I/M implementation
can be properly addressed through a well-designed and comprehensive public
information program. It can help to eliminate adverse public criticism by
stressing the purpose, objectives, benefits, and operation of I/M. Emphasiz-
ing the checks and balances (e.g., quality assurance) designed into the I/M
program and health benefits from emission reductions will alleviate many
problems associated with the implementation procedure.
A public information program can address other benefits to the vehicle
owner. Improvements on fuel economy, vehicle performance and longevity are
important to vehicle owners. Control of vehicles that emit annoying quantities
of smoke, and assurances that I/M requirements will extend to all vehicles are
important points to stress.
This is accomplished by effective use of advertising techniques that
utilize the mass communication media (e.g.; radio, television, newspapers,
etc.), information centers, education programs, citizen group contacts, etc.
In the early stages of I/M implementation, initial program information should
include:
o Explanations that outline control procedures and derived benefits
from automotive emission controls.
o Explanations of what automotive equipment requires inspection.
o Identification of the most common causes for emissions failure.
Supplemental information is required after the public has accepted the
need to understand the concepts of I/M. This additional information includes:
o The location of test facilities.
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o Instructions and fee requirements.
o Explanation of retest requirements and conditions.
o Importance for allowing time for repair, and retest, or considerations
for waiver.
o Explanation of complaint referral system,
c. District Responsibility of Consumer Protection Implementation
The responsibility of implementing an emission control consumer protection
program on a regional basis belongs to the "Emission Control Investigative
Unit" (ECIU)—the investigative arm. of the Vehicle Inspection Office. The
primary function of the ECIU is to prevent fraudulent automotive emission
repair practices on vehicles identified as having failed to meet emission
standards. These fraudulent emission repair practices include overcharging
and performing unnecessary or unwarranted repair work. Under I/M program
requirements, the automotive emission repair dealer must:
o Supply the consumer With a written estimate before any emission
repair is performed. The estimate is calculated by using state
established emission repair prices.
o Obtain authorization for any expense in excess of the original
estimate, and not to exceed the maximum repair price ceiling.
o Provide the consumer with an itemized invoice clearly showing all
labor and parts supplied, tttis fully informs the consumer of the
cost and nature of the emission repairs performed on the vehicle.
o Refrain from false advertising, misleading statements, or promises
intended to induce an uninformed consumer to agree to unnecessary
repairs.
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The ECIU accepts and processes cotrgplaints that involve infractions of any
of the above four regulations. Consumer representatives of the CAO operate a
statewide information and referral network through which consumers may register
their complaints. An attempt is made by the consumer representative to satisfy
the complaint by contacting the emission repair dealer. If there is no agree-
ment, the complaint is referred to a field investigator of the ECIU. The
responsible investigator will meet with the consumer and repair dealer and, in
some instances, examine the repair work to ensure that provisions of the law
are satisfied. Under unusual circumstances, investigators may at their dis-
cretion use a specially outfitted surveillance vehicle to check the integrity
of emission repair work. If there is sufficient evidence of consumer fraud,
the matter will be turned over to the CAO for further investigation, and
possibly prosecution.
The ECIU will also have the responsibility of testing and licensing indi-
vidual facilities as official emission repair stations. When an automotive
repair facility employs an individual trained in emission control equipment
repair, and owns or leases approved emission HC/CO analyzers, the facility may
apply for a license as a State Approved Emission Repair Facility. Field
investigators will make periodic checks of all licensed stations to inspect
all phases of emission repair work. Any irregularities in the operation,
quality of repair work, pricing, etc., may result in revocation of the license.
In cases that involve flagrant violations of consumer rights, the ECIU
may request that the CAO begin proceedings against certain repair facilities.
It should be anticipated that many cases would be settled by decree or voluntary
compliance. However, when there is evidence of serious violation, cease and
desist orders should be sought. The CAO would decide whether a formal complaint
is required, enter into a consent settlement and, if necessary, try the case
before a hearing examiner. Where consumer abuse is localized, the CAO would
establish a liaison with and refer the matter to municipal or county authorities
for possible criminal investigation.
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3. Quality Assurance
a. Inspection and Maintenance Equipment Standards
The equipment standards are classified and discussed according to the two
following categories: sampling system considerations and selection, and gas
analyzer considerations and selection. The sampling system and gas analyzer
considerations sections discuss the various technical problems and solutions
associated with the analysis of vehicle exhaust gas emissions. The selection
sections discuss the basic requirements for the equipment to adequately
perform the analysis.
Included in this section is a table giving relevant information concerning
a small sample of gas analyzer systems currently available and suitable for an
I/M program. Within this information are specifications defining the ambient
conditions necessary for valid emission analysis.
Sampling System Considerations - Exhaust gases are extremely complex
mixtures of HC, CO, NO^, aldehydes, particulates, water, nitrogen, oxygen,
hydrogen, and many other compounds. To accurately measure any single pollutant,
the application of proper gas sampling techniques and careful sample handling
treatment prior to instrument analysis are required. The basic consideration
must be to obtain a sample of exhaust gas which is completely representative
of the vehicle exhaust for the operating condition of interest.
It becomes necessary to selectively remove those materials and compounds
which may affect the absolute measurement of the subject pollutant without
changing the concentration or characteristics of that pollutant. In a practical
sense, this generally means reducing the water vapor level in exhaust gases
and filtering out the particulates before passing the gas sample through a
measuring instrument. Additionally, the sample handling system must also
Provide for the periodic inputting of zero and span check gases and calibration
gases.
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Sampling System Selection - The sampling system may consist of a tail
pipe probe, sample line, vapor condensor, particulate filter(s), sample pump
and appropriate valves for the check and calibration cycles and for purging
the system. In the definition of a sampling system, the following need to be
considered:
o Avoidance of materials that are subject to corrosion, deterioration
and HC hang-ups.
o Adequate flow rates for fast system response.
o Rugged construction of sample lines and probes to withstand heavy
usage.
o Filtering system of adequate capacity and serviceability.
o Adequate provisions for water removal.
Gas Analyzer Considerations - The heart of any automobile exhaust emission
test system is the instrument component required to measure the levels of
pollutants. Depending on the type of test being conducted, the analyzers will
vary from relatively simple and inexpensive to highly sophisticated versions.
A large number of sophisticated exhaust gas analysis systems have been
assembled and used in research programs and in the certification and quality
audit of new cars to evaluate their compliance with state and Federal standards.
At the other end of the spectrum, some relatively simple analyzers are being
used by garage mechanics and tune-up technicians to assist in adjusting engine
operating parameters during maintenance. The instrument system required in a
mandatory inspection program probably lies somewhere between these extremes.
Typical Gas Analyzer Selection - For I/M applications, prior to the
selection of the exhaust emission analyzers, the emission inspection limits
should be reviewed to ensure that all necessary ranges are considered. With
the introduction of catalytic reactors and other refinements on new vehicles
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to comply with emissions standards, engineering estimates should be used to
predict the measurement levels anticipated in the near future. Other factors
to be considered in defining instrument specifications include accuracy, speed
of response, stability, effect of interference gases, ease of operation, and
maintenance.
Carbon Monoxide - The most commonly used method for CO measurement in
exhaust analysis is the nondispersive infrared (NDIR) technique. These instru-
ments are based on the principle that the infrared absorption spectrum of the
measured gas is sufficiently unique as compared to any other exhaust component
gas, and that measurement of infrared energy absorption is proportional to the
concentration of the component of interest in the presence of other gases.
The sensitivity of the NDIR instrument is proportional to the physical
length of the sample cell. CO monitors have been built for ambient air monitor-
ing which can detect CO in the 1 ppm range. The sensitivity requirement for
exhaust CO analysis is much less severe because the concentrations in exhaust
gases are orders of magnitude higher than in the atmosphere.
On the high end, CO is occasionally observed in the exhaust gases of
uncontrolled (pre—1968 model) cars in concentrations above 10 percent. On the
low end of the range, some properly tuned and adjusted engines on controlled
cars will produce CO concentrations lower than 0.1 percent during idle and
cruise modes of operation. Thus, the CO instrument should provide accurate
readouts over the range of 0 to 10 percent. A preliminary conclusion is that
the CO analyzer required for the mandatory inspection program will require two
or more gas concentration ranges from 1 to 10 percent.
Hydrocarbons - The analysis of HC in automotive exhaust gas is complicated
by several factors. HC are a complex mixture and their concentrations vary
over an exceptionally wide range. The NDIR technology may also be used for HC
measurements or, as in current Federal mass testing, the Flame Ionization
Detector (FID) is used.
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NDIR analyzers using detectors sensitized with N-hexane had been the
standard for measurement through 1971. FTP for 1972 and subsequent years
specified use of FID due to the higher sensitivity required for dilute exhaust
gas measurement. Neither instrument method is clearly superior and either
method can be incorporated into a mandatory inspection program. Presently,
the NDIR analyzer has been most successfully adapted to a relatively low-cost
rugged analyzer for inspection use, but the characteristics of FID analyzers
need to be examined also.
FID instruments are significantly different from NDIR analyzers in that
they measure the total HC present in a sample of exhaust gas. The FID method
also can be electronically switched over a wide concentration range making
only one instrument necessary in those test modes which require high dynamic
range. The measurement of total HC is, however, not necessarily desirable for
two reasons:
o Methane contributes to the response in the FID instrument; but,
being a nonreactive component, it is debatable whether it should be
included in HC measurement.
o Since the NDIR method is the only one used at the repair shop level,
and the NDIR does not respond to methane, correlation between the
inspection station and repair shop would be questionable if the FID
were used for inspection.
Another important consideration in the selection of the instrumentinn is
the wide range of values required to measure HC concentration in the various
modes of vehicle operation. During vehicle testing, HC concentrations of a
few thousand ppm are commonly observed and, occasionally, values in excess of
10,000 ppm are observed. Conversely, observed values of less than 50 ppm are
common in the exhaust of well adjusted 1972 to 1974 emission controlled cars
operating in steady-state modes; even lower values are observed with 1975 and
later vehicles.
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For the I/M exhaust emission program, the NDIR analyzer is probably the
best choice because it is reasonably stable and trouble free. Calibrations
and maintenance procedures are well defined and their effectiveness well
established. Many thousands of these instruments, produced by several major
manufacturers, are being used very successfully in automotive exhaust emissions
analysis.
For the final analyses, the selection of HC instrumentation depends on
the degree of measurement accuracy and ranges required based on an evaluation
of the exhaust emissions inspections standards established by the state.
Table 4-3 provided information concerning a small sample of exhaust emission
analyzers suitable for use in an I/M program.
b. Inspection System Quality Assurance Plan
The Quality Assurance Plan is classified according to the four following
categories: daily operational checks and adjustments, scheduled preventive
maintenance, major maintenance and repair, and periodic instrument calibration
checks. The first two categories are conducted on a routine, as-required
basis and are performed during normal working hours by inspection facility
personnel. Major maintenance should be available on an on-call basis by fully
trained service personnel supplied by the appropriate instrument manufacturing
company. The major maintenance service personnel would repair and overhaul
major equipment and have available a complete stock of spare parts and major
equipment replacement units. Periodic instrument calibration checks would be
performed by qualified state inspectors dispatched from a central state-
operated facility. The state inspectors would conduct the calibration checks
using a fully equipped mobile test unit.
Daily Operational Checks and Adjustments - Daily operational checks of
the vehicle inspection system would be performed by inspection facility person-
nel prior to opening for business. The daily operational checks schedule is
shown in Table 4-25.
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Table 4-25. DAILY OPERATIONAL CHECKS AND ADJUSTMENTS
CHECK ADJUSTMENT MAINTENANCE
NDIR Gas Analyzer
Sample Handling
Working gases
Zero and Span. One/
shift by the super-
vising inspector and
one per six tests by
inspection personnel
None
Replace filters or
damaged sample probe
as required
Check cylinder gauge
pressure and replace
gas cylinder as
required
Temperature, flow
and pressure check
once/shift by in-
spection personnel
Turn on gas and ad-
just output pres-
sure if necessary
The NDIR CO/HC analyzers require initial zero and span check to verify
that the test lane operational status is according to specifications. The
NDIR gas analyzers would be zeroed and spanned manually at the beginning of
each work shift by the supervising inspector or surrogate. For the remainder
of the shift, the inspector should compensate for minor zero or span shifts
once every six tests. Repeated zero and span drift error will require that
the analyzer receive first eche'lon maintenance.
At the beginning of each shift, the temperature of the water bath would
be checked and adjusted as required. The pressure and flow of the exhaust
sampling system would be checked and adjusted to specified values by the
supervising inspector or other inspection personnel. Cylinder pressure of the
working gases (zero and span for the NDIR analyzer) would be checked each
shift and new cylinders will be installed by the facility personnel if the
pressure drops below 100 PSI.
Scheduled Preventive Maintenance - Preventive maintenance of the vehicle
inspection system would be accomplished on a scheduled basis and integrated
into the daily operational checks by the inspection facility supervising
inspector.
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Preventive maintenance for the sampling system would be performed at the
beginning of each shift. The tail pipe sample probe and sample line would be
checked for damage and restricted sample flow. The water trap and aspirator
would be checked for deposits and cleaned as required. The exhaust gas filter
would be checked and replaced as required.
The preventive maintenance for the analyzers would be performed periodi-
cally as specified by the instrument manufacturer.
First Echelon Repair - Daily operational checks and adjustments or periodic
calibration and preventive maintenance activities may reveal a functional
problem or a defective component. The inspection facility personnel would
perform the required maintenance when the problem can be readily isolated down
to available spare parts. Two categories of spares would be maintained:
(a) operating disposable spares including filters, and (b) field replaceable
spares including indicator lights, fuses, and sample probes. All repair
activities would be in accordance with equipment manufacturer's repair and
adjustment procedures.
Major Maintenance - Those system failures which cannot be corrected by
inspection facility personnel due to problem complexity, spare parts, or
troubleshooting instrumentation, would be referred to the appropriate manufac-
turing company responsible for major maintenance. The inspection facility
supervising inspector would inform the manufacturer of the problem, provide a
detailed description of the malfunction and describe the impact on vehicle
testing. Based on these descriptions, the manufacturer would dispatch the
skilled service personnel and required resources to accomplish the field
repairs.
To perform the vehicle inspection systems repair and to limit system
downtime, components for the systems would be maintained by the manufacturer.
When a system failure occurs and the failed component can be promptly identified
by the vehicle inspection facility, the replacement component would be dis-
patched from the manufacturer so that the equipment can be repaired and
recalibrated.
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Periodic Calibration Checks - Periodic calibration checks would be per-
formed at 90-day intervals. These periodic calibration checks would be per-
formed by qualified state inspectors. The state inspectors would operate out
of a mobile test unit dispatched from a centrally located state facility. The
mobile test unit would be equipped with an NDIR gas analyzer, remote tachometer,
!i percent calibration gases, tachometer calibrator, field-type diagnostic
equipment and field replaceable spare parts. For customer and facility owner
convenience, the calibration checks would be prearranged to allow for scheduled
downtime. The expected downtime involved for each facility calibration check
is one hour, providing that no problems are encountered. The periodic calibra-
tion check schedule is shown in Figure 4-5.
The remote tachometer calibration check would be performed using the
tachometer calibrator, and necessary adjustments and repairs would be made per
manufacturer1s specifications.
The NDIR gas analyzer would receive a 5-point calibration test with
!1 percent certified calibration gases; any necessary adjustments and mainte-
nance would be made per manufacturer's specifications.
A correlation test would then be performed using the state mobile unit as
the test vehicle. The mobile unit would receive one emission test using the
facility instrumentation and one emission test using the state-owned instrumen-
tation located on board the mobile test unit. The emission test results would
then be compared for accuracy.
If the calibration check and correlation test results fall within the
specified range, the inspection facility would receive a 90-day certification.
If the inspection station fails the calibration check and/or the correlation
test, it would not be recertified and, therefore, would not be able to perform
emission testing. It would then be the responsibility of the facility to have
the equipment corrected and to contact the Motor Vehicle Division (MVD) to be
rescheduled for calibration testing.
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Figure 4-5. STATION CERTIFICATION PROCEDURE
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Referee Vehicle - Customer complaints will arise regarding the reliability
of emission test results, especially in cases where a vehicle fails an emission
test after the recommended repairs have been performed. In order to resolve
complaints of this nature, a referee operation must be set up. For convenience
to the customer and the MVD it is recommended that the mobile test units which
are used for periodic instrumentation checks, also be used as referee operation.
Upon receipt of a customer complaint and request for verification of emission
test results, an appointment would be made to conduct the verification test at
the test facility in question. The appointment time can be arranged in such a
way as to be convenient to the mobile test unit, perhaps when the unit is in
the general location performing its usual task. The result of the verification
test conducted by the state inspectors should be final.
To avoid an overload on the system, specific criteria would have to be
developed to single out complaints of possible validity for verification
testing. For example, vehicles which have failed after the recommended repairs
were performed and/or vehicles for which the recommended repair costs are
above some predetermined level would be eligible for verification testing.
4. Data Management System Design
Data management encompasses the flow of data from primary source to
ultimate use. The mandatory vehicle emission inspection program may be broken
down into three data management subsystems:
o Vehicle owner notification
o Vehicle inspection and repair
o Program effectiveness
These will be discussed separately with the interface between each pair
identified.
Vehicle Owner Notification - Satisfactory completion of a vehicle emissions
inspection would be required prior to initial and annual motor vehicle registra-
tion. Annual registration would be accomplished on a month-to-month basis.
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Notification of registration renewal would be supplied to the owner approxi-
mately 2 months prior to the final date for renewal. This would provide
sufficient time for the owner to have his vehicle inspected, to have any
required repairs completed, and to be retested. The most expedient and least
costly way to notify the owner of the inspection requirement would be as part
of the automobile registration renewal packet.
Two items of information would be required for inclusion in this packet:
o An explanation of the requirement and instructions for accomplishment
of the inspection.
o A Vehicle Identification (VID) card to be used by the inspection
facility to identify the vehicle and applicable exhaust emission
data; e.g., emission control^ device (s) installed, appropriate emission
levels, etc.
Vehicle Identification Card (VID) - A VID card would be provided which
contains sufficient information to identify the vehicle to be inspected. This
fixed information would be recorded on the inspection report form along with
variable information such as odometer reading and inspection number. The VID
card must be presented in legible condition, along with the automobile regis-
tration renewal card, to the inspection facility personnel prior to inspection.
Lost VID cards would be duplicated at the facility office. In no case would a
vehicle be tested without this documentation. The two documents and the
vehicle would be compared for accuracy and for missing data.
At the beginning of the inspection program, it is known that some of the
data required for accomplishing the inspection will not be available from the
DMV. Missing data may include:
o Vehicle weight class
o Emission control systems installed
o Number of cylinders
o Applicable emissions standard code
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These would be determined at the initial inspection and marked on the VID
card. It could also be noted on the automobile registration card retained by
the owner and on the portion retained by the MVD so that their files can be
updated.
It would be the vehicle owner's responsibility to safeguard this VID card
for use at subsequent vehicle inspections (e.g.; next annual registration,
installation of a different model-year engine or an engine with a different
number of cylinders, change of ownership, etc.). Should any of the information
on the card require a change, it would be necessary for the vehicle owner to
go to a designated site to obtain an updated card. Should the owner lose or
destroy his card, he would be required to pay a fee for its replacement. This
will entail the transcript of information from his automobile registration
card and perhaps a physical inspection of the vehicle if data are missing.
Safeguards Against Fraud - It is reasonable to believe that some persons
might try to beat the system by altering the information on the VID card to
put the vehicle in a less stringent emission standards category and/or change
the emissions control system requirement code. This can be overcome by using
a card on which is imprinted the state insignia and by using special codes for
identifying applicable standards and emissions control systems required.
Use in Identifying Retests - It would be necessary for a failed vehicle
to return to the inspection facility at which it failed for a retest after
repair. This would ensure that corresponding inspection and repair data are
collected and greatly simplify data handling. Proper forewarning should
reduce any inconvenience to the motorist.
Other persons might also use the inspection system as a low-cost diagnostic
center whenever they suspected a problem with their vehicle. In one sense
this is good, if a high polluting vehicle is detected and repaired voluntarily,
but this places an unnecessary burden on the system.
Keeping track of the number of inspections is important, and it may
become necessary to charge an additional fee for retests above some basic
quantity, to discourage inefficient or ineffective repairs.
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An effective method of accomplishing all of these safeguards would be to
use a stamping device, much like a timeclock, to imprint the VID card with the
facility number, date and time of an inspection. It would then be easy for
the inspector to determine whether the vehicle was in for a retest, since only
a short period (less than 2 months) would have elapsed since the last stamped
test, and if he were at the correct facility for a retest. Approximately 12
of these imprints could be placed along the 3-1/4-inch edge of the VID card so
the same card could be used through several years of inspections and retests.
A replacement fee would discourage the vehicle owner from destroying his card
to avoid paying a retest fee, or having to return to the facility at which his
vehicle failed. Otherwise, it might also become necessary to imprint the back
side of the automobile registration card as a double precaution since this
would also be checked each time the vehicle was submitted for a test.
The alternative is to rely on the motorist to tell the inspector whether
he is in for a retest or not. The driver, who would not necessarily be the
owner, may honestly not know.
Vehicle Inspection and Repair - The data management responsibilities at
the inspection facility would include the checking of registration documents
to establish which emission standards are to be applied, checking the repair
summary for completeness (if a retest, as noted by a recent date on the VID
card) and checking certificates of retrofit installation (if required). If a
retest, a copy of the previous inspection report form would be pulled from a
Retest File for comparison.
Additional responsibilities would include the control of the information
flow through the inspection process, the distribution of copies of the inspec-
tion reports depending on the inspection results, and the correlation of
repair data with retest data. As an example, the flow of this data is shown
in Figure 4-6. All hard-copy data would be retained at the facility for a
period of at least 18 months.
Inspection Report Forms - The Inspection Report Form, Figure 4-7 would be
completed in the following way. The information to be recorded from the VID
181
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Figure 4-6
EXAMPLE OF TEST FACILITY DATA FLOW
182
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VEHICLE INSPECTION REPORT
INSPECTION DATE_
FACILITY NO.
LICENSE NO.
WEIGHT CLASS
TEST RESULTS:
LANE NO.
_YEAR_
CYL
_MAKE_
SMOG
MODEL
ODOMETER
FIRST TEST fl
RETEST NO. f~|
IDLE
2.500 RFIT -
HC, PPM
STD.
ACTUAL
CO, %
STD.
ACTUAL
[""^FAILED" VISUAL INSPECTTO^
DECISION: Q] PASS £3 FAILED THOSE MODES DESIGNATED BY F
DIAGNOSTIC INFORMATION:
SEE REPAIR PROCEDURE NO.
MEASURED PARAMETERS AND DIAGNOSTIC MESSAGES
Remarks
Il*sp. NO. INSP. SIGN.
Figure 4-7. EXAMPLE OF INSPECTION PROGRAM REPORT FORMAT
183
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card and visual inspection would include the year, make, model, number of
cylinders, and smog code. Other information to be recorded would include
license number, weight code, odometer reading, facility code and test number.
Proper installation of the original equipment control device(s) would be
visually verified by the inspector. Other visual inspections will include
checking the exhaust system and inspecting for excessive fluid leaks.
The results of the visual inspection would be recorded on the vehicle
inspection report.
Visual Inspection Report Form - In the event that a vehicle fails the
visual inspection, the Visual Inspection Report form, Figure 4-8, would be
completed. Vehicles with original equipment control devices improperly
installed would be rejected without emission testing. Other reasons for
rejecting a vehicle prior to emission testing are exhaust system leaks and
excessive fluid leaks which could effect emission test results. One additional
reason for rejection after the vehicle is in place for emission testing is
excessive sample dilution due to a faulty exhaust system not detected visually.
Emission Testing - When it is determined that a vehicle is testable, the
emission test would be performed. Measured values would be recorded on the
Inspection Report form. Figure 4-7, and compared to the proper emission
standards. Based on this comparison, inspection personnel would make a pass/
fail decision. In the case of a failed vehicle, inspection personnel would
select proper diagnostic recommendations from the diagnostic chart and record
them on the inspection report form. Further diagnostic information derived
from visual inspections would also be recorded on the inspection report form.
Certification Forms - When the inspected vehicle's emission levels are
less than the established standards, and no repair is required, a Certificate
of Compliance would be issued. A copy of the Vehicle Inspection Report would
be given to the vehicle owner for his information. This may be of value to
his mechanic at the time of his regular maintenance especially for those
vehicles that passed marginally.
184
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-VISUAL INSPECTION REPORT
INSPECTION DATE
FACILITY NO. LANE NO.
LICENSE NO._ YEAR_ MAKE
WEIGHT CLASS CYL SMOG
TEST RESULTS:
THIS VEHICLE HAS BEEN REJECTED WITHOUT TEST BECAUSE:
REQUIRED EMISSION CONTROL DEVICES WERE FOUND TO BE
II DISCONNECTED OR MISSING. REPAIR OR INSTALLATION OF
PROPER DEVICES IS REQUIRED IMMEDIATELY
I I EXCESSIVE LEAKS IN EXHAUST SYSTEM
_MODEL
ODOMETER
FIRST TEST |~1
RETEST NO. |~f
fl EVAPORATIVE EMISSION LOSS COLLECTION SYSTEM
Remarks
^SP. NO. INSP. SIGN.
Figure 4-8. EXAMPLE OF REJECTION SLIP FOR VISUAL INSPECTION
185
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Failed Vehicles - Should the vehicle fail one or more emission inspection
modes, these failures would be denoted by the letter F (for failed) printed
after the numeric value, the diagnostic information to be provided would be
entered in the Diagnostic Information area. This would be an exception report
listing the most probable cause(s) for failure and the measured values for
engine parameters used to determine the cause.
The report format would provide a space for remarks to cover unusual
problems not covered elsewhere.
Diagnostic Chart - Diagnostic recommendations, selected from the diagnostic
chart, and values of key engine parameters would be recorded on the inspection
report form. Within the diagnostic chart various parametric criteria would be
used to identify the probable cause for high emissions. An abbreviated example
of a diagnostic chart is shown in Table 4-26. These charts would be developed
by the MVECO and distributed to each test facility upon certification.
Table 4-26. MALFUNCTION TRUTH TABLE
HC CO
Malfunction High Very High High Very High Rough Idle
PCV Valve Dirty/Restricted X X
Air Cleaner Dirty/Restricted X x
Choke Stuck Partially Closed X
Carburetor Idle Circuit Malfunction
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
Source: Northrop Study (Ref. 3)
Reports Distribution and Filing - Prior to distributing the inspection
reports, the certifying inspector would enter his identification number in the
appropriate space and sign the report. He would also stamp the VID card with
the facility number and date and return this and the automobile registration
card to the owner. After each vehicle's paperwork is completed, Copy 2 would
be placed in a basket marked passed or Copy 1 in a basket marked failed. At
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the end of each day the reports of failed vehicles would be placed in a Retest
File in license plate number order. If other failed reports for a given
vehicle are already in the file then the motorist should have returned the
previous test report and repair summary (Copy 2). Copy 1 of this previous
test should be matched to ensure that it is identical to the returned copy,
after which Copy 1 can be discarded.
Ultimately there may be one or more failed test reports and repair sum-
maries (Copy 2) and one passed test report (Copy 2) for each vehicle. Periodi-
cally, the Retest File would be checked to ensure that failed vehicles have
returned for their retest. A query to DMV periodically (perhaps quarterly) by
license number, should determine if the vehicle has been subsequently regis-
tered, sold, dismantled, abandoned, etc. This action is necessary to purge
the files.
For the system to be effective, the failed vehicles must return to the
same inspection facility after repair. The method of imprinting facility
number and date on the VID card described would provide the necessary control.
Maintenance and Repair Forms - The reverse side of each Vehicle Inspection
Report (Copy 2) would be printed with the repair summary form shown in Fig-
ure 4-9, and would provide for parts and labor cost information for emission-
related repairs. The description of these items would be pre-printed and used
as needed. Blank spaces are provided for additional materials or labor actions.
Recommended items, as specified by the inspection facility and previously
established by the MVD via the diagnostic chart, that were completed by the
garage would be so noted. Should additional space be needed, continuation
sheets would be used as shown in Figure 4-10. These sheets would be available
from the MVD in the form of pads. A fee should be charged for these pads to
ensure judicious use.
To ensure that data are not lost, it would be necessary to know when a
continuation sheet has been used. Instructions for use would direct the
repairing facility to show the total costs only on the continuation sheet (if
one is used) and to staple the continuation sheet to the inspection report.
187
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MATERIALS USED
REQ
VOL
QUAN
PART NO.
DESCRIPTION
PRICE
PCV Valve
1 -
Air Filter
• A
Spark Plugs
. .
Points
Condenser
Rotor
Wires
Carburetor Overhaul Kit
Replacement Carburetor
1
1
•
•
LABOR ACTIONS
REQ
VOL
DESCRIPTION
LABOR
Set Dwell
Set Timinq
Adlust Idle Mixture/Speed
Set-Idle Speed Only
Repair Choke
Repair Heat Riser/Heated Air Inlet
Repair A.I.R. System/Components
Test Compression ( )( )( )( )( )( ){ )( )
Overhaul Carburetor
Replace Carburetor ~ New ~ Rebuilt
Perform Low Emission Tune-Up
Use ^Continuation Sheet' if necessary. Show
totals on continuation sheet.
TOTAL VOL LABOR
tfotAL V6l PARTS
TOTAL AEQ LABOR
TOTaL r£Q PARTS
*
TAX
TOTAL
A-
DESCRIPTION OF ADDITIONAL RECOMMENDED REPAIRS
ESTIM.
•
»
DATE ODOMETER_
Q I certify that'the recommended maintenance indicated on the reverse side
was performed by me or at my request by a mechanic.
Owner
Sign.
Q I certify^ that the recommended maintenance indicated on the reverse side
have been performed.
Inst.
Sign.
'Figure 4-9. EMISSIONS CONTROL SYSTEMS--REPAIR SUMMARY
188
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FACILITY # TEST NO. REPAIR DATE
LIC NO. YEAR HAKE MODEL
MATERIALS USED
REQ
VOL
QUAN
PART NO.
DESCRIPTION
PRICE
SUBTOTAL FROM SHEET 1
LABOR ACTIONS
REQ
VOL
DESCRIPTION | LABOR
I
LABOR COST SUBTOTAL FROM SHEET 1 j
A
-- •
*
TOTAL VOL LABOR
TOTAL VOL PARTS
TOTAL REQ LAS6r
TOTAL REQ £aRT3
¦
TAX
TOTAL
'
Figure 41—AO • CONTINUATION SHEET FOR ADDITIONAL REPAIR INFORMATION
189
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Hence, no entry in the total cost blocks on the original repair summary would
indicate that a continuation sheet should be attached.
Any other emissions-related work performed that was not recommended by
the inspection program should have been voluntarily requested by the vehicle
owner and so noted. The costs for required and voluntary work would be identi-
fied separately.
Space would be provided for a description and cost estimate of additional
emissions-related work which the garage recommends to ensure meeting the
emissions standards. In general, this would only be estimates for major
engine repairs. However, it is expected that older vehicles would also require
these estimates to secure waivers due to cost constraints on repairs. This
information would be used when considering issuance of a Certificate of Waiver.
Data Collection for Program Effectiveness Determination - Data would be
collected with regard to emissions levels, repair activities and facility
operations. Analysis of these data would be performed to ascertain emissions
reduction cost-benefit relationships, patterns of malfunctions, the adequacy
and accomplishment of required maintenance, the effectiveness of failure
diagnosis based on emission reduction calculations and on the review of
remarks received from the repair garages, and operational effectiveness.
Emissions Data Collection - Emission data would be collected at the
inspection facility and transcribed on the Vehicle Inspection Report for data
processing. Several approaches may be used to accomplish this data collection.
o Keep an ongoing cumulative summary of data at each site instead of
data on each individual vehicle.
o Collect all data on all vehicles individually.
o collect all data on all vehicles at a specific site for a specific
period (day or week) with the site changed periodically.
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All data could be processed at the end of each working day by inspection
facility personnel and the summary forwarded to the MVD for inclusion with
summaries from each facility. The summary report format can be arranged such
that conversion to machine readable form will be expedited.
It is possible to collect all emission data on all vehicles. The purpose
would be to gather maximum information to verify emission standards, repair
effectiveness and operational effectiveness. These data would be encoded for
keypunching each day by inspection facility personnel and forwarded to the MVD
for keypunching and inclusion with data from each facility.
To reduce data handling to a minimum it would be desirable to collect all
data for a given period, day or week, from a specified facility. A total
sample size of 2,000 vehicles out of 0.54 million should be adequate for the
first year (1982) of the program. "However, the actual sample size required to
ensure statistical significance should be determined by observing the mean and
standard deviation of these actual data collected during the first year of the
program. To ensure randomness of data collection, em assignment algorithm
would be used to indicate where and when the data collection would take place.
In the case of a privately-operated facility operating at its projected
capacity of less than 5 vehicles per day, a statistical design will need to be
developed that will allow sufficient data to be collected over a reasonable
length of time from an adequate number of stations. Only then can statistically
significant statements be made about that particular facility's measure of
effectiveness. For the total program, data from all of the sites sampled will
be combined for an overall effectiveness measure.
Data Encoding to Machine Readable Form - Data may be transcribed from the
Printed Vehicle Inspection Report (VIR) onto an 80-column coding sheet which
could then be keypunched at the State Data Processing Center for input to a
computerized data analysis program. The punched card format shown in Figure 4-11
includes the data for each test on each vehicle. The order of data entry
follows the order of listing on the VIR. The data would be encoded as a
series of cards after a Certificate of Compliance or Waiver had been issued
191
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the day of first test for passed vehicles or several days (or weeks) later for
failed vehicles. Daily operational information would be tallied separately.
Two problems must be considered for this method of data handling-
transcription errors and time expended. Transcription errors cannot be totally
eliminated but can be reduced by using a coding form that clearly identifies
each data field by title, by using heavy separating lines between fields, by
blocking out fields that must be blank, by coding in the same order as data
are read, and by fixing decimal points wherever possible. An example of this
technique was shown in Figure 4-11.
Time required to fill in these forms and to keypunch the data must be
considered. Using a conservative estimate of 50 seconds for manually recording
the first test (the only test in the case of passed vehicles), and 40 seconds
for each additional test (since descriptive data need only be recorded once),
a 35 percent inspection failure rate, a 10 percent reinspection failure rate
and 5 tests or retests per facility per day, it would require less than 5 min-
utes per facility per day for recording all data manually.
The manual method of data recording applies equally well to the collection
of data at a specific site for a specific period.
Repair Cost Data Collection - Cost data on repaired vehicles would be
derived from the repair summaries filled out by the repairing facility and
returned by the vehicle owner at the time of retest. These data must be tran-
scribed manually to a machine readable form. Assuming 5 tests per facility
per day, an average of 3 minutes per repair summary will be required for
interpretation and coding or about 6 minutes per day per facility.
To provide meaningful cost breakdowns for subsequent data analysis, it
will be necessary to identify parts and labor for recommended maintenance
separate from voluntary maintenance. This would allow determination of an
average cost figure for each of the required maintenance items which can be
used in identifying excessive charges. Distinguishing recommended from volun-
tary maintenance would also aid the consumer by imposing a limitation on the
192
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Card Cols
1-4
5
6
7-12
13-14
15-16
17-18
19-20
21-23
24
25
26
27-30
31-35
36-39
40-44
45-48
49-52
53-57
58
59
60-
63-
66-
69-
•62
¦65
68
71
72
73-
76-
79
80
NOTE;
¦75
78
Item
Facility number
Lane number
Space
License number
Model year
Weight class
Number of cylinders
Emission control code
Odometer (in 1000s)
Space
Test number
Test Decision-
Failed = 1
Idle HC
Idle CO-
Fixed Decimal in Col 33
Lo Cruise HC
Lo Cruise CO-
Fixed Decimal in Col 42
Hi Cruise HC
Hi Cruise CO
Fixed Decimal in Col 55
Space
Required maintenance-
Not completed = 1
Required Parts
Cost - Dollars
Required Labor
Cost - Dollars
Voluntary Parts
Cost - Dollars
Voluntary Labor
Cost - Dollars
Space
Parts Estimate-Dollars
Labor Estimate-Dollars
Space
Waiver-Granted = 1
Example
xlll
4
123ABC
70
xl
x8
x3
X42
1
blank
xl50
xO.49
xl21
xO.38
xl23
xl. 01
blank
XXX
XXX
XXX
XXX
XXX
XXX
blank
Remarks
Constant for
each facility
Each test
Constant
Each test-for
traceability
Once
in
a
series
Constant
For
each
test
Constant
For
each
retest
Constant
For waiver
consideration
Constant
x is used to show number of available field positions
Figure 4-11. MANUAL DATA ENCODING FORMAT
193
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repair garage, and would aid the MVD in identifying repair garages that
fraudulently indicate that some voluntary items are required.
An analysis of the repair summary would be made by comparison with a
matrix of failure diagnosis versus recommended actions to determine whether:
a. Fewer than the recommended actions were performed.
b. Only the recommended actions were performed.
c. Only recommended and voluntary actions were performed.
d. Excessive actions were performed and indicated as being required.
The result would be encoded along with the given cost data. The Vehicle
Repair Summary (Figure 4-9) can be encoded for direct keypunch operation. To
facilitate data encoding, the following definitions of correct, excessive,
insufficient and incorrect repairs are proposed.
Correct Repairs - A correct repair may be implied if the vehicle passes
the retest and the recommended repairs were performed. Additional and voluntary
repairs may also be allowed.
Excessive Repairs - The vehicle may pass the retest, but more may have
been repaired than was required. It would require considerable test and
maintenance data to assure the MVD that only those repairs identified as
recommended are sufficient to ensure passing a retest.
Insufficient Repairs - Insufficient repairs would be implied if the
vehicle fails the retest. Less than the recommended repairs may have been
performed and this can be determined from the repair summary. The recommended
repairs may have been completed but the list of repairs or the procedure for a
given failure diagnosed may be lacking completeness. It is also possible that
more than the recommended repairs were performed and it could still be insuffi-
cient since the "correct" diagnosis was not performed.
Incorrect Repairs - If the vehicle fails the retest and fewer than (or
none of) the recommended repairs were performed but other repairs were per-
formed, the repair can be considered incorrect. It might also be possible
194
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that incorrect repairs were performed due to faulty garage equipment. To
identify this possibility, measured engine parameter data should be collected
in the early stages of implementation and whenever a vehicle returns to the
rspair facility after failing a retest. It is possible to have both excessive
and incorrect repairs.
Operations Data Collection - There are numerous items of data that would
be collected to determine the effectiveness and efficiency of the inspection
facilities. These data would include daily tallies of:
o Inspections completed - Pass, Fail, and Fail Retest from VIR copies.
Additional breakdowns would be accomplished as part of emissions
data analysis.
o Vehicles rejected - Cause, as determined from copies of reject
reports.
o Complaints processed - Complaints received, resolved and forms
forwarded for investigation.
o System Performance (as determined from system log) - Number of hours
in operation, scheduled maintenance - by equipment, unscheduled
maintenance - by equipment.
These tallies would be performed during the day following the day of
operation being reported on. A sample of an operations worksheet is shown in
Figure 4-12. Completion of this log would require less than 3 minutes per day
per facility. An additional 2 minutes would be required to collect and organize
the data and check it for completeness.
Data Conversion - All cost and operations data would require keypunching
from coding sheets. Assuming a total of 1,480 tests per day, keypunching of
manually collected emissions data would require less than 5 hours per day (at
160 to 200 cards per hour). This punching would be done at the State Data
Processing Center or by a service bureau.
195
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Date
Date
Date
Date
Date
Date
Week
Total
Inspections Completed
Pass
C of Cs Issued
Initial Failure
Failed Retest 1
Failed Retest 2
Waivers Issued
Vehicles Rejected
Retrofit Lacking
Control System
Inoperative
Brakes
Exhaust Leaks
Fluid Leaks
Complaints Processed
Received
Resolved
Forwarded
Hours of Operation
Lane 1
Lane 2
Lane 3
Lane 4
r
Maintenance Hours
Lane 1
Equipment A
Equipment Z
Lane 4
Equipment A
Equipment Z
•o
a
o
0]
e
D
TJ
-------
5. Legislative Considerations
In designing an I/M program, there must be careful consideration of
potential problem areas that could hinder acceptance by the State Legislature.
These potential problem areas are the result of secondary impacts that may be
unforeseen by program designers. These secondary impacts include political
constraints, socioeconomic considerations, and institutional effects. These
impacts are wide in scope, illustrating the pervasive effects of I/M on the
population. Among the more important secondary impacts, the following require
early legislative consideration:
o Impact on those groups that must subsist on low or fixed yearly
income (e.g.; the poor, the disabled, and the elderly).
o Impact on the repair industry.
o Consumer protection,
a. Impact on Low-Income Groups
A major concern posed by consumer protection groups, legal aid societies,
etc., involves the effect of I/M on low-income groups. It is felt that since
older vehicles as a group are more likely to be seriously out of compliance
with emission standards, the maintenance cost would be prohibitive and, in
effect, deny low-income citizens the right to operate older vehicles.
This problem can be remedied by establishing exemption criteria for
certain vehicles requiring costly emission-related work to be performed. One
criterion involves a repair cost ceiling based on an absolute dollar figure,
or the percentage of vehicle value—whichever is lowest. The second criterion
would exempt vehicles of a certain age (e.g.; pre-1952, antique vehicles).
Both criteria would substantially reduce the cost burden on low-income groups.
These exemptions would not have a significant effect on the I/M program
effectiveness on reducing emissions from the in-use vehicle population. The
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majority of vehicles that are seriously out of compliance with established
emission standards tend to be older (5 years), and probably would not remain
in the vehicle population much longer. Resale vehicles that filter down over
time to replace the gross emitters would have been maintained as a result of
I/M and should not be as costly to keep in compliance.
A potential problem area requiring legislative resolution involves the
question of warranty protection. Presently, emission devices are subject to a
50,000 mile/5-year manufacturer's warranty. In most cases, the warranties on
older vehicles owned by low-income groups have expired. This places a burden
on low-income groups that are required to replace costly emission control
devices. It should be mentioned that it is unknown how long these durable
devices will last and may conceivably remain operative until the end of the
vehicle's useful life.
b. Impact on the Repair Industry
The repair industry has considerable lobbying power that may be exerted
on the legislature. Areas of special concern involve questions of how I/M
will affect the ability of the repair industry to maintain vehicles; the
accuracy of the HC/CO analyzer; the ability to profitably finance program
equipment; and, finally, new rules, regulations, and restrictions that may be
placed on the repair industry. These questions can certainly be voiced and
perhaps resolved through committees and public hearings.
c. Consumer Protection
Legislative provisions must be made to ensure that vehicle owners are
protected from abuses that could appear in the maintenance phase of an I/M
program (e.g.; overcharging, unnecessary repairs, and warranty protection).
Section 4.E.2 provided descriptions of various program issues that should be
adequately covered by initial legislation. As program development advances,
it is likely that other issues will surface requiring revision or modification
of initial legislation.
198
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d. Legislative Implementation
The first stage in the implementation of an I/M program is the development
of appropriate enabling legislation. For the drafting of the enabling legis-
lation, a preliminary description of the major program components should be
prepared and the organizational option should be decided upon. Program objec-
tives, operating rules, program scope and major agency responsibilities should
be specified- Planning and trade-off studies will result in the identifi-
cation of the technical, social, and economic characteristics of the desired
I/M program. This aids in the structuring of the legislation.
Several states have already passed legislation establishing legal require-
ments for the control of emissions of HC, CO, and NO^ from motor vehicles. In
some cases, this has been accomplished by either an act of the State Legisla-
ture, or through official action taken by an air pollution control board,
commission, or other state agency. Either method is acceptable, depending on
the legal requirement of individual states, so long as a firm legal authority
is established under which necessary action can be taken.
Generally, most of these laws and regulations include two provisions.
The first is a legal requirement that the owner or operator of a motor vehicle
should not deliberately remove or inactivate the emission control devices
presently required of automobile manufacturers.
The second provision establishes a system of inspection and/or maintenance
programs. This provision would address specific issues (i.e.; legal authority,
fees, penalties), that should be incorporated into the enabling legislation
such as:
o Adequate authority to adopt rules and regulations concerning:
-requirements for periodic inspection
-establishment of fees for providing the inspection service
199
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-withholding vehicle registration for those vehicles that do not
satisfactorily complete the inspection or that do not comply with an
applicable emission variance
-prohibition of tampering
-vehicle exemption.
o Provisions for providing adequate funds for implementing, monitoring,
and enforcing the I/M program.
o Adequate authority to obtain pertinent data and information, and
require periodic reporting of emission information.
o Authority to develop emission reports and information suitable for
public inspections.
o Authority to compel compliance with rules and regulations, supported
by civil or criminal penalties.
o Provisions for injunctive relief where deemed necessary.
o Provisions for public hearings.
6. Mechanics Training
A high level of skill and technical competency of automotive mechanics is
required to repair, diagnose, and adjust vehicles to emission standard levels.
This implies that mechanics must be thoroughly familiar with the underlying
principles, theory, and operation of emission control devices. However, this
becomes increasingly difficult owing to the great diversity of vehicles,
profusion of various makes/models/years, and their associated emission devices.
This problem becomes compounded by the fact that emission control technology
is becoming increasingly more complex. The end result is an apparent shortage
of qualified mechanics capable of correctly diagnosing engine parameters.
200
-------
In order to ensure that enough qualified mechanics are available to
service and repair vehicles according to I/M specifications, present educational
programs should be upgraded to meet the current and future needs of the repair
industry. This may be accomplished, prior to implementation of I/M, if the
state takes an active role in formulating criteria that evaluate, train, and
assist currently employed mechanics. These criteria would include:
o Mechanic training curricula which incorporate multimedia aids that
review step-by-step emission tune-up techniques.
o Assessment of mechanic qualification requirements, and development
of qualification examinations.
o Conducting pilot programs to evaluate the effectiveness of training
programs.
Each criterion will be covered in greater detail in the following
subsections.
a. Mechanic Curricula
There is a wide variety of mechanic training programs currently available
at the various trade, vocational, and technical schools. These programs will
differ in content because of the different degree requirements of each school.
Unfortunately, many of these programs either ignore or superficially cover the
effects of various engine parameters on vehicle emissions. This problem can
be remedied if a standardized and comprehensive emission control training
program is instituted at selected schools.
As part of this comprehensive training program, an EPA-approved emissions
control course would become mandatory. Colorado State University has recently
published a "Motor Vehicle Emissions Control Instructional Materials Packet
that has been extensively field tested and widely accepted by many states.
This packet is designed to be used by vocational automotive instructors as a
complete multimedia approach to emissions control systems. The topics that
201
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are covered in-depth include: positive crankcase ventilation, thermostatic
air cleaner, air injection reaction, fuel evaporation, exhaust gas recircula-
tion, spark control, and catalytic converters.
Once the fundamentals of emission controls are covered in sufficient
detail, supplemental courses (Table 4-27) could be made available to emission
inspectors and repair mechanics alike- These courses would add greatly to the
mechanics understanding of the needs, concepts, and requirements of an I/M
program.
An important by-product of a mechanic training program would be the
development of a handbook that describes definite repair sequences for each
type of emission failure. Mechanics would be instructed to proceed only so
far as the step that corrects the particular malfunction. This would alleviate
unnecessary repair work.
b. Mechanic Qualification/Certification
Before state-approval is given to perform emission repair work, a mechanic
should be required to demonstrate proficiency by:
o Successfully completing the required number of training courses.
o Correctly diagnosing and repairing control vehicles to meet emission
requirements.
o Passing qualification examinations designed to test the mechanic's
understanding of the principles and theory underlying emission
control devices.
o Demonstrating a working knowledge of Federal and state laws and
regulations governing emission control.
Upon the successful completion of the above requirements, the mechanic
would be certified.
202
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Table 4-27.
CONTENT OF TRAINING COURSES
COURSE TITLE
Program
Orientation
COURSE
HOURS
1-2
SUBJECTS
Vehicle Emis-
sions and
Standards
7-8
Inspection
Procedures
21-24
(1st
day)
Objectives of and general procedures used
in periodic inspection and maintenance.
Program structure including organization
charts, and relationships to other State
and local agencies. Relationship of PVI
to other air pollution control strate-
gies. Data flow within agency and be-
tween related agencies. Enforcement
procedures for vehicle owners and re-
pair facilities. Consumer information
and protection measures.
General discussion of mechanisms produc-
ing hydrocarbon, carbon monoxide,
nitric oxide and smoke (particulates)
emissions. Concepts of normal emission
levels and excess emission levels.
Effect of factors such as misfire, air/
fuel rations, and combustion temperature
on emission levels. Emission standards
and regulations mandating particular OEM
or retrofit equipment. General types of
emission control systems, including
general configuration, theory of opera-
tion and typical effect on emission
levels at different engine operating
conditions. Identify differences in
standards set for emission inspection and
original manufacturer certification.
Identify distinction between Federal and
Georgia standards and equipment con—
f igurations by model year.
Facility layout. Description, purpose
and use of principal equipment. Facil-
ity personnel organization, shifts,
duties, and authority of each inspector.
Vehicle traffic flow through facility.
Public relations and manner of dealing
with the motorist.
EQUIPMENT
AND DOCUMENTS
Slide/tape or sound
movie presentation
including pictorial
and diagramatic
visual aids.
Question and answer
period follows.
Distribute Consum-
er 1s Handbook.
Film or videotape
presentation includ-
ing pictorial and
diagramatic visual
aids. Distribute
training manual on
emission controls
and standards.
Film or videotape
presentation show-
ing actual facility
and equipment con-
figuration. Provide
training manual to
trainees.
203
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Table 4-27.
CONTENT OF TRAINING COURSES (Continued)
EQUIPMENT
AND DOCUMENTS
(2nd Specific inspection procedures for each
day) work station. Procedures for visual
inspection. 'Specific vehicle emission
control equipment configurations by model
year. Exemptions. Retrofit require-
ments. Examples of equipment violations.
Procedures for connecting ignition analy-
zer and exhaust probe. Emission inspec-
tion driving pattern. Interpretation of
test results. Consulting with driver on
vehicle results. Grounds for waiver.
COURSE
COURSE TITLE HOURS SUBJECTS
Repair
Procedures
Fleet-Owner
Inspection
and Mainte-
nance
(3rd Laboratory practice in facility or lane
day) mock-up. Each inspector performs at
each work station for 1 hour performing
inspections on sample vehicles. Em-
phasize order of tasks, completeness
of visual inspection, accuracy of driv-
ing inspection test, interpretation
of results, dealing with the public.
Set-up and calibration of equipment.
Start-up and shutdown of facility.
Certification of inspection person-
nel and assignment to facility.
4 Ignition and carburetor systems. Emis-
sion control systems. Diagnosis of
engine malfunctions using scope and
and infrared analyzers. The service
warranty and criteria for satisfactory
performance. Completing, signing, and
returning repair forms and estimates,
information required, and method of
entering data.
7-8 Describe the emission test. Show
typical test bay with gas analyzers.
Describe data recorded. Explain vari-
ous emission standards. Calibration
and use of gas analyzers. Diagnosis
of failures using emission data. Use
of ignition scope in diagnosing HC
failures. Reporting of information
and retention of records. Spot sur-
veillance of vehicles and test facil-
ity. Cost savings of inspection for
directing vehicle maintenance
activity.
Inspection lane,
either in facil-
ity or mock-up
at training
center. Dupli-
cation of equip-
ment used in
actual facility.
Film or video-
tape of vehicles
being tested and
repaired for
typical malfunc-
tions . Issue
mechanics a
certificate and
note attendance.
Distribute Repair
Procedures Manual.
Film or videotape
of inspection
process and emis-
sion related re-
pairs . Training
manual defining
procedures and
guidelines.
204
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Table 4-27.
CONTENT OF TRAINING COURSES (Continued)
COURSE TITLE
Adm inistrative
Procedures
COURSE
HOURS
3-4
SUBJECTS
Specific procedures for recording, trans-
mitting, and reporting test data and
requisitioning supplies and services.
Administrative, personnel, budgetary,
and public relation policies and proce-
dures. Management procedures.
EQUIPMENT
AND DOCUMENTS
Training manual
and film or video-
tape presentation
205
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c. Mechanic Training Program Costs
In order to develop costing information for implementing mechanic training
programs, it was necessary to assume that state safety inspection stations
would provide the minimum number of mechanics necessary to support emission
repair activity. Hence, at least 650 mechanics, one from each of the safety
inspection stations will participate in the training programs.
The program costs for training 650 mechanics are shown in Table 4-28.
These costs were developed by assuming that at least 30 mechanics would enroll
in each class taught by vocational instructors at local colleges, trade schools,
etc.
The estimated $12 thousand can be defrayed by charging a tuition of
$50 per student. This would produce annual revenues of $32,500. This can be
allocated to pay instructors fees, capital and operating costs, etc. The
remaining funds can be used for an on-going training effort in the form of
seminars, workshops, etc. This will upgrade certification requirements and
help keep mechanics current with new information.
Table 4-28. ESTIMATED PROGRAM COSTS FOR MECHANIC TRAINING
COST CONSIDERATIONS _ COSTS
A. Capital Costs:
Audio visual materials $ 1,200
B. Operating Costs:
1. Personnel planning, curricular
development and class
scheduling 3,500
2. Personnel
C
11 instructors 7,480
Total $12,180
aMaterials estimated at $200 per course - projection slides, charts, etc.
There are 6 courses in training program.
Program coordinator's time at $6.80/hr. Estimate 3 months planning and
development.
cAssuming 1 instructor can teach 2 classes per day at 3 hours per class meet
ing, then the number of instructors required is calculated.
/m 1 \ 1 instructor ,, .
(22 classes) 2 classes = 11 instructors
State vocational instuctors receive approximately $13,600/yr or $6.80/hr.
Each class will require 50 hours in class instruction or $340/class.
206
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7. Decentralized I/M System Minimum Station Requirements
The I/M option established by the State of South Caroline is the decentral-
ized system (a system of private garages for emissions testing). An I/M
option available to the State of South Caroline involves consideration of
private-garage emission inspection facilities. This section is an analysis of
the minimum number of emission testing stations and their location.
In estimating the minimum number of private garages involved in emission
inspection and the service coverage for each garage, the following assumptions
were used:
o Projection vehicle registration data for 1977 (base year), 1982, and
1987.
o Thirty percent (i.e., stringency factor) more inspections than
actual registrations.
o Capital Investment Per Station
-$3,000 - Cost of emission testing and auxilary equipment
o Operations Throughput Time
-3.75 minutues
o Mechanics Costs (including overhead)
-$18 per hour
o Station inspection work load factor capability for private garage -
10 percent of work load assigned to emission inspection. In the
four county area with safety inspection stations the work load
factor for emissions testing is about 3 percent.
o Emissions for statewide option were developed by extrapolating the
four county data.
o Cost of capital is 6 percent for the state.
207
-------
o The state personnel benefits including sick leave, vacation, retire-
ment, insurance, holidays, etc., is 25 percent of base rate.
o Fuel cost is $.70 per gallon.
o Inflation rate is 7 percent. To convert from 1978 to 1982, a com-
pound factor of 1.31 must, be used.
o Indirect costs reflecting the cost to consumers for waiting time at
inspection lanes and cost of transportation to and from the inspection
and repair facilities were ignored.
o Average miles traveled per year for LDVs is 11,500 miles per year.
o Failed vehicles consumed an average of 3.8 percent more fuel than
the certified vehicle.
o Fleet fuel economy for LDVs is 15 miles per gallon (1982), 24 miles
per gallon for 1987 LDVs,
o Emission testing, without supplemental diagnostic testing, requires
at least 3.75 minutes per test.
o Ten percent of station business is emission-inspection related,
a. Minimum Number of Private Garages
The minimum number of private garages directly involved in emission
testing is calculated using the following formula:
(V + V S.)
G = r z r £
where:
G = the minimum number of private garages
Vr = vehicle registration data
208
-------
= stringency factor = .30
I = number of vehicles inspected by each garage per year (2,200
inspection/year)*
Using the methodology outlined above, the minimum number of private
garage emission inspection stations for each county are presented in Table 4-29.
It is expected that the total vehicle population will increase over time.
Hence, the number of garages involved in inspection will change accordingly.
For instance, the number of additional stations at 5-year intervals, for each
county are as follows: Lexington and Charleston Counties 15 to 17 additional
stations; Richland 19 to 20 stations; and Berkeley, 9 stations.
Table 4-29. PROJECTED PRIVATE GARAGE EMISSION TEST STATIONS
REQUIRED FOR EACH COUNTY
1977 1982 1987
(Base Year)
COUNTY NO. OF GARAGES NO. OF GARAGES NO. OF GARAGES
Lexington 52 64 g2
Richland 92 111 232
Berkeley 25 34 42
Charleston 90 106 223
259 318 373
b. Service Area Radius
In order to calculate the service area coverage for each garage, it is
necessary to make certain fundamental assumptions. First, no motorist need
drive more than a certain distance, R, to an inspection station. Second,
c^vviee oarages are spread evenly across the landscape, this
assuming cars and service gar
-------
where:
R = service area radius
A = county area
= 3.14159
G = number of private garages in each county
The service area radius for all garages within each nonattainment county
is shown in Table 4-30. The calculated service area radius are comparable for
all counties ranging from 26 to 32 miles. The service area radius decreases
as the number of private garages increases over time.
Table 4-30. SERVICE AREA RADIUS FOR PRIVATE GARAGE TEST
STATIONS IN EACH COUNTY SERVICE AREA RADIUS
(Miles)
COUNTY
1977
1982
1987
Lexington
Richland
Berkeley
23
29
27
30
21
26
23
27
19
24
21
25
Charleston
210
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Section 5
STATEWIDE I/M PROGRAM ANALYSIS
This section presents the statewide I/M program option. The scenario for
this option is as follows:
o Area - statewide I/M program
o Test mode - idle
o Vehicle category - LDV, LDT^ and LDT2
o Administration - private garage
o Enforcement - vehicle registration
o Emission check - HC and CO
A. FACILITIES REQUIREMENTS
• ^ - 4-i^r, t-hpro are 3,135 private garages that would
For the statewide option there are *
participate.
B. PERSONNEL REQUIREMENTS
Table 5-1 lists the State personnel requirements for the four-county area
-The State personnel requirements do not
and the statewide program options. Tne
1-a the number of vehicles because the minimum
have a one-to-one correspondence to tne numc r
. ¦ x. i
-------
Table 5-1. I/M STATEWIDE MANPOWER REQUIRMENTS*
JOB CATEGORY STATEWIDE
Program Administrator
Assistant Program Administrator (Quality Control)
Assistant Program Administrator (Testing)
Environmental Engineer
Statistician
Clerical
Secretaries .
. o
Inspection Agents
TOTAL
aSalaries are presented in Table 4-10.
Including 8 quality control field personnel.
Program management responsibilities for either option will include:
1) vehicle testing scheduling, 2) record maintenance, 3) establishment and
review of emission test limits, 4) data analyses to determine inspection
program effectiveness, 5) evaluation of current and future equipment needs,
and 6) provision for future analyses and development. These program responsi-
bilities will be coordinated by three key state personnel positions: 1) Quality
Control Assistant Program Administrator, 2) Testing Assistant Program Adminis-
trator, and 3) Environmental Engineer. The specific responsibilities for each
management position is outlined as follows:
1. Assistant Program Administrator (Quality Control) - Will manage the
twice-monthly equipment calibration checks for all private-garage
inspection centers; the statistical analysis of emission test data.
2. Assistant Program Administrator (Test) - will be responsible for the
efficient day-to-day operation of referee test stations.
3. Environmental Engineer - Is responsible for monitoring program
effectiveness and evaluation of vehicle emission reduction.
1
1
1
2
2
8
2
43
60
212
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C. EMISSIONS REDUCTION
The HC/CO emissions for statewide I/M program are as follows: the reduc-
tions for HC in the year 1982 is 6 percent and in the year 1987 it is 23 per-
cent. The CO reductions in the year 1982 is 16 percent; in the year 1987 it
is 34 percent.
D. COSTS OF A STATEWIDE PROGRAM
The costs of a statewide program are presented in Table 5-2. In contrast
to the four-county option, the total capital costs for 3,135 private garages
at $6,000 per garage is $18.8 million. This will require an annualized cost
for capital equipment $70© per year per private garage. The private garage
operation costs over the 10-year period is $28.5 million or $9,000 per private
garage. This amounts to $900 per private garage per year and a total cost per
year for capital and operation costs of $1,600.
The statewide operation costs of each private garage is less than that of
. i „ thev will not inspect as many vehicles per
the four-county option because xney wxj.j. ^
garage. The operating costs per vehicle is equal for each option.
The State cost of $22.2 million or an average of $2.22 million per year
fc cover 1) 15.1 million for operating administra-
over the 10-year program is to covei
4. of data, prepare reports, administer the program,
tive costs to support analyses or qiu>, r
J „„nQ,mer protection, $5.7 million for increased
investigate complaints and consumer protec
quality control of the 3,135 private garages, 2) initial implementation costs
of $202,000 and 5200,000 for public information, and 3, other capital cost, of
• r>f S41.000 for administrative equipment,
approximately 1 million consisting of 541,ouu h f
¦ir^ani- and $377,000 for consumer protection
$575,000 for quality control equipment and
capital cost.
«. -nrr-ease was considered to be proportional to the large
The State costs increase wa
• rraraaes which was a 4.7 fold increase over
increase of participating private garages wn
the four-county options.
213
-------
Table 5-2.
COSTS OF SOUTH CAROLINA I/M PROGRAM - STATEWIDE OPTION
($1,000 1978 Dollars)
CATEGORY
Test Equipment Costs
1982-1986
State
Private
Garage
9,405.0
1987-1991
State
Private
Garage
9,405.0
TOTAL
State
Private
Garage
18,810.0
II Operating Costs
Facility Operation
Administrative Support
Quality Control
III Initial Implementation Costs
Public Information
0
7,552.5
2,859.3
202.0
200.0
13,053.6
0
0
0
' 0
0
7,552.5
2,859.3
0
0
15,508.5
0
0
0
0
0
15,105.0
5,718.6
202.0
200.0
28,562.1
0
0
0
0
nj IV Other Capital Costs
Administrative Office
c
Equipment
Quality Control Equipment
Consumer Protection
TOTAL
TOTAL STATE & PRIVATE GARAGE
41.1
575.7
377.4
0
0
0
11,808.0 22,458.6
34,266.6
0
0
0
0
0
0
10,411.8 24,913.5
35,325.3
41.1
575.7
377.4
0
0
0
22,219.8 47,372.1
69,591.9
Costs are to the closest §100.
3,135 private garages would be participating in the program.
'Costs for statewide option are considered directly proportional to the number
of stations participating in the program.
-------
The total operating and capital cost for the statewide option program is
approximately $69.5 million. The gross estimate under this option was to
provide general comparative data only.
E. CONSUMER FEE
In order to compute consumer fee, the program costs for the statewide
option in Table 5-2 were converted into annualized costs. This was done by
amortizing capital-related (categories I, IV, and V) over 10 years of program
operation. Results are presented in Table 5-3. Cost of capital was assumed
to be 6 percent.
The average consumer "fee to defray the statewide option I/M program cost
was estimated to be $3.48 (see Table 5-3). The State's share is $1.06, while
the private garage's share is $2.42. The average vehicle population for the
statewide option was 2,103,000 vehicles. The increased cost for the statewide
option is because the costs of equipment and operations requirements of 3,135
participating private garages. The participating garages for the statewide
program would be testing fewer vehicles then the participating stations in the
four-county option.
It should be noted that the fee covers only the suite's direct cost on
the I/M program and certain indirect costs, such as utilities/supplies, office
rental, etc. It is difficult to include all governmental indirect costs in
this study without a detailed knowledge of the state's general accounting
procedure.
215
-------
CATEGORY
Table 5-3. ANNUALIZED COSTS OF I/M PROGRAM'
(1978 DOLLARS)
TOTAL AMORTIZED COSTC
a,b
- STATEWIDE
Test Equipment Cost
private garage
II. Operating Costs
private garage
state
III. Initial Implementation
Costs - state
IV. Other Capital Costs
state
$9,405,000 x 0.2374 x 5 +
$9,405,000 x 0.2374 x 5 =
$22,327,500
$28,562,100 facility operating
$202,000 x 0.1359 x 10 = $274,500
(41,100 + 575,700 + 377,400), x
0.1359 x 10 = $1,351,100
AVERAGE ANNUALIZED COST ($/YR)
$22,327,500/10 = $2,232,700
$28,562,100/10 = $2,856,200
(15,105,000 + 4,718/500)/10 = $2,082,400
$274,500/10 = $27,500
$1,351,100/10 = $135,100
$5,088,900
$2,245,000
$7,333,900
Total - State
Private Garage
State and Private Garage
aAll costs are rounded off to hundred dollars.
°Basic capital and operating cost data is taken from Table 6.
'Amortization factor (F) is determined by the formula.
F = i(l + i)n/l + i)n -1 where i is the cost of capital (= 6%) and n is the number of years.
For equipment amortization of 5 years, F = 0.2374
For capital amortization of 10 years, F = 0.1359
^Equipment life is considered 5 years, therefore, it is required to replace equipment after 5 years.
$5,088,900
NOTE
Fee Calculations
private garage share
state share
2,103,000 vehicles
$2,245,000
2,103,000 vehicles
= $2.42
= $1.06
TOTAL FEE $3.48
-------
Section 6
SPECIAL TOPICS
A. REFEREE STATIONS
Customer complaints will arise regarding the reliability of emission test
results, especially in cases where a vehicle fails an emission test after the
recommended repairs have been performed. In order to resolve complaints of
this nature a referee station can be used. The use of a referee station will
also provide an additional check on emission test facility instrumentation,
engine diagnosis, and mechanic capability.
The configuration of a referee station is presented in Figures 6-1 and
6-2. The costs of a referee station is presented in Table 6-1. For the
following capabilities:
o FTP testing capability
o Loaded mode and diagnostic testing (minimum system)
217
-------
K—15
^—15 ' -^5^ IS' -^5"'j <5'-H
Figure 6-1.
THREE-LANE/REFEREE FACILITY
218
-------
¦35'
*
¦25'
~7F
24'
V
K
~
36'
24'
^r
7K
¦15'
STORAGE OR REPAIR
^ 7.51^-10'.
T
9*
I
y
OFFICE
EQUIP.
CAL/WK
GAS ROOM
CHANGE
ROOM
WAITING
ROOM
REST
ROOM
REST
ROOM
7v
TEST CELL
18'
±-
OFFICE
28'
STATION 1
&
O
STATION 2
80'
•25''
QC VAN GARAGE
STATION 3
&
75"
Figure 6-2.
INNER OFFICE AND TEST AREA
three-lane/referee facility
219
-------
Table 6-1. REFEREE STATION EQUIPMENT COSTS
MINIMUM SYSTEM
EQUIPMENT FTP CAPABILITY (LQAD/DIAG.)
Constant Volume Sampler (CVS)
$12,000
CVS, Calibration Equipment
2,000
Sampler System
5,400
Dynamometer with road load inertia weights
39,000
$16,453
Driver's Aid
5,000
5,000
Cooling fan
650
Analyzer bench
125,000
16,000
Isolated power for analyzer
3,000
AC regulators
500
Gases
8,000
870
Miscellaneous-barometer, wet & dry bulb
8,850
850
FTP equipment (soak area)
12,000
Total
$221,400
$39,175
B. CORRELATION CAR
In addition to the regularly scheduled calibration checks, correlation
vehicles could be used to further standardize the station-to-station equipment
complements. An emission test performed using a highly standardized correlation
vehicle would provide a quality check on the entire analytic system (i.e.;
analyzer, sample collection system, tachometer, and inspection personnel).
The costs of a correlation vehicle is presented in Table 6-2.
Table 6-2. CORRELATION VEHICLE COST PER UNIT
1. Vehicle: 360 CID engine,
automatic transmission
2. Propane conversion (Emco)
3. Take off power items (power steering brakes, windows,
air conditioning, etc.) and
remove vacuum advance and alternator
4. Install recorder and sensing device to record fuel
temperature, carburetor and engine rpm
5. Install torque meter
6. Trailer
7. Hitch
Total
$ 5,000.00
1,000.00
500.00
1,500.00
500.00
1,200.00
120.00
$9,820.00
220
-------
C. TAMPERING CHECK
Tampering check as a function of vehicle inspection. This problem is
nted in Appendix F. TJ
This involves checking for:
presented in Appendix F. The major focus on tampering would be for NO .
X
o System hoses missing
Steel ball in vacuum hose
Top of EGR valve is dimpled reducing stroke; thereby the vacuum status
Drilled holes for air access
Coolant thermostat switch alteration
o Vacuum amplifier modification
o Vacuum line notched or cut
This check can be accomplished in approximately 30 seconds using visual
and vacuum checks.
D. DIESEL VEHICLES
Due to visible smoke emissions, the diesel engine is widely blamed for
i- ¦„ r^nn-Hon However, the medically harmful pollutants
much of the atmospheric pollution, nowev ,
nnvrene. and aldehydes are emitted only in low
such as carbon monoxide, benzopyrene, ouu <*•<-
concentrations, while the oxides of nitron, though by no means negligible,
are present in much lower proportions than in gasoline engines. However,
. fc ypadilv noticeable and is a potential safety
black diesel exhaust smoke is reaany
studies have introduced legislation to limit such
hazard. Therefore, many stuai
.. Are checked with opacity measurements. Diesel
diesel smoke. These limits are cnet-js.
r fnnrtioninq, is another area of concern,
exhaust odor, a further sign of malfunctioning,
1. ron.-Hf.ents in Dieseljaainejiasust Emissions
o Black smoke Wnbumed Carbon Particles)
t. anoearing as visible black smoke, is a clear mdica-
Unburned carbon, appear g ....
<3uch. its elimination is a matter
tion of inefficient operation, as such.
221
-------
of personal as well as public interest to diesel vehicle operators.
The composition of exhaust smoke has been reported between 75 and
95 percent carbon (Ref. 10) showing significant variation with
engine loading (Ref. 11). Particle size varies in the 0.1-0.3^m
range with smaller particles predominating. Particles in this size
are problems in personal health.
White Smoke
A fine mist of partly vaporized fuel and water droplets is often
produced in "cold-start" conditions or on misfire (Ref. 12). This
is white smoke and is a powerful irritant due, in part, to accompany-
ing aldehydes in the exhaust gases. Fortunately it is of short
duration and is of little importance in normal driving schedules.
Thus, one can distinguish between "hot" smoke (black) and "cold"
smoke (white).
Blue Smoke
Although "white" smoke and (particularly) black" smoke have attracted
wide attention, less is known about "blue" smoke (Ref. 12). This
does not become visible until several feet from the exhaust and is
probably the result of a cooling and (ultimately) condensation
process. Precipitation of the droplets in blue smoke yields a dark
amber liquid of the viscosity of light lube oil. Mass spectrometric
analysis has shown this to be a mixture of hydrocarbons. Blue smoke
droplets are of much smaller diameter than those of white smoke or
the particles in black smoke. They represent a particular fraction
of the unburned fuel in the exhaust, viz. that fraction which will
condense in the colder conditions some feet away from the exhaust
pipe. It is heaviest at medium load, the maximum emission occurring
at 40 percent rated load with straight-run fuels, at 60 percent with
cracked fuel. At higher engine speeds the maximum blue smoke emission
occurs at lower loads, this shift being related to exhaust
temperature.
222
-------
° Odor
Diesel exhaust odor, although somewhat unpleasant, is not of itself
dangerous, except in confined situations. However, as symptomatic
of some pollution "odor" is now regulated by the State of California.
There seems to be no direct correlation between odor and pollutants;
thus odor and irritant intensity have to be assessed by panel esti-
mates. In comparative studies it has been assumed that aldehydes
and oxides of nitrogen are the most probably odoriferous constituents.
Minor sources of odor, such as organic peroxides and acids are
unlikely to be present in sufficient quantity to contribute to
noticeable levels.
o Other Pollutants
The pollutants arousing most concern in spark-ignition engines have
been shown to be present in relatively insignificant quantities in
the case of diesel engines. Figure 6-3 shows the concentration of some
pollutants related to air/fuel ratio (Ref. 13). Carbon content is
seen to increase rapidly at higher air/fuel ratio than carbon
monoxide. (The range of values shown covers a wide range of produc-
tion model engines.) -Furthermore, concentration of 3.4-benzpyrene
is of negligible importance at acceptable air/fuel ratios, and
measurable quantities of nitrogen oxides are not detected until fuel
delivery rates are nearly twice normal values, so that pollution
from either source is unlikely to be important. Carbon, emitted as
black smoke, remains the most serious pollutant.
The diesel engine because of its high combustion ratio, better utilizes
the calorific value of injection fuel, so it needs less fuel than a gasoline
engine to develop the same horsepower, Figure 6-4 (Ref. 14).
2. Light-Duty Diesel-Powered Vehicles
The emissions of an uncontrolled diesel engine is presented in Appendix G.
In its uncontrolled form (i.e.. pre-1973), the diesel engine emits 1.1 gm/km
(1.7 gm/mi) carbon monoxide, and 0.29 wAm (0.46 gm/mi) hydrocarbons. This
223
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a
u
«€00
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§ 500
S.
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« 300
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e 100
2
5
« 0
o
CJ
7
6 -
5 -
4 -
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2
i o
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-
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—»» ^ s B.M.E.P. range
120
ioo
a.
ui
80 Z
- 60
10 12 14 16 18 20 22 24 26 28
Air/futi ratio (by weight)
Figure 6-3. DIESEL ENGINE EXHAUST GAS CONSTITUENTS
100% <
36%
33%*
7
-------
is considerably less than comparable controlled gasoline engines with 1.7 gm/km
carbon monoxide and 0.46 gm/km hydrocarbons.
The Federal emissions standards for 1978 light-duty vehicles as set forth
in the Federal Register Title 40, Paragraph 86.078-8 does not differentiate
between light-duty gasoline or light-duty diesel engines. The standards set
forth are:
o Hydrocarbons - 0.41 grams per vehicle mile
o Carbon Monoxide - 3.4 grams per vehicle mile
o Oxides of Nitrogen - 0.4 grams per vehicle mile
Comparing these 1978 standards to the emission values for the pre-1973
uncontrolled vehicle, one finds that the diesel engine without controls meets
the 1978 standard, except in the NO^ emissions.
An opacity standard for LDV smoke emissions should be defined as in the
emissions standards for 1978 diesel heavy-duty vehicles.
Statistics on the number of light-duty diesel vehicles (LDDV) as obtained
. oor-qnnnel. relating to the sales of light-duty
from the manufacturer's sales personnex, rexa y
vehicles is as follows:
Oldsmobile
o Diesels are 12.2 percent of Oldsmobile sales
o Oldsmobile has about 8.75 percent of the sales market
Mercedes-Benz
o Diesels are 65 percent of the Mercedes vehicle sales
o Mercedes-Benz sales on an allocated basis 53,000 vehicles in the U.S.
o Mercedes-Benz has about 0.5 percent of the market
Volkswaaen (VW) .
„ Volkswagen is planning to Diesels in Kabbit and Dasher models,
o sale forecast is about 60,000 vehicles per year.
225
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On the basis of the above statistics, it is assumed that the light-duty
diesel engine has 1.3 percent of the vehicle market in the United States.
It is evident that a well designed diesel engine, regularly maintained
and sensibly operated without overloading will produce very little HC/CO or
smoke emissions.
3. Heavy-Duty Diesel-Powered Vehicles
Heavy-duty diesel-powered vehicles (HDDV) as compared with its counterpart
in the gasoline-powered HD engine, feature low pollution power plants. The
emissions factors for the heavy-duty diesel-powered vehicles (pre-1973) are
presented in Appendix H. In the pre-1973 vehicles, the HDDV CO emission
factors were 28.7 gm/mi (truck) and 21.3 gm/mi (bus); 4.6 g/mi (truck) and
4.0 (bus) for HC? and 20.9 gm/mi (truck) and 21.5 gm/mi (bus) for NC>X- The
emission factors for HDGV were 188 gm/mi CO, 13.6 g/mi HC, and 12.5 g/mi NO^.
it is evident that the diesel emissions are considerably lower.
The EPA in 1979 promulgated new standards for the 1980 heavy-duty diesel
engines. These standards are:
o Hydrocarbons - 1.5 grams per brake horsepower
o Carbon monoxide - 25 grams per brake horsepower
o Hydrocarbons plus oxides of nitrogen - 10 grams per brake horsepower
hour
Or the following standards
o Hydrocarbons plus oxides of nitrogen - 5 grams per brake horsepower
hour
o Carbon monoxide - 25 grams per brake horsepower hour
226
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The opacity of smoke emissions from new 1979 and later model-year diesel
heavy-duty engines shall not exceed:
o 20 percent during the engine acceleration mode
o 15 percent during the engine lugging mode
o 50 percent during the peaks in either mode
The new standards are more stringent on emissions then the 1972 noted
values. The corresponding levels are difficult to interpolate because of the
certification test mode applied is in brake horsepower readings. To establish
an I/M program having gas emissions testing it will be necessary to develop
short tests that would correlate to the FTP for heavy-duty diesel. At present,
the test would include only opacity checks. This ensures that the vehicle is
operating in a satisfactory air/fuel ratio range. The test could be measured
under "free acceleration" conditions that is, full throttle in neutral gear to
give three successive similar maximum smoke readings.
E. FIRST-YEAR VEHICLES
Vehicle stress inducement relative to time is presented in Figure 6-5.
This figure notes three failure rate regions. These regions are:
o The green engine region (tj) (break-in region) wherein the vehicle
has a failure rate slightly higher then the stabilized region.
o Stabilized region (tj where the failure rate is constant.
o t region (wear-out region) has a continuously increasing failure
u
rate.
o t region has an increasing slope identifying high rate of failure.
This is the area of gross polluters.
in the majority of reported cases, new vehicle oraers (i.e., first year)
returned their vehicles to the dealers for servicing within the warranty
227
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Figure 6-5. FAILURE RATE REGION
228
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period of 12,000 miles. This servicing would provide the necessary maintenance
and repairs resulting in minimum emissions.
A California CVS 75 study (unpublished) performed in 1976 on 159 LDVs and
21 LDTs resulted in the following conclusions.
o "Closely" maintained vehicles were significantly lower in CO emissions.
o Failure rates were high on only one component—the EGR valve. The
EGR valve becomes plugged with carbon residues because of tampering.
o Of the 105 1976 vehicles, 3 vehicles failed because of HC per CVS 75
test requirements and not per short test (Figure 6-6). The repaired
vehicles were within emission standards.
o Of these 1976 vehicles, only 11 failed the CO test under CVS 75 test-
ing. Seven would have failed a short test because of the lack of
required maintenance, that is, adjustment of carburetor or timing
(see Figure 6-7).
A review of Figures 4-3 and 4-4 of Section 4 would identify long- and
short-term vehicle deterioration.
It is generally accepted that vehicle emissions increase with time, and
change in fuel consumption as well; however, it
that there is a corresponding cnanye x
, ^ ^ if there were no inspection and maintenance program
is also concluded that it tnere
there would be little deterioration the first year. An SCI study showed that,
after repairs, emissions regained generally low £or 6 to 9 months and then
• .wia after about 1 year (Ref. 15). It is assumed
increased to pre-repair levels after ax^u
• • *-,• e-Fartorv repair as it leaves the dealer's show
that each new car is in satisfactory reP
. , -s ooinns will remain at satisfactory levels for
room. Presumably, vehicle emissions will rem
t. * _ +~r~\ be noted that the manufacturers are subject to
1 year thereafter. It is to b
all new 49 state cars. Thus, the quality
average quality level audit of all new
¦ • nn new cars are normally to FTP standards or less,
setting for emissions on new
, .,les is, per the 49 state average, 7.5 per-
The number of new in-use vehicles is, P
^ T-><» nealiqible the first 6 months of vehicle
cent The HC reductions would b 9
q a 0.30 gm/mi emissions factor for IBV. The
use. The Mobile 1 Program uses a u.
EPA standard is 0.41 gm/mi.
-------
-------
-------
Section 7
REFERENCES
1. Kincannon, B.F. and A.H. Castaline. "Information Documents on Automobile
Emissions Inspection and Maintenance Programs Final Report," EPA,
Report 400/2-78-001, February 1978.
2. State of California, Air Resources Board, Evaluation of Mandatory Vehicle
Inspection and Maintenance Programs, dated August 2, 1976.
3. Northrop Corporation, "Mandatory Vehicle Emission Inspection and Main-
tenance," V. 5, Part. 1971.
4. U.S. Environmental Protection Agency, "Control Strategies for In-Use
Vehicle," November 1972.
5. Olson Laboratories, Inc., "Effectiveness of Short-Emission Inspection
Tests in Reducing Emissions Through Maintenance," July 31, 1977.
6. U.S. Environmental Protection Agency; Appendix N - Emission Reduction
Achievable Through Inspection and Maintenance of Light-Duty Vehicles,
Motorcycles, and Light- and Heavy-Duty Trucks. Proposed Rule. Federal
Register, 24(84): 22177-22183. Monday, May 2, 1977.
7. Williams, M.E. "Computer Simulation of Emission Inspection Procedures -
Assessment of Effectiveness." Society of Automotive Engineers, June
1976.
8. State of California, Bureau of Automotive Repair, "California Vehicle
Inspection Program Riverside Trial Program Report Operations from
September 2, 1975 to February 13, 1976," Volumes 1 and 2.
9. Rubenstein, G., R. Ingles, R. Weis, and A. Wong: "Vehicle Inspection and
Maintenance - The California Program," paper presented to Society of
Automotive Engineers, 1976.
10. R.A.C. Fosberry and D.E. Gee, Motor Industry Research Association Report
No. 1961/5, July 1961.
11. H. Stott and H. Bauer, M.T.Z., 18(5), 127, May 1967.
12. J.B. Durant and L. Eltinge, S.A.E. Paper No. 3R, Annual Meeting,
January 1959.
232
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13. M. Vulliamy and J. Spiers, S.A.E. Paper No. 670090, Automotive Engineer-
ing Congress, Detroit, January 1967.
14. Mercedes-Benz diesel trucks - economy data ASP-77-211-10-CVR1 data
sheet.
15. Olson Laboratories, Inc. - Effectiveness of Short - Emission Inspection
Tests in Reducing Emissions through Maintenance, July 31, 1972.
16. Engineering Science, Inc., South Carolina Highway Emissions, October 1978.
17. California Air Resources Board, 765-1975-1976 Model-year Surveillance
Test Program Report, March 1978.
18. State of South Carolina, Department of Highways and Public Transportation.
19. U.S. Environmental Protection Agency: Appendix N - Emission Reduction
Achievable through Inspection and Maintenance of Light-Duty Vehicles,
Motorcycles, and Light- and Heavy-Duty Trucks. Proposed Rule. Federal
Register, 24 (84); 22177-22183, May 2, 1977.
20. U.S. EPA, Mobile 1: Mobile Source Emissions Model, August 1978.
21. Bureau of Vehicular Emissions, Arizona Department of Health Service,
Arizona Vehicular Emissions Inspection Program Operation 1977, April
1978.
233
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Appendix A
MEMO FROM THE UNITED STATES EPA TO REGIONAL EPA ON I/M POLICY
-------
v ^
"•t
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANN ARBOR. MICHIGAN -181C5
JUL 1 7 IS73
OF~ICE CP
AIR ANO WATER PROGRAMS
MEMO TO: Regional Administrators, Regions I - X
SUBJECT: Inspection/Maintenance Policy
As you know, the Clean Air Act Amendments of 1977 set forth
specific requirements for the.implementation of motor vehicle
inspection/maintenance (I/M) programs- Attached is a policy paper
indicating what SPA will consider a minimally acceptable program
wherever I/M is required by the Act. It should._aid your efforts to
provide for adequate I/M submissions for the State Implementation
Plan (SI?) revisions-1 of January 1, 1979. Please continue to contact
3*e if problems in I/M implementation develop.
cc: Air and Hazardous Materials Division
Directors, Regions I, III -?¦ X
Environmental Programs Division Director,
Region II
Air Programs 3ranch Chiefs, Regions I - X
237
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Policy for the Development and lapLamentation of
Inspection/Maintenance. Programs
The Clean Air Act Anendnants of 1977 provide new direction for cha
development and implementation of motor vehicle inspection/maintenance
(I/M) programs. If statas are not able to demonstrate attainment of the
standards for oxidant (C:i) or carbon mcno:cide (CO) by December 31, 1932,
a specific schedule for the implementation of I/M Bust ba included in
the State Implementation Plan (SIP) revisions of January 1, 1979 for the
plan to ceet the requirements. of Section 172. The general requirements
for the I/M programs are set out in a February 24, 1973 memorandum from
the Z?A Administracor to the Regional Administrators (reprinted in the
Fedsral Register on May 19, 1973, 43 T.3.. 21673). The requirements, for
these programs, ara explained in mors detail below.
A. I/M SI? Revision D-evalooment and the January 1. 1979. Submittal
In producing an I/M SI? revision, the states should provide for:
1. an analysis of the benefits and costs of the program;
1. a public information effort;
3. a legislative proposal; and
4. a schedule for- I/M implementation.
A copy of suggested steps-for development of the SI? revision is attached
(Attachment 1). 3efora the January 1, 1979 submittal, the SI? revision
must ba adopted by the stata air pollution control board or agency head as
appropriate- As a part of the SI? revision submittal itself, there must
ba a commitment by the Governor to implement the I/M program according to
the schedule submitted.*
*SecCions 172(b)(7) and (10) provide that the plan revisions required
for nonattainmant areas shall —
(7) identify and commit the financial and manpower resources
necessary to carry out the plan provisions required by this subsection;
[Emphasis added]
and shall —
(10) include writtan evidence that the state, tha general purpose
local government or governments, or a regional agency designated by genera,
purpose local governments for such purpose, have adopted by statute, regu-
lation, ordinance, or otr.ar legally enforceable document, Che necessarv
requirements and schacula and timetables - for cc-.-s liar,ce. ar.d are committed
to implement and anfarta the appropriate elements of the plan; [Emphasis
added I
238
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These plan elements should be prepared in accordance with the guidance
on pages 186-133 of the Compilation of Presentations prepared by EPA's
Office of Air Quality Planning ana Standards (OAOPS) for the "Workshops
on Requirements for ^lonattainment Area Plans" February -March 1978
(pages 213-220 in the April 197S edition).
B. The I/H Implementation Schedule
The specific items listed below must be included as a part or the
States' I/H implementation schedules with specified datas for implementation
of each item. The stringency planned for the program and other factors
affecting the potential for emission reductions should also be indicated.
Additional items if necessary because of local factors nay be required by
USE? A P.egicnal Offices.
1. Initiation (or continuation) of public information
program including publicizing the I/M program in the
media, meeting and speaicing with affected interest
groups, etc.
2. Preparation of a draft legislative package and
submittal of legislation package to legislature
i"£ additional legislative authority is needed.
3. Certification of adequate legal authority by approp-
riate state official.
4. Initial notification of garages explaining program
and schedule oz implementation.*
5. Development and issuance of RFPs.*
6. Award to contractor(s).*
7. Initiation of construction of facilities.*
8. Completion of construction of facilities.*
9. Adoption of procedures and guidelines for testing
and quality control including emission analyzer
requirements (and licensing requirements for private
garages, if applicable*).
10. Notification of and explanation to garages of actions
in step 9.*
239
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11. Completion of aquipment purchase and delivery of
equipment.
12. Development and adoption of outpoints.
13. Initiation of hiring and training of inspectors or
licensing of garages.*
14. Initiation of introductory program (voluntary main-
tenance with either voluntary or mandatory inspection)
if not previously initiated.
15. Initiation of mechanics training and/or information
program.
16. Initiation of mandatory inspection.
17. Initiation of mandatory repair for failed vehicles.
If certification of adequate legal authority occurs after January 1979,
the States say modify previous comaitnents to iapl^nent and enforce the elements
of the schedule to conform to the legal authority.** These aoaif icatior.s will be
approved by the EPA Regional Offices ana must be consistent with the Administra-
tor's February 24, 1973, policy aenorancua. The documents should be subsided
to the EPA Regional Offices for inclusion in the SIP revisions already submitted
by January 1, 1979. Any necessary adjustments to the schedule taay be made at
this time but aust be approved by the EPA Regional Offices.
C. Authority to' laolaser, t I/M
Normally, adequate legal authority to Inplecent a SIP revision aust exist
for a revision to be approved. Where a legislature has had adequate
opportunity to adopt enabling legislation before January 1, 1979, the
Regional Administrator should require certification that adequate legal
authority exists for I/M implementation by January 1, 1979. However,
for many states there will be insufficient opportunity to obtain adequate
legal authority before their legislatures meet in early 1979. Therefore,
a certification of legal authority for the implementation ci-^^j.a
these states aust be aade no later than June 30, 19/9. An extension to
July 1, 1980, is possible, but only when the state can demonstrate that
(a) there was insufficient opportunity to conduct necessary technical
analyses and/or (b) the legislature has had no opportunity to consider
any necessary enabling legislation for inspection'/ maintenance betveen
enactment of the 1977 Amendments to the Act and June 30, 1979. Certifi-
cation of adequate legal authority, or other evidence that legal authority
has been adopted, aust be submitted to the EPA Regional Offices to be
included in the a I? rev«s*on already suosittec, Failure to submit evidence
of legal authority by the appropriate deadline will constitute a failure
to submit an essential element of the SIP, under Sections 110(a)(2)(I)
and 176(a) of the Act.
~Dependent on type of systea chosen (state-run centralis, contractor
centralised, or decentralized).
**See footnote on page 1.
240
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a a j°r respective deadlines for initiating nandatory insTjec^cn
and mandator repair of failed vehicles, the state, local governaenr «
regional agency should aaoot whatever legally enforceable recu—e-en*s
S^hn^eSfary ".e^urf Chat Nicies are not used unless the/^w
vith the inspection/maintenance requireaents. Written evidence of"
adoption or these requirements should be submitted to the E?A Regional
l! 1979 V0 iac~ud&d in che SI? "vision already subaicted by January
D. I/M Imoleaentation Deadlines
Implementation of I/M "as expeditiously as practicable" shall be
defined as iapleaentation of aandatory repair for failed vehicles no
later than two and a half years after passage of needed legislation or
certification of adequate legal authority for new centralized svste^s
and one and a half years after legislation or certification for'de-In-
tralizec systens or far centralized systaas vfaich are adding emission
inspections to safety inspections. For the noraal legislation deadl^e
of June 30, 1979, new centralized programs aust sjart by December 3i~"
1981, and all others aust start by Deceaber 31, 1980. For the case of
the latest possible legislation date, July 1, 1980, this Beans that a
new centralized prograc aust scare by December 31, 1582, while all othe-
prograns oust start by Deceaber Ul, 1981. Where I/M can be implemented"
more expeditiously, it aust be. Each state implementation schedule"auS =
be looked at individually to determine if it is as ertpedizious as practi-
cable. Iapleaentacion dates ordered by courts, if earlier than these
daces, cake precedence.
E. Geographic Coverage
I/H should focus on metropolitan areas and should include the entire
urbanized area and adjacent fringe areas of development. Boundaries cf the
area affected aay be adjusted if an equivalent eaission reduction is achieved.
For urbanized areas of 200,000 population or greater which need I/M to obtain'
an extension of the 1982 attainment date, lull mandatory I/M must be implemented
by the deadlines indicated above. Statewide programs are encouraged, "especiallv
for those states which are saall and highly urbanized.
It should be eaphasized chat all nonattainment areas must have SIPs
which are adecuate to attain and maintain the National Ambient Air
Quality Standards (NAAQS) by 1982 or by no later than 1937 should an
acceptable nonattainment demonstration be made. For araas under 200,000,
EPA will not at this tine automatically require I/M schedules in 1979 as a
condition for SI? approval or an extension. However, areas under 200,000
still have to aztainand raintain NAAQS as expeditiously as praczicable,
and I/M is encouraged as a aeans of helping to provide for an adequate
SIP. EPA will review the need for I/M in areas under 200,000 after the
1979 SI? revisions are submitted, and will consider additional require-
ments at chat time.
*See rootnote on page !•
241
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?, Emission Reductions Raauirad for I/M
I/M programs must produce at least a 25 percent reduction in light
duty vehicle (LDV) exhaust emissions of hydrocarbons and a 25 percent
reduction in LDV emissions of carbon monoxide by December 31, 1987,
compared to what emissions would be without I/M on the basis of the most
recent motor vehicle emission factors. However, the choices of stringency
factor to be used and other actions affecting the potential for emission
reduction should be made by the states. States should of course be
encouraged to develop programs which produce more emission reduction
when possible. The final revision to Appendix N (4Q C.F.R., Part 51)
when promulgated (along with its minimum program requirements) should be
used to determine if the program described in the implementation schedule
will meet the minimum 25 percent CO/25 percent HC criterion. Should a
program not need to be this stringent to attain and maintain the NAACS
by 1982, the I/M program need be only as stringent as needed to assure
conformity with NAAOS. Should a state want to emphasize control of one
particular pollutant at the expense of the other, the plan for such an
I/M program must be submitted to the appropriate EPA P.egional Office for
approval.
G. Minimum Program Requirements
In addition to the emission reduction requirement above, all I/M
programs must:
1. provide for regular periodic inspections of all vehicles
for which emission reductions are claimed;*
2. provide for maintenance and retesting of failed vehicles
to provide for compliance wich applicable emission
standards;
3. prohibit registration or provide some equally affective
mechanism to prevent vehicles which do not comply with
the applicable exhaust emission requirements from operating
on public roads;
4. provide for quality control regulations and procedures
for the inspection system including:
*Random roadside checks, while a useful addition to an I/M program-,
are not an acceptable substitute for regular periodic inspections.
242
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a. minimum specifications for emission analyzers
b. required calibrations of all types on analyzers and
c. minimum record keeping;
5. provide for either a mechanics training program or a program
to inform the public of service establishments vith approved
emission analyzers; and
6. inform the public of the reason for the I/M program plus
the locations and hours of inspection stations.
Decentralized system must also comply with the following reauira-
aieats.
1. All official inspection facilities must be licensed.
Provisions for the' licensing of inspection facilities
must insure that the facility has obtained, prior to
licensing^ analytical instrumentation which has been
approved for use by the appropriate state, local, or
regional government agency. A representative of the
facility must have received instructions in'the proper
use of the instruments and in vehicle testing methods
and must have demonstrated proficiency in these nethacs.
The facility must agree to naintain records and to submit
to inspection .of the racility. The appropriate government
asency must have provisions for penalties fcr facilities
which fail to follow prescribed procedures and for mis-
conduct.
2. Records required to be maintained should include the
description (make, year, license number, etc.) of each
vehicle inspected, and its emissions test results.
Records must also be maintained on the calibration of
testing equipment.
3. Summaries of these inspection records should be submitted
on a periodic basis to the governing agency for auditing.
A. The governing agency should inspect each tactile"
periodically to check the facilities' records, check,
the calibration of the testing equipment and observe
that proper cest procedures are followed.
5. The governing agency should have an effective program
of unannounced/unscheduled inspections both as a routine
measure" and as a complaint investigation measure. It is
also recommended that such inspections be used to check
correlation of instrumen*. read-i-n^s amon0 inspection
facilities.
243
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6. The governing agency should operate a "referee" station
where vehicle owners say obtain a valid test to compare
to a test iron a licensed station. At least one 'teferee"
station nust be present in each I/M metropolitan area.
244
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Attachment 1
Suggested I/M Milestones
Complete plan for preparing and implementing I/M SIP revision
including:
a. technical analysis
b« public information program
c. development of necessary legislation
d. development of I/M implementation schedule.
Complete technical analysis including:
a. emission reduction benefits
b. fuel economy benefits
c. costs.
Complete elements of a continuing public information program
including:
a- further publicity concerning oxidant (and/or carbon
monoxide) episodes
b. meeting with and speaking to affacted interest groups
(including the public and public officials)
c. news releases.
Complete development of legislative proposals.
Complete development of I/M implementation schedule.
Receive approval of I/M, including implementation schedule, from
air pollution control board or agency head as applicable and
introduce into stata legislature.
Submit SI? revision for I/M, including implamentation schedule, to
EPA (due no later than January 1, 19/9).
Obtain lesal authority needed to implement I/M (required by July 1,
1979, with some exceptions allowed until July 1, 1980).
245
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Appendix B
EMISSION CREDITS GIVEN IN THE CODE OF FEDERAL REGULATIONS
Appendix N - Emission Reductions Achievable Through Inspection,
Maintenance of Light-Duty Vehicles, Motorcycles, and Light-
and Heavy-Duty Trucks.
-------
Appendix B
EMISSION CREDITS GIVEN IN THE CODE OF
FEDERAL REGULATIONS
ENVIRONMENTAL PROTECTION
AGENCY -
[ 40 CFR Part 513
[FKL 703-4J
APPENDIX N—EMISSION REDUCTIONS
ACHIEVABLE THROUGH INSPECTION
AND MAINTENANCE OF UGHT OUTY
VEHICLES. MOTORCYCLES, AND UGHT
AND HEAVY DUTY TRUCKS
AGENCY: Environmental Protection
Agency.
ACTION: Proposed rule.
SUMMARY: This Appendix presents es-
timates of potential emissions reduction
benefits which, in the judgment of the
Administrator, are likely to be achievable
throush the application, of a properly
structured and managed inspection/
maintenance CI/M) program. Estimates
of emission reductions available through
retrofit programs, formerly contained in
Appendix N. have been deleted. Inspec-
tion/Maintenance program effectiveness
is given as a function of the level of
technology, the stringency "of emission
standards, the length cf program opera-
tion. and the adequacy of mechanic
training. Basic program requirements are
outlined for both the centralized and
decentralized program -concept. Attach-
ment 1 provides a discussion of the mo-
deling techniques utilized to generate the
emission reduction estimates, \rhile At-
tachment 2 provides computational ex-
amples illustrating the usage of Appen-
dix N.
FOR FURTHER INFOE1IATIOK CON-
TACT:
John O. Hidinger. Director, 03ce of
Transportation and Land Use Policy
(AVV-443) UJ3. Environmental Protec-
tion Agency, 401 M Street SW.. Wash-
ington. D.C. 20460 (2O2-755-04SO).
ADDRESS: Submittal of Comments:
Comments upon Appendix N are re-
quested. Such comments should be di-
rected to the individual belowund post-
marked no later than August 1, 1977.
Dated: April 19,1977.
Douglas M. Costxx,
Administrator.
In Part 51, of Title 40. Code of Federal
Regulations, Appendix N is revised to
read as follows:
Arrzxvzx N—Emission Reductions irco
Achievable Tkuccch lusprenos 'and
MAijrrswAKcr or lassn Dtrrr Vmictxs.
Motokctclxs, ajs~d Ljckt ajtd Heavy Dl. i
Treats
AWHoairr: Section 301 (a) of the Clean
Air Act as amended by section 15(c) (3) of
Pub. I* 91-604. 84 Stat. 1713: 81 Scat. 504
(42 DAC. 1857g(a)).
L Introduction. This Appendix presents
estimates of tie potential emissions reduc-
tion benefits which, is the Judgment of the
Administrator, are Ukely to be achievable
through the application of a properly struc-
tured and managed inspection.'maintenance
(I/M) program. Since the publication of the
original Appendix N, new data obtained and
experience gained from operating programs
have shown the necessity for a revision to
certain portions of this document. Zn addi-
tion. estimates of emission reductions avail-
able through retrofit programs, former!? con-
tained in Appendix N, have been deleted.
Retrofit guidance will be placed in a separate
appendix consistent with a format to be fol-
lowed for other strategies.
To the extent possible, estimates La this
Appendix are baaed on empirical data. How-
ever. lack of data in several areas has neces-
sitated extrapolation of empirical data using
modeling techniques based on sound engi-
neering Judgment. A description of these
modeling techniques is contained in Attach-
ment 1. As new data became available. or
as predicted extrapolations change, this
Appendix will be revised and amended
accordingly.
Several definitions have bees, modified to
reflect their intended meaning. Most impor-
tant, "initial failure rate" has been redefined
as a "stringency factor." Hopefully, this new,
definition will dispel past misapprehension
concerning the "Initial failure rate" concept.
In addition, the idle test has been slightly
redefined to reflect actual idle emission test-
ing currently being used.
The minimum requirements of an 1-1'
program are defined. Those programs which
are contemplating the use or a private garage
I/M program should note the special require-
ments necessary to obtain the basic emission
reduction credits.
- Emission reductions for light duty vehicles
are estimated not only for the first year of
an I<"M program but also for subsequent years
since modeling has shown that the reduction
benefits can increase with time. Additional
emission reductions are estimated for those
programs which Include twice-a-year inspec-
tion and special mechanic training. Estimates
of emission reductions resulting from t/ZI
programs for light-duty trucks, heavy-duty
tracks, and motorcycles are also given.
Certification data and recent surveillance
data indicate that I/M effectiveness ma? be
greater (especially for carbon monoxide i' for
catalyst equipped in-use vehicles than-for
pre-cataiyst vehicles. By the time many I/M
programs are fully implemented, catalyst-
equipped vehicles will dominate -.he vehicle
mix. Estimates are therefore given for the ef-
fectiveness of I/M on such vehicles, despite
the limited data base at the present time.
Tables 1 through 3 summarize the emis-
sion reductions obtainable 'rom I M pro-
FeO£RAl REGISTER, VOL 42, NO. 84—MONDAY, MAT 2, 1977
249
-------
* W I
grans. The actual benefit obtained by any
state or Tegion Implementing a well-designed,
program may exceed the emissions reduc-
tions listed. Such higher reductions, how-
ever, would have to be shown through, an
adequate source surveillance study.
2. Definitions, a. "Cutpotnt" means the
level of emissions which discriminates be-
tween those vehicles requiring emission-re-
lated maintenance end these that do not.
b. "federal Teat Procedure" (FTP)—A se-
quence or testing utilized by the Agency to
measure vehicle exhaust emissions over a
typical urban driving cycle.
c. "Heavy-duty vehicle" means for the
purpose of this Appendix, a gasoline fueled
motor vehicle whose GVW is greater than
8.200 pounds.
0. "Idle emissions test" or "Idle teat"
means a test procedure for sampling exhaust
emissions which requires. operation of the
engine in the idle mode only. At a minimum,
the idle test should consist of the following
procedure carried out on a fully warmed-up
engine: a measurement of the exhaust emis-
sion concentrations for a period of time of
at least 15 seconds, shortly after the engine
was run at 2.000 to 3,500 rpm with no load
for approximately SO seconds.
e. "inspection/maintenance" means a
strategy to reduce emissions from ln-use ve-
hicles by Identifying vehicles that need emis-
sions-related maintenance and requiring
that such be performed.
f. "Light-duty vehicle" means a passenger
car or passenger car derivative capable of
seating 12 persons or leas.
g. "Light-duty truclt" means, for the pur-
pose of this Appendix, a motor vehicle de-
signed primarily for the transportation of
property, or the derivation of such a vehicle,
whose GY"W is 8500 pounds or less.
h. "Load emissions teat" or "loaded test"
means a test procedure for sampling exhaust
emissions which exercises the engine under
loading by use of a cs««in dynamometer to
stimulate actual driving conditions. As a
miTi'mum requirement. the loaded test must
include running the- vehicle and measuring
exhaust emissions at two speeds and loads
other than idle.
1. "Motorcycle" means for the purpose of
Appendix, a two-wheeled motorized ve-
hicle designed to transport persons or prop-
erty on a street or highway.
j. "stringency factor" is a measure of the
rigor of a program based on the estimated
fraction of the vehicle population whoae
emissions would exceed outpoints for either
or both carbon monoxide and hydrocarbons
wei* no improvements In maintenance hab-
its or quality of maintenance to take place
as a result of the program.
v "Tampering" means, for the purpose of
this Appendix, rendering inoperative, or in-
tentional misadjustment of any motor .ve-
hicle device or element of design intended'to
control-exhaust emissions.
1, "Technology I" means the general type
of exhaust emission control technology uti-
lized on all light-duty vehicles subject to
pre-1973 Federal emission standard*.
m. "Technology U" means the general type
of exhaust emission control technology uti-
lized on light-duty vehicles subject to 197S
later model year federal exhaust emis-
sion standards. -
X Emission reductions /or light-duty ve-
hicles. Tables 1 through 4 list emission re-
ductions for light-duty i vehicles that can be
achieved through properly structured and
managed programs of inspection/ mainte-
nance and accompanying mechanic training.
See Attachment 1 and 2 for a description of
the derivation of these credits and for com-
putational examples of the use of the tables.
ik first year program crtdiu. The follow-
ing first year credits are applicable to both
idle and loaded tesu.
Table I.—First year of program credits
Table 4.-
Strirf ney -
lacior
EC (percent!
Tw:h-
noioty
1
Tech-
nology
XI
CO (percent)
T'-cii-
noloiy nolcgy
1 H
0.J0
1
3
s
.20
S
3
a
20
,30
7
9
13
28
.40
10
16
33
.20
11
24
«v»
37
b. Subsequent years program credit. The
following additional (to Table 1) credits are
applicable to vehicles which have undergone
more than one Inspection by the beginning
of the calendar year of Interest. These cred-
its ara not applicable to programs having
inspection Intervals of longer than one year.
For a model year group of vehicles, the ap-
propriate credit is selected on the basts of
the specific number of Inspections that the
group has incurred by the beginning of the
calendar year of Interest. The credit is then
added to the appropriate first year credit
above. Credits are applicable to both tech-
nology level cases, to the idle and loaded
tests, and to all stringency factor programs.
Tjlblx 2,—Subsequent years program credi
.1
N umber al
inspections ¦
Additive credit
BC (percent) CO (percent)
! :=E
a
;
8 Yrzcoril.!
14
20
23
30
33
36
S
12
19
23
T.
30
34
Strtntency •
Actor
Technology I
T'.thnolOfr II
nc
(percent)
CO
(percent)
HC
(percent)
CO
(percent)
a 10
.20
.30
.40
..58
7
10
10
•Mechanic training subsequent
year credits
Tictinolon I
Number oI Inspections
Strinc^ncy
(actor
3 or mors
HC CO HC CO
(percent) (percent) (percent) (percent)
a io
3
3
15
IS
.20
4
8
10
12
.30
6
S
9
9
.40
5
5
S
5
.60
3
2
3
2
Teeimolon K
Stringency
Number o t inspection*—2 or aort
HC
CO (percent)
0.10
10
A
.20
8
n
.30
2
I
.40
1
3
.50
1
I •
c. Semi-annual I/M program credit. A
credit of .0.2 percent per subsequent semi-
annual inspection may be added, up to IS
times, to the first year (Table 1) credits for
those programs requiring semi-annual in-
spection. This credit is applicable at all strin-
gency factors for both HC and CO. idle and
loaded tests, and both technology levels.
d. Mechanic framing program credit. The
following additional credits may be taken
for She' presence of an adequate program of
mechanic training.1 Table 3 provides the
basic credits for Tn»ch»ni^ training, while
Table 4 lists the appropriate credits to be
added to Table 3 credits for subsequent
years of program operation. The sum of Table
3 and 4 credits is then to be added to the"
basic credit computed from Tables 1 and 2.
TABLE 3.—Mechanic training first year
credits
The above Table 4 credits are applicable to
vehicles which have undergone more than
one inspection by the beginning of the calen-
dar year of interest. For a model year group
of vehicles, the appropriate credit Is se-
lected on the basis of the technology level
of the vehicles, the number of inspections
the vehicles have Incurred by the beginning
of the calendar year of Interest, and the
stringency factor of the I/M program. The
credit is then added to the appropriate first
year mechanic training credit (Table 3) and
the result is added to the basic credit cal-
culated from Tables 1 and 2. Credits are ap-
plicable to both the idle and the loaded test.
Inspection/maintenance approaches are
expected to be applicable to heavy duty
gasoline fueled trucks and motorcycles. l>
well as light duty vehicles.
a. Emission reductions lor motorcycles end
kglit duty trucks. The estimated emission
reductions for this group of vehlcies are the
same as those given In Tables 1 through 4
for Technology I light dnty vehicles.
b. Emission reductionj /or heavy duty
trucks. Estimated emission reductions due
to I/M for gasoline fueled heavy duty ve-
hicles, using either an idle or loaded emis-
sions test are ss follows:
Table 5.—Heaty duty vehicle I'M credit
.1
Stilneiney
factor
BC (percent)
CO (percent)
120
.30
.40
.40
11.4
1X3
13. S
17.2
8.3
».:
10. J
12.11
1 "adequacy" of a mechanic training
program will, for the present, be determined
on a case-by-case basis. Guidelines will be
Issued In the future if found to be feasible.
Analysis of data (generated by the City of
New York under EPA grant) on 65 truclcs
Indicate that I/M is a potentially viable emis-
sion reducing strategy. The estimated emis-
sion reductions given above are based on
these limited data. Mo data on the deteriora-
tion of trucics with or without I/M are avail-
able. The assumption utilized to develop
Table 5 Is that the average yearly effective-
ness rt one-balf ofthe initial benefit achieved
as a result of a tune-up.
FEDERAL REGISTER, VOL 45, NO. » 4—MONDAY, MAY I, 1977
•250
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PROPOSED RULES
22179
S. Basic program requirements. There in
two teste types at operation which may be .
utilized for an I/M program, namely a cen-
tralized Inspection system (government or
contractor operated) and & decentralized in-
spection system (private commercial f[a-
rages). In order to obtain, lull emission
reduction benefits' for either * centralized
cr decentralized inspection system. certain .
minimum requirements are established,
•which if not met, *111 result in assessed emis-
sion reductions lower than those listed in
Ta&les 1 through 5 or tiis Appendix.
a. Program requirement!—Minimum' lor
ail programs.
i. Provisions tar regular periodic inspec-
tion (at least annually) of all vehicles for
which. emissions reductions are claimed.
ii. Provisions to ensure that failed vehi-
cles receive the maintenance necessary to
achieve compliance with the inspection
standards. The basic method is to require
that tailing vehicles pass a retest following
maintenance.
lil. Provisions for quality control. Hi#
reliability of the inspection system and
equipment accuracy must be ensured. Tills
will include routine maintenance, calibra-
tion and inspection of all I/M equipment,
and routine auditing of inspection results. .
b. Minimum decentralised program re-
quirements. In order to receive the basic
emission reduction benefit for a decentral-
ized I/M program, the following require-
ments must be Included in addition to pro-
visions Usted in Section 5(a).
1. Provisions for the licensing of inspec-
tion facilities which insure that the facility
has obtained, prior to licensing, analytical
instrumentation vrhich has been approved
lor use by the appropriate governing; agency.
A representative -of the facility must hare
received instructions in the proper use of
the instruments and in vehicle testing
methods. The facility must agree to maintain
records, to collect signatures- of operators
Those vehicles have passed inspection, and
to submit to inspection of the facility.
IL Records required to be maintained
should include the description (make, jeir,
license number, etc.) of each vehicle in-
spected, and its emissions test results, acc-
ords must also be maintained on the calibra-
tion of testing equipment.
ill. Copies of these inspection records
should be submitted on a periodic basis to
the governing agency lor auditing.
iv. The governing agency should inspect
each facility at least once every 90 days to
check the facilities' records, checlc the cali-
bration of She testing equipment and ob-
serve that proper test procedures are fol-
lowed.
v. The governing agency should have an
effective program of unannounced/ unsched-
uled inspections both as a routine measure
and as a complaint investigation measure. It
is also recommended that such inspections
be used to checX the correlation of instru-
^ment readings ¦T-mng inspection facilities.
c. Motorcycle mi heavy duty truck pro-
gram requirements. An acceptable I/7S pro-
gram for motorcycles and truefcs must in-
clude the same provision specified in Section
. S for light duty vehicles. In addition, f. source
'"surveillance program, such as discussed in
•Section S(c) is strongly recommended for any
^emission reduction estimates for motorcycles
~*sd heavy duty vehicles. The test procedures
*od program design for the evaluation of
'
-------
signed to an: the more stringent 1973 aad
later emission standar da. Samples of vehicles
of tie two technology levels were Input to
the model, and were taken as representative
of Technology I and Technology II vehicles
on a nationwide basis. Please note: all com-
putations is Attachments l and 2 are based
upon ".he metric system.
I. Description of t.1e simulation model of
the inspection/maintenance process. The I/M
process as currently conceived In the model
consists of the following events:
1. Emission deterioration from existing
levels.
2. Inspection lane testing of HC and CO
levels using the Idle test to detect high FTP
emitters (NOx emissions are insignificant at
Idle, and therefore are not considered In the
model),
3. Maintenance or repair (resulting In lower
emission levels;, IT a vehicle Tails the inspec-
tion.
Each vehicle undergoes ibis sequence of
events throughout Its useful life, which la
assumed to lie nine yens, or approximately
160,000 kilometers.
The model compares avenge FTP emissions
In the case where an I/M program is opera-
tional , with emissions tn the case where so
I/M program exists. Benefit Is calculated aa
the percent reduction In FTP emissions from
the average level In the no I/M case. FTP
emission levels art used to measure benefit
since the FTP driving cycle Is assumed to be
representative of vehicle operation la urban
areas. Two types of benefit can he computed:
(1) the average benefit over a vehicle's life,
and (2) the benefit In a particular year of a
vehicle's life. Both types of benefit are de-
pendent upon the vehicle's level of emission
control technology and the number of times
the vehicle has been subjected to a manda-
tory Inspection program. The average benefit
for a population of vehicles in a-givea calen-
dar year is computed from the Individual
technology level vehicle benefits given In Ap-
pendix N, which are of the second type. The
calculation methodology Is discussed In a
later section of this Appendix,
Issues a Meeting estimated I/Zt benefit. Ben-
efit due to I/M depends upon the assump-
tions used to Implement the simulation at
the I/M process: that Is, the assumptions
surrounding the three events Identified
above. Because the currently available data
are limited, assumptions were made regard-
ing some of the Issues that logically affect
benefit. The model refiects these assumptions,.
which were based on engineering judgment.
The Issues and assumptions are discussed
below.
Issue 1. Emission levels of vehicles at first
Inspection.
Concept. Benefit is the first and subse-
quent inspection years Is expected to depend
on the emission levels of vehicles at their first
Inspection. There are two ways la which dif-
ferences in the first year emission levels could
produce significant differences in benefit.
First, it ts possible that for vehicles of a given
age there will be differences in the distribu-
tion of emission levels at fixat inspection
from one technology level to another; for ex-
ample. it might be the ease that for one tech-
nology level vehicles have either very low
or very high emissions at first Inspection,
whereas for another technology level vehicles
have emissions which are clumped closely
together around some average value. This
situation could possibly result tn more bene-
fit for the first technology level case, even If
the same percentage of vehicles of each tech-
nology level were to fall an inspection. 3lnee
failures Is the first technology level case
could result in bigger drops is emissions
percentagewise. Second, within a technology
level, different emission levels at the time of
I/M implementation will naturally exist for
different model year vehicles, and It Is pos-
sible that these absolute numerical differ-
ences will result In benefit (or percentage)
differences as well.
Assumptions. The first year Appendix 7t
benefits, and indirectly the benefits for each
subsequent Inspection year, were determined
by analyzing the emissions performance of
one-year-old caxs with and without I/M.
Separate benefits were calculated for the
Technology I and Technology n cases. Tech-
nology I first year benefits were based on
emissions data on 130 1973-74 models tested
in the FY *73 Emission Factor Program. Tech-
nology n first year benefits were based on
emissions data on 587 1375 models tested tn
the FT "74 Emission Factor Program. These
vehicles were tafcen to be representative of
the nationwide mis of low altitude nan-
California one-year-old Technology I and
Technology H vehicles, respectively, in terms
of mileage and maintenance characteristics.
As Appendix N benefit numbers Indicate, I/M
benefits differ by technology level, at least for
CO.
With regard to different first year emission
levels that all model year vehicles, regardless
of age. obtain the same first year benefits.
This assumption Is based upon the premise
that, far public acceptance reasons, the first
year pass/fall outpoints would differ with
age or model year so that all vehicles would
experience similar failure rates. Limited data
indicate that under this premise, benefits (on
a percentage-wise basis) are similar,
issue 2. Emission. deterioration.
Concept. Emission deterioration Is the
process whereby vehicle emission rates In-
crease over time from the levels at which the
vehicles were Intended to emit when new.
Emission deterioration Includes changes In
emissions due to normal wear of engine/
emission control components as well as
changes la emissions due to tampering or
poor maintenance.
Assumptions. The deterioration rates used
la the model are expressed as a percentage
of low mileage average FTP values per year.
These percentage rates are assumed to be
equal for all vehicles of a given technology
level, and are constant over time. Specifically,
the rates were talcea to be IS percent per
year for HC and 15 percent per year for CO
for Technology I vehicles: 21 percent per
year for HC and 14 percent per year for CO
for technology n vehicles. These rates are
based on data from EPA's FT '71 through
FT "74 Emission Factor Programs aad repre-
sent vehicle deterioration under typical owner
maintenance practices. For a given pollu-
tant aad vehicle, the model considers the
FT? rate of deterioration per year (grams/
Kilometer/year) to be constant over time.
Thus, deterioration is modeled as a linear
phenomenon. The grams/lcilometer/year
value Is calculated as the overall deteriora-
tion rate, (in percent) multiplied by the in-
dividual vehicle's first-year emission level.
Thus, each vehicle is considered to be sa
inherently low or high emitter with respect'
to each pollutant: vehicles-Which have low
emissions when new will continue to have
relatively low emissions as they accumulate
mileage Emissions of vehicles In the no I/M
case are assumed to deteriorate throughout
their useful life until they reach the average
levels of pre-con trolled can at 161,000 Idiom-
etsrs (100.000 miles).
Significant percentages of catalytic con-
verter failure may occur with increasing ve-
hicle age and if such a situation does occur,
the emission rates will increase sharply In
later years: that is. a constant deterioration
rate assumption will not be valid. However,
the surveillance data currently available to
EPA do sot cover mileage ranges extensive
enough to estimate the frequency and effect
of such failures.
The FTP deterioration rate (grams/
kilometer/year) is assumed not to be af-
fected by the existence of an I/M program.
However, if an I/M program is operational
the deterioration process Is not continuous
because deterioration Is Interrupted by an-
nual idle test emissions Inspections. If a ve-
hicle fails the Idle test, its emissions are as*
sumed to be reduced via maintenance cr
repair to meet the pre-detecnlned idle test
standards. Th.e FTP emissions are assumed
to be reduced correspondingly, as deter-
mined by regression relationships. Follow-
ing an I/M repair, the deterioration process
continues under the assumption that a ve-
hicles yearly rate of deterioration (gm/Icm)
Is unaffected by the repair that occurred.
The implication Is that the Inherent emis-
sions characteristics of a vehicle cannot be
Improved via repair. If a vehicle passes the
Idle test. Its emissions are left unchanged
for the calculation of the average amission
levels (gm/km) following the round of I/M.
The deterioration process then continues
until the next annual Inspection occur.
The Idle test deterioration rate per year
(percent CO or ppm HC) is also assumed to
be constant over time for each vehicle. Idle
teat deterioration rates are determined from
FTP deterioration rates using the following
rationale: The effectiveness of I/M m reduc-
ing ln-uae vehicle emissions as measured
over the FTP requires that the short test
used la the Inspection lane be an accurate
predictor of FTP passage or failure. One way
to ensure this is to define the Idle deteriora-
tion rate in terms of the FTP deterioration
rate. Currently Is the model the assumption
Is made that FTP emissions can be quan-
titatively predicted from Idle test emissions,
and vice versa. The idle deterioration rate
for a given vehicle Is determined from the
FTP deterioration rate and a regression re-
lationship. Based on data over a limited
mileage range, the relationships are assumed
to be Independent of milage and mainte-
nance state.
Issue 3. Short test pass/fall cutpolats.
Concept. The "purpose of an Inspection/
maintenance program is to reduce the emis-
sions of la-use vehicles as measured over
the FTP. A short emissions test procedure
Is Intended to provide a practical method
(l.e'„ quick and Inexpensive) for Identifying
high FTP emitting vehicles. The benefit asso-
ciated with an I/M program Is dependent
on the methodology used to determine the
short test pass/fail cutpclnt lor each pollut-
ant from year to year. The method of de-
termining Initial short test outpoints has
varied la practice from assigning outpoints
that are make/model specific . to assigning
one set of cutpolats for all light duty vehi-
cles with similar emission control tech-
nology. The possibility of changing shore test
cutpolats to reflect vehicle age is also aa
Important consideration.
Assumptions. The HC and CO cutpolats
on which the Appendix N benefits are based
are technology level specific. Thus, all vehi-
cles of a given emission control technology
(for example, catalyst-equipped cars) are
assumed to have the same cutpotnts. Cut-
points for the first year of the simulated
I/M program were set by first specifying a
stringency factor and then analyzing appro-
priate EPA emission factor data on one-year-
old vehicle.- which were assumed to be repre-
sentative of the nationwide mix of one-year-
old vehicles. The analysis resulted In the
determiaatlon of idle test pass/fail cutpolats
for HC and O which corresponded to the
specified stringency factor (ranging from
10 percent to 50 percent). For example. If
a 30 percent stringency (actor was specified,
then HC and CO idle test cutpotnts were de-
termined so that approximately 30 percent
of ail vehicles would Jail the Idle test at
FEOEXAl REGISTER, VOL. 42, NO. S4—MONDAY, MAY 2, 1977
252
-------
- the first inspection assuming that owners
•rdld not cbugg their maintenance hailts
-from thoe* typically la effect prior to tie
implementation of I/M.
- The relative stringency factors for HC and
CO were determined by assuming that a car
emitting at twice the HC FTP standard la
equally likely to be railed as a car wiilch-
1s emitting »t twice the CO FTP standard.
This amssptlon is only one of an infinite
number or xits that relative SC and CO
stringency ractors could be weighted to
achieve the apedfied overall stringency 'ac-
tor. For example, since more AQCHs exceed
ambient oxidant emission standards than ex-
ceed aw,Meat CO standards, a car at vwica
the HC TT? emission standard could be con-
sidered equally likely to fall as a ear which
la at four times the CO FTP standard. The
result or the weighting criterion which was
applied Is that at sflngeacy levels below
30 percent, the large majority of vehicle
failures caa be attributed to high CO emis-
sion levels; even though significant percen-
tages of HC failure are detected at strin-
gency leveU of 40 percent and above, SC
failure is sever u high as CO failure, per-
centagewise.
One of the model's critical aeazaptsns
with regard to cutpoint specification. Is that
the ant year outpoints continue to be used
year after year to determine which vehicles
win pass or fan the idle test. One implication
of the assumption of maintaining constant
cutpoints over tame is that vehicles can con-
tinue to be repaired to meet the same stand-
ards year after year, regardless of vehicle age
or mileage. In support of this assumption,
data from the 1972 and 1973 EPA In-use
Compliance Program (ZXJCP) programs indi-
cate that vehicles can continue to be repaired
to FTP levels well below short test levels
which represent 50 percent stringency levels.
¦ If service industry repair capability la as-
sumed to be minimal (as in the base case
Appendix N credits, where failed, vehicles are
repaired just to meet the Idle test cutpoints),
another Implication Is that the percentage of
failed vehicles increases over tune to about
twice the initial stringency factor if. as the
model assumes, significant voluntary owner
maintenance does not occur. Data from I/M
programs in. Sew Jersey and Chicago indicate
that the failure rates of a given model year
of vehicles do not increase significantly as
vehicles age. even though the same cutpoint
Is applied. Thus, either considerable volun-
tary maintenance is occurring or mechanics
are repairing vehicles to levels significantly
better than the minimum required repair
levels.
/save 4. Service industry repair capability.
Concept. Air quality benefit derived from
.an I/M program Is dependent on the ability
of the service industry to pet/mm the repair
work necessary to lower emissions. Depending
on the level of service industry training. Idle
emissions could be reduced Just to the cut-
points, or wen below the cutpoints, poten-
tially resulting in different benefits to air
quality.
Assumptions. The base ease benefits given
la Table l of Appendix V assume that the
service industry is capable of repairing all
tailed vehicles exactly to the idle test cut-
points. Then the equivalent FTP levels are
computed so that the average urban bene-
fits can be calculated. The model assumes
that a vehicle which Is railed incorrectly on
the idle test does not hare Its 5TP emissions
nther raised or lowered by the repair proc-
ess. The model also assumes that a vehicle
*tich fails for one pollutant only nil hare
-he other pollutant emissions lowered to the
equivalent idle standard in cases where
errors or emission occurred.
Additional benefit is predicted U mechanic
Gaining Is in effect. The model assumes that
merManlr training would mult Is the reduc-
tion of *mmion* of failed vehicle* to the
7T? standards. At tn the base case, the model
assumes that 12 a vehicle falls for one pol-
lutant only, the other pollutant will also be
reduced to the FTP standard If an error of
emission occurred. The first year credits in-
dicate a dependency on stringency factor.
For catalyst vehicles, the tendency is for me-
chanic aiming to have the largest effect on
programs with stringency factors of 20 and
30 percent. This is reasonable because the
efiect of mechanic training is Jointly depend-
ent on the percent of cars failed and the de-
gree of improvement In the FTP levels of
repaired vehicles resulting from the me-
chanic training program: If only 10 percent
of ill can are failed initially, then only 10
percent of all ears are repaired so that even
an apparently significant increased reduction
due to mechanic training win be somewhat
dampened by the fact that a good percentage
of the remaining cars are undoubtedly high
FTP emitters which simply were not caught.
If. on the other hand, SO percent are failed
and the PTP standardsln gm/taa are approx-
imately equal to the FTP levels correspond-
ing to the more sttingeat idle test cutpoints _
additional benefit due to mechanic training
would be Insignificant. For precatalyst CO.
the tendency described a bore, although less
apparent, rCH teems to be present Eowever,
precatalyst EC exhibits a tendency for me-"
'•ha-ir training to have an increasing efiect
wtth increasing stringency factor. The tend-
ency is explained by the fact that for the
data which were input to the computer pro-
grams. the HC FTP standards tagm/Sai was
significantly lower than the FTP level cor-
responding to the idle test HC cutpoint, even
at stringencies of 40 to £0 percent. As a re-
sult, an Increased percentage of failed ve-
hicles continued to produce Increased benefit
due ;o mechanic training.
The model assumes that owner tampering
following the sequince of events: failure ol
the idle test, vehicle repair, and subsacuent
paw ge of the idle test, does est occur. Sines
motcrjts frequently attribute driveabllity
problems to properly-functioning emission
control devices, this assumption may be
somewhat unrealistic v.-1 mechanics be-
come more knowledgeable about the trade-
offs between performance and emission rates.
However, a good estimate of the frequency
and effect of owner tampering (either with
or without US) Is not available at the prsseni
time, l^oreover. the benefit credits given in
Apoendix " require the esistence of an ef-
fective anti-tamperlng program.
Izrj£ S. Frequency of inspection.
Ccncrpt. Since emission deterioration is
modeled to occur continuously over time, the
frequency of Inspection determines the ex-
tent of vehicle deterioration bccween inspec-
tions. The mere frequent the inspection, the
less the vehicles deteriorate and thus the
greater the I/M benefit.
jjmimptioru. Por the base cause benefits
given in AopendU K, inspections are modeled
to tahe place —¦»''T Additional benefits
rescit from semi-annual taapeettons. The dif-
ference in benefits from the annual to the
1-t—' -...-i.Tai case is presented in section
3(c) of Anoead» K.
;.srt:c 5. Short test procedure used Is tni
tosoeetion lane.
Cwrpt. Since the Intent cf an LOC pro-
— — 13 vo reduce the emissions of in-use
ve'-'cies as measured over the FTP, one would
lri~"y be able to desirn a short emissions
idle test is used in the Inspection lane. Lim-
ited analysis using the simulation model In-
dicates that benefits using the Idle test and
a loaded test are comparable since the two
tests-are equally able to Identify high FTP
emitters.
Attachment 2
MrraoDOiOGT ro* a^pltinc af*ekdk ?r
iiMU1.; jrcatBiats
Tables 1 and 2 of Appendix >T provide the
I/M benefit numbers necessary to calculate
the estimated calendar year percent reduc-
tion. in HC and CO emissions from emission
levels expected in the absence of" I/M. To
determine the percent reduction in HC and
CO emissions for a given calender year, the
Appendix N numbers must be applied' to
the scenario in question. The scenario is
specified in determining' the fallowing for
the calendar year i of Interest;
1. The calendar year. y. in which an I/M
program was implemented.
2. The number or percentage of vehicles
of each model year (i—12 through 0 con-
tributing to the total vehicle population
(vehicles of model years earlier than i—12
should be considered as model year i—12),
3. Average vehicle kilometers traveled by
each model year group of vehicles, v-
4. EC and CO emission factors (grams/
kilometer) for each model year group of
vehicles, assuming r/JI has never been In
effect
The calculation of emission reduction in
kilograms for a given pollutant (HC or CO)
In calender year i is performed as follows:
aisles in
procedure m
applicable
ir2 hasei on
¦ 2 ;
(-1-12
i e,i "i,i
where
fit-
fi if
percent reduction is emissions (or n bides i>[
model year t m calendar yrar i,:
'crlnion factor (puins/lsilooter) for whirli* of
mode! year t ir. calendar year i. assumin? haj
never been is ellect.
'aveiase kilometers trsrtiwl by vehicles of icodW
year; la calendar year (.
¦aaher of vchiclis of model year f hi calccd.-.-
year f,
?Th« benefit ncrebere :r. Tabli-! 1 throccli 4 cf
dix N (which r*5i««it both The i>e« ease of
the esse whew raechanic trauiiae »nd/or a
-------
rnvruseu KULtS
du year t u a result or I/M, is performed u
follows:
(Sn.>
(100-B,)-
100
'^2
whert Si. f.;, ind i.jmrf as defined sbovt. ("Kcyiacw-
m*nt d a« *ttb P>< vui yiejd rn» urn nnmanrni results*.
Appendix N can also be used to compute
the avtr»?s percentage beneftt ot I/M ior a
given Tetucle over Its useful life. which Is
assumed to be nine years or approximately
160.000 tiiometers and represents eight an-
nual I/M inspections. If the vehicle Is of
model Tear : and I/M began. In calendar
7ear y, this percent reduction In emissions
far a speciic pollutant Is computed as
follows :
r,= ioo
'(jEj ek,,mk.?J<
*bw»
i-csWadsr yean Meeting *.h« useful lil« o( tw-
bkU of modal y«ar <: * »t, t+U • " <+8.
&>.<—ptrcrat reduction in emissions lot rehidts ol
node! y»ar t in eslesdar ynt It.'
a ,»rauiion (actor (grams/lalonieier) tor v«hic!ra of
mod»l ;nr t in calendar year t, assuming IM
has a»«r b«n in eilect.
mi I'lTeim fcilomrten traveled by vehicles ot model
7 ear <"ui caleiwar year t.
' The benefit numbers in Tables 1 through * at Ap-
pendix X (w&icb represent hoth tile base ease ol I/M ldd
tbe esse wbere mechanic training and/or s semi-annual
piuMfsm is in cCrc:;. can be used to determine &».<• by
lderulymf the technology lerel represented by vehicles
ot model year >' md tfce number ot inspections which
TrSirles o( ziodel ;«! nave imdereane by the bejirmmj
oi talenilar year t. The number ol inspections (for calen-
dar years tii#r calendar year v) can be calculated formally
as tie ot {k—t) aud (*—0 for an annual I.'il
pi'/jum. »-tert } is the year in w'niclr I/M was imple-
r:witecL f is tiie mode* year, and t is tits calendar year.
Note tilt in.,»0 for t less tban or equal to jr.
Nationwide estimates of the number of
vehicles ol each model year In the calendar
year of Interest, and average kilometers
traveled by each model year vehicle lor the
calendar year of interest can be obtained by
referring Table 1 which provides nationwide
estimates of number of vehicles by vehicle
a$e, and average leilometers traveled by ve-
hicle age. Nationwide estimates of emission
factors by calendar year are available In
A?—42. Tables 2 and 3 provide, for illustrative
purposes only, sample emission factors for-
calendar years 1377-1980 In format to be
utilised la the upcoming revision of AP-42,
Supplement 5.
Examples of the application of the met?i-
odalotfy for calculating benefit. ¦
Specification, of scenario for problem ex-
amples 1 and. 2. Tha nationwide mix of vehi-
cles by age and average VBTTs, as given !n
AP-42. applies. An I/M program with a 40
percent stringency factor was implemented la
1973, and vehicles one-year-old or older were
tested by the end of calendar year 1973.
Problem I. Determine the present reduc-
tion la emissions for BC and CO In CT 1977,
assuming t^ac th« I/M l&spections ax® an-
nual, »&d tiut no mechanic training program
is in e£ect.
Soitiiion. Tiie percent reduction, Srr, cm
be calculated irom 'Jit formula:
factor {ffuftm) for T^htelcA of meir.tm~.>'PT>.
Bt7 =
-X100,
y, eTt.imTT.iPn.i
t-77-12
wh»f A
^.¦-percent reduction to emissions tor vehicles ot
model ynr t m calendar year 1B7T (obtained from
Appendix N},
1977
0
0.9
2S.6
0-081
0
L*7
1976
17
LI
24.2
.110
.50
193
1975
25
1.2
22.5
.107
. 72
189
137-4
35
2.9
21.1
.irwi
6.49
1973
41
3.4
19.6
.102
2.79
130
HC 1972-
41
3.7
IS. 2
.096
2.65
146
1971.
41
4.1
16.6
.066
m. 46
5.99
1970
•41
4.5
15.1
.077
115
5.23
1969..
41
4.9
11.7
. 064
L76
<30
19®
41
5.3
12.2
.019
L30
3.17
Pre-19«..
- 41
i;
10.8
. 120
3.24
7.91
19.84
54.04
-
(percent)
en, i »tt, i
Nu- Denom-
mer»- inscor
tor product
product
WT7
0
U.7
25.6
0.081
0
30.5
1976
40
16.6
24.2
.110
17.7 '
44.2
1973
51
IS. 6
22.5
.107
22.S
4A.8
1974
47
35.3
21.1
.106
37.1
75.9
1973
51
39.5
19.6
.lttt
40.3
79
CO 1972..
51
43.7
18.2
.006
38.9
76.3
1971
&L
47.9
16.6
.CS6
IS. 7
70
1070
51
52.1
15.1
.077
30.9
6H. 6
1969
51
56.3
13.7
.064
- 25.2
49.4
1963
51
50.5
12.2
.049
18. S
36.2
Prf-1068..
51
77.5
10.8
,lJ0
51.2
100.4
31&3
670,3
. CO:^«(31SJ/S7DJ!)Xl-flO-.«.
Specification of scenario for problem tz-
ample J. The nationwide mil of vehicles by
age and average V£TT. aa given In AP-42. ap-
plies. An I/M program with a 30% stringency
factor was Implemented la calendar year
1980, and vehicles one year old or older wer*
tested by the end of calendstr year 1980. The
program Is annual and no mechanic training
program Is in effect. Since the emissions
characteristics of 1378 and later model year
cars are unknown, it will be assumed that
the Initial year emissions from these vehicles
will be the same as that determined for
1S75 model year vehicles by the Agency's
Emission Factor Program: namely, .87
HC and 14.7 gm./)cm. CO. Also. It
will be assumed that 1978 and later model
year vehicles deteriorate at the same rate
u 1375-77 models: namely, .17 gm/l£m./yr.
HC and 1.9S jm./!cm./jT. CO.
Problem 3. Determine the percent reduc-
tion in emissions. lor HC and CO in
calendar year 1990. and the resulting reduced
emission factors for BC and CO lor calendar
year 1990.
Solution. To calculate B», the method used
In the solutions to Problems 1 and 2 Applies.
The following tables detail the numerical
calculation at both numerator and denomi-
nator of B„ for HC and CO.
CO: Br-(2*.i;STCU)X 1.00-,3«.
Problem 2. Determine the percent reduc-
tion in emissions, Srr, for HC and CO in
C? 1977, assuming that the Inspections ire
annual and that an adequate mechanic
training program, is in effect.
Solution. The method used for Problem 1
applies. Only the bn,< numbers will differ to
reject the presence of an adequate program
of mechanic training. Hi* following table*
detail tha calculation of both numerator and
denominator of Bt for HC and CO:
Nn- Denom-
6n. i en. i mrr, i 7n. > mera- tnator
(percent) tor product
product
Nu-
Dtnom-
bm. i
JRW, (
>m. i
m«ra-
Wifctor
(p«r
tor
product
ctnt)
product
1090
0
0.9
22.6
0.081
0
1.37
1989
9
1.1
24.2
.110
.28
193
1035
• 16
1.2
215
.107
.46
2.89
1957
23
L4
2L1
.106
.72
113
1986
29
L6
19.6
.102
.93
3.20
19S5
34
A7
18.2
.098
LOt
197
HC 13*t_
39
18.8
.088
LOS
178
1983
42
10
15.1
.077
.98
132
1982
45
12
1X7
.001
.88
L 93
1981
4S
14
112
.049
.65
* L44
1980
45
14
10.8
.033
.38
.86
Prt-1980..
45
14
10.3
.087
L 01
128
ft. 34
28.58
HC: Bm-(SJV3.a) X1.00-
Nu-
Denom-
• t
bm. >
-------
PROPOSED RULES
• ' To calculate the rtdac*d emlMloa factors
lor HC and CO, the lallowicg formula can
b. uaed:
' 20
T"'
¦ TjLBIS 2.—Emtstion factort /or tighl-dvty,
fOKjiitit'panicrtd o«Jiiciai (auiomcbiles)
(iota allitude, non-Californic)
100
23 ih»,tPn.i
t-*»-12
The (otlowtog tables detail the calculation
cf th* numerator and denominator:
Nffljwrator P«wnrti-
P™1"" p££a
1990...— 0.9 25.5
-tf89—... 1-1 2<-2
WSS 1.2 22.5
19S7 L 4 SL1
1966... 1.6 19.6
19S3...... 1-7 18.2
HC196C. 1.9 14- <*
I9S3...... 2.0 IS-1
19*2..—.. 2.2 13.7
1981 i* 12.2
19S0 X4-10.S
,?re»l9S0.. 2.4 las-
a osi
107
.110
193
.107
180
. J00
113
,102
120
.094
197
,084
178
.077
132
, 004
\.$2
.049
L43
,jo
2.41
2.24
100
L4*
1.46
1. !€
.**
.60
.94
16.2*
CO: S.ta.
Table 1.—Es(tjnate<£ fraction of vehicles in
use nationwide ana average annual til'
omtien driven naLion.vri.de, by vehicle age
Fraction o<
i eludes talotocteri
-------
Appendix C
SHORT-TEST EMISSIONS STANDARDS AS RELATED
TO FEDERAL CONSTANT VOLUME SAMPLING TESTING
-------
Appendix C
SHORT-TEST EMISSIONS STANDARDS AS RELATED
TO FEDERAL CONSTANT VOLUME SAMPLING TESTING
The correlation attributes between short test programs and FTP tests for
noted gaseous emissions for model-year 1975 are presented in Figures C-l, C-2,
and C-3. In setting pass/fail limits in a mandatory inspection program using
modal testing, it is required to set concentration standards that relate in a
logical manner to the Federal Constant Volume Sampling (CVS) test procedure.
U.S. Environmental Protection Agency (EPA) report "Evaluation of Restora-
tive Maintenance on 1975 and 1976 Light-duty Vehicles in Detroit, Michigan"
presented emission test results for individual vehicles for test types noted
in Table C-l. This data is plo.tted in the graphs as noted above for idle
mode. The data, along with its statistical analysis, indicates a low level of
correlation. Superimposed on the graph is a Federal Test Procedure to short
test procedure regression relationship established by the EPA (Ref. 7).
Table C-2 presents correlation coefficient for short-test emission
measurement procedures on a California 1972 Idle Inspection Fleet Test Program.
Idle Test Correlation and Commission Errors
Until there is a sufficient data base that describes the operational
characteristics of emission control systems, it is not possible to determine
with certainty the adequacy of various emission test procedures in identifying
malfunctions of those systems. The relative importance of identifying various
types of malfunctions cannot be determined until operating experience with
substantial numbers of new and future emission control systems has been gained.
259
-------
70
90
so
to
Fig. C-l
CO Emissions
Idle Mode
2 3> CLE TEST CO ( PCT »
260
-------
o
X
u>
N.
O
Fig. C-2
HC Emissions
Idle Mode
2 J> CLE t AVBMGE HGH * LOW 9B) ) FFM HC
UJ
»
2
e>
X
O
z
Fig. C-3
N0x Emissions
Idle Mode
10
N.
CD
2 ^ OLE TEST NDX ( PPM )
261
-------
Table C-l. TEST TYPE
TEST
tM&irn
READINGS
TEST PROCEDURE CHARACTERISTICS
1975 FTP
GMS/Mile
Defined in sections 85.076-14 through 85.075.24
of Federal Register Vo>l. 37, No. 221
HWY FET
GMS/Mile
Defined driving cycle of 10.2 miles and 765
second duration
FED SCY
GMS/Mile
Driving cycle of 125 second duration and .7536
miles in length and 9 modes
NY/NJ
GMS/Mile
Driving cycle of 75 seconds duration and .2792
miles in length consisting of 7 mode
KEY MODE
Concentration
ppm/pct
3 Steady-state operating conditions high-speed,
low speed and idle plus presoak
TWO-SPEED
IDLE TEST
Concentration
ppm/pct
Nonloaded test having two speeds: idle and
2,250 rpm
FED THREE-
MODE
Concentration
ppm/pct
Similar to Key Mode with dynamometer loads
simulating the average power as required on the
FTP under NADA weight class
262
SfSTtMS CONTROL, NC.
ENVIRONMENTAL ENGINEERING OIV1SIOM
-------
Table C-2.
CORRELATION COEFFICIENTS FOR SHORT TEST EMISSION MEASUREMENT PROCEDURES
1972 FTP REGRESSION BEFORE SERVICE
CALIFORNIA IDLE
INSPECTION
FLEET DATA
Standard Error
of Estimate
Correlation Coefficient
Grams
Per
Mile
Test Procedure Emission Measurement
HC
CO
N0x'
HC
CO
NOx
Federal Short Cycle Mass
0.94
0.81
0.74
2.5
32
1.1
Seven Mode Cycle Mass
0.91
0.70
0.70
3.1
38
1.1
Key Mode (multiple regression) Mass
0.96
0.81
0.66
2.2
32
1.2
Steady State Modes (mult, regression) Mass
0.96
0.82
0.71
2.2
32
1.2
Idle Mode Mass
0.80
0.62
0.15
4.4
42
1.6
Seven Mode Cycle Volumetric
0.57
0.77
0.43
6.0
34
1.4
Key Mode (multiple regression) Volumetric
0.79
0.68
0.61
4.5
40
1.3
Steady State Modes (mult, regression) Volumetric
0.81
0.68
0.63
4.4
40
1.3
Idle Mode Volumetric
0.35
0.50
0.02
6.8
46
1.6
SiSS *¦
&jsrcMscotmtoi,Nc -
ENVIRONMENTAL ENGINEERING division
-------
However, some general conclusions can be drawn based upon the general character-
istics of various test procedures.
The Federal Certification Test Procedures (FTP) is considered the standard
for measuring vehicle emission because it is representative operation in urban
areas. The idle-mode emission test, as compared with the FTP, provides for
testing a limited number of operating conditions.
The potential shortcomings of the idle-mode test for emission testing is
its inability to diagnose malfunctions of exhaust gas recirculation (EGR)
systems which are currently used by most automobile manufacturers to ensure
compliance with the 1973 Federal NO^ emission standards. When the EGR valve
is functioning properly, there is no recirculation of the exhaust gas during
idle operation; therefore, the system provides no reduction of idle NO
x
emissions. A malfunction of the EGR system causing an increase in NO emission
x
during loaded operating modes would not result in a concurrent increase in
idle-mode emissions. The malfunction would, therefore, remain undetected by
an idle test measurement.
A loaded-emission test, on-the other hand, includes a wider range of
operating conditions and would be more generally useful in testing future
vehicles. However, all current short emission tests are hampered by their
inability to measure cold-start emissions, which is so important for vehicles
equipped with catalytic and thermal reactor emission control system.
The evaluation of alternative inspection procedures must also consider
their relationship to enforcing the warranty provisions set forth in Section 207
of the Clean Air Act. That section authorizes the EPA to establish regulations
requiring automobile manufacturers to warrant the emission control performance
of every new motor vehicle for the vehicle's useful life. To implement this
provision, Section 207 requires that there be available short—test procedures
which achieve adequate correlation with the FTP. While the definition of
adequate correlation is yet to be established, it is clear that those short
tests which achieve the highest degree of correlation will be most likely to
satisfy the requirements for adequate correlation. The correlation analyses
264
-------
have consistently shown that for current vehicles, the dynamic (loaded) tests,
as a general category, achieve significantly higher correlation with the FTP
than do the idle-mode tests.
States are not required to consider the feasibility of enforcing the
warranty provisions in the design of their transportation control plans.
However, any enforcement program which imposes a burden of responsibility upon
the private citizen, should also provide adequate protection for the vehicle
owner to ensure that the burden of noncompliance is only placed upon those who
are truly liable. Accordingly, the enforcement of the warranty provision may
directly affect the public acceptability of any enforced in-use vehicle inspec-
tion program.
The selection of an individual inspection test requires the development
of criteria for determining what degree of correlation is adequate to satisfy
the warranty provisions. The following analysis provides a qualitative means
of making such a determination.
For illustrative purposes, it is assumed that the points marked "a" in
Figure C-4 represent the Federal emission standard for all the vehicles in a
sample fleet. The points marked "b," "c," "d," and "e," represent hypothetical
cut points for a state inspection program. A higher cut point results in a
lower rejection rate and, thereby, reduces the fleet emission reduction poten-
tial of the program. Any vehicle which is above the inspection cut point, and
is to the left of point "a," is defined as an error of commission. These
vehicles are erroneously identified as excessive emitters. Any vehicle which
the inspection criteria and is to the right of point a is a valid
failure.
The feasibility of enforcing the warranty will be determined by the
frequency of commission errors among the vehicles which fail the short test.
The probability of a commission error can be reduced by raising the inspection
test failure criteria. At any cut point, a commission error is still defined
as any failed vehicle to the left of point "a." Therefore, a trade-off exists
between the feasibility of enforcing the warranty and the fleet emission
265
-------
12
u
C
-------
reduction achieved by the inspection strategy. The degree of correlation
between the two test procedures is a measure of the extent to which the short-
test failure criteria must be raised to reduce the errors of commission to an
acceptable level.
Table C-3 presents the results of applying this type of analysis for the
idle-mode test procedure. The rejection rate, the frequency of commission
errors, and the fleet emission reductions are shown for selected short test
cut points.
Table C-3. ERRORS OF COMMISSION FOR IDLE-MODE SHORT-TEST PROCEDURES
TEST TYPE
REJECTION
RATE %
FREQUENCY OF
COMMISSION ERRORS
% OF FAILED
VEHICLES
FLEET EMISSION REDUCTION
AFTER MAINTENANCE
(CO Emissions) %
Idle Mode Test
(Corr. Coef. = 0.375)
50
40
30
20
10
5
43
40
30
30
27
14
17
15
10
12
8
4
The results of this analysis are not intended to provide sufficient
information to determine the failure criteria which should be used in a state
program The test fleet used to demonstrate this analysis was composed of the
total model-year mix of the 1972 California vehicle population. The individual
failure criteria would have to be determined for each model-year such that the
upre reduced to an acceptable level. However, Table C-3 does
commission errors were
demonstrate the impact of the trade-off between commission errors and the
fleet emission reduction potential for idle-mode test.
267
-------
Appendix D
GENERAL DEFINITIONS
-------
Appendix D
GENERAL DEFINITIONS
The following definitions and abbreviations are those commonly used in
inspection and emissions testing procedures.
accuracy: The degree by which an instrument is able to determine the true
concentration of a pollutant in the exhaust gas sampled.
air contaminants: Any fumes, smoke, particulate matter, vapor gas, or any
combination, but excluding water vapor or stream condensate.
air-fuel ratio: The expression of the proportional mixture of air and gasoline
created by the carburetor.^ Usually expressed as a numerical relationship
such as 14:1, 13:1, etc.
ambient air: The surrounding or outside air.
calibration gases: A blend of HC and CO gases using nitrogen as a carrier gas.
carbon monoxide: A nonirritating, colorless, odorless gas at standard condi-
tions which has the molecular form of CO.
catalytic emission control system: Device to reduce automobile emissions by
converting CO and HC emissions to harmless carbon dioxide and water.
certificate of compliance: A document which is issued upon completion of the
inspection which records the results of the inspection and serves as proof
of said inspection for vehicle owner.
271
-------
certified mechanic: An individual licensed to install, repair and adjust motor
vehicle engine emissions-related components and pollution control devices
in order that the motor vehicle meet applicable emissions standards.
certified station: A private facility licensed to install, repair and adjust
motor vehicle engine emissions-related components and pollution control
devices in order that the motor vehicle meet applicable emissions standards.
chassis dynamometer: A machine equipped with two parallel rollers which support
the rear wheels of a motor vehicle. When positioned on the dynamometer
the vehicle may be "driven" to simulate the loadings the engine would
experience when the vehicle is operated on the road. A power absorption
unit is connected to the rollers to simulate the loading from the various
sources of fluid and mechanical friction present during road operation.
Weights can also be coupled to the rollers to simulate the inertial effects
of vehicle mass during acceleration and deceleration.
crankcase emissions: The products of combustion emitted into the ambient air
from portions of the engine crankcase ventilation or lubrication system.
degradation: The decreased effect of I/M on emission reduction due to normal
wear of engine system.
deterioration: A synonym for degradation indicating an increase in emission
levels due to wear.
drift: The amount of meter reading change over a period of time. Zero drift
refers to change of zero reading. Span drift refers to a change in reading
of a calibration point on the upper half of the scale. The calibration
point is established by reading a calibration gas of known concentration.
emission inspection program: An inspection and maintenance program in which
each vehicle is subjected at specified intervals to a test of its emissions
under specified conditions. The emission levels are compared with a
standard established for the vehicle class. If the emissions are higher
272
-------
than the standard, the vehicle is failed and must be adjusted or repaired to
bring its emissions into compliance with the standards.
engine family: The basic classification unit of a manufacturer's product line
used for the purpose of test fleet selection.
engine-system combination: An engine family-exhaust emission control system-
fuel evaporative emission control system combination.
exhaust gas analyzer: An instrument for sensing the amount of air contaminants
in the exhaust emissions of a motor vehicle.
exhaust emissions: The products of combustion emitted into the ambient air
from any opening downstream of the exhaust ports of a motor vehicle
engine.
fleet owner authorized stations: A permit issued to a qualified fleet owner
to perform vehicle emissions inspection limited to his fleet only.
fleet operator: The owner of a' fleet of a designated number of vehicles.
fuel system: Combination of fuel tank, feeder lines, fuel pump, and evaporative
control system.
gross vehicle weight: The manufacturer's gross weight rating for the individual
vehicle.
hang-up: HC which clings to the surface of the sampling and analyzer system
in contract with the gas sample stream which causes an erroneous indication
of HC in the measured value.
heavy-duty vehicle: Any motor vehicle designed for highway use which has a
gross vehicle weight of more than 8,500 pounds. A heavy-duty gasoline
powered vehicle is designated as HDG. A heavy-duty diesel-powered
vehicle is designated as HDD.
273
-------
hydrocarbons : A compound whose molecular composition consists of atoms of
hydrogen and carbon only.
idle test: An emission inspection program which measures the exhaust emission
from a motor vehicle operating at idle. (No motion of the rear wheels.)
A vehicle with an automatic transmission may be in drive gear with brakes
applied or in neutral gear.
independent contractor: Any person, business firm, partnership or corporation
with whom the state may enter into an agreement providing for the con-
struction, equipment, maintenance, personnel, management and operation of
official inspection stations.
inspection and maintenance program: A program to reduce emissions from in-use
vehicles through identifying vehicles that need emissions control-related
maintenance and requiring that maintenance be performed.
inspection station: A centralized facility for inspecting motor vehicles and
pollution control devices for compliance with applicable regulations.
inspector: An individual who inspects motor vehicles and pollution control
devices for compliance with applicable regulations.
instrument: The system which samples and determines the concentration of the
pollutant gas.
key-mode test: A loaded mode test in which exhaust emissions are measured at
high- and low-cruise speeds and at idle. The cruise speeds and dynamometer
power absorption settings vary with the weight class of the vehicle. The
dynamometer loading in the high-cruise range is higher than normal load
in order to more effectively expose malfunctions leading to high emissions.
light-duty vehicle (LDV): A motor vehicle designed for highway use of less
than 8,500 pounds gross vehicle weight. Further distinctions are some-
times made between light-duty automobiles and light-duty trucks such as
274
-------
pickup trucks. Light-duty gasoline-powered truck, category 1 (LDT^) is
a motor vehicle on a truck chassis, 0-6,000 pounds gross vehicle weight
(GVW). A light-duty gasoline-powered truck, category 2 (LDT ) is a motor
vehicle on a truck chassis, 6,000-8,500 pounds GVW.
loaded mode test: An emission inspection program which measures the exhaust
emissions from a motor vehicle operating under simulated road load on a
chassis dynamometer.
model year of vehicle: The^production period of new vehicle or new vehicle
engines designated by the calendar year in which such period ends.
motorcycle: A motor vehicle having a seat or saddle for use of the rider and
designed to travel on not more than three wheels in contact with the
ground, but excluding a tractor.
motor vehicle: Any self-propelled vehicle which is designed primarily for
travel on public right-of-ways and which is used to transport persons and
property.
oxides of nitrogen: Sum of nitric oxide and nitrogen dioxide contained in a
gas sample as if the nitric oxide were in the form of nitrogen dioxide.
positive crankcase ventilation: A system designed to return blowby gases from
the crankcase of the engine to the intake manifold so that the gases are
burned in the engine. Blowby gas is unburned fuel/air mixture which leaks
past the piston rings into the crankcase during the compression and ignition
cycles of the engine. Without positive crankcase ventilation these gases,
which are rich in hydrocarbons, escape to the atmosphere.
prescribed inspection procedure: Approved procedure for identifying vehicles
that need emissions control-related maintenance.
quality: The composite product characteristics of engineering and manufacturing
that determine the degree to which the product in use meets customer
expectations.
275
-------
quality assurance: A system for integrating the quality functions of various
organizational groups to assure production and service at the most economical
levels satisfying quality requirements of test facility or contractor.
registered owner: An individual, firm, corporation or association whose name
appears in the files of the motor vehicle registration division of the
Department of Motor Vehicles as the person to whom the vehicle is registered.
repeatability: The instrument's capability to provide the same value for
successive measures of the same sample.
response time: The period of time required by an instrument to provide mean-
ingful results after a step change in gas concentration level initiated
at the tail pipe sample probe.
smoke: Small gasborne and airborne particles, exclusive of water vapor,
arising from a process of combustion in sufficient number to be observable.
stringency factor: The percentage of total vehicles tested in an inspection/
maintenance program in a given time period that fail inspection and are
required to have maintenance performed.
system or device: Equipment designed for installation on a motor vehicle for
the purpose of reducing pollutants emitted from the vehicle, or a engine
modification causing pollutant reduction.
tampering: The illegal alteration, modification, or disconnection of emission
control device or adjustments or manufacturer tuning specifications on
motor vehicles for the purpose of controlling vehicle emissions.
vehicle dealer: An individual, firm, corporation or association who is licensed
to sell motor vehicles.
vehicle emissions standard: A specific emission limit allowed for a class of
vehicles. The standard is normally expressed in terms of maximum allow-
able concentrations of pollutants (e.g., parts per million). However, a
standard could also be expressed in terms of mass emissions per unit of
time or distance traveled (e.g., grams per mile)
276
-------
Appendix E
COST AND FEE CALCULATIONS
-------
Appendix E
COST AND FEE CALCULATIONS
This appendix provides the detailed method used in calculating annual
costs and fees.
Analysis of economic activities requires comparison of sums of money
(cash flows) at various points in time. This means we need methods which will
enable us to take into account the time value of money (interest).
The values of sums of money at different points in time depend upon the
interest rate and the time spans. A sum of money today is not equivalent to
the same sum ten years later unless interest were assumed at the unrealistic
rate of zero.
The present value (P) of a future sum (S) that yields n years from now
is calculated as follows:
where i is the interest rate.
Another useful concept is the annualized worth of a present sum. For
example, if a borrower applies loan of P dollars from a bank, the interest is i.
E.l
TIME VALUE OF MONEY
P = S x
279
-------
What is the yearly uniform payment that he has to pay back in n years? This
type of question can be answered with the following formula:
R = P
i(1+i)
_ (1+i)n-l -
where:
R
is
the
uniform payment per year
P
is
the
present sum
n
is
the
number of years
i
is
the
interest.
E.2 CONSUMER FEE CALCULATIONS
The consumer fee, is calculated by dividing total uniform annualized
cost by the average number of vehicles inspected per year. This fee is designed
to defray all of the costs, except certain state overhead expenses incurred on
the implementation of an I/M program.
E.3 INFLATION EFFECT
The above mentioned fee is in constant dollars. To consider the inflation
effect, an adjustment factor must be applied.
Let the projected annual inflation rate be i. The consumer fee in constant
dollars is F . Let the uniform fee in actual dollar be F . The relationship
between F and F can be derived as follows:
a c
V-i
(F + F (1+i) + F (1+i)2 + + F (l+i)n_1) (1+l)
F = ^
a n
(1+i)n -1 n . Y-l
= F x : (l+i.)
c n x l
280
-------
where is the number of years to the starting year of I/M program, and n is
the program period. The term
(1+i)n -1 , V^i
(l+i)
n x i
is the adjustment factor for inflation.
For example, if an I/M program starts in 1982 and continues for 10 years,
the adjustment factor to 1978 constant dollars with 7 percent inflation rate is
calculated as follows:
4 10
(1+0.07) x ((1+0.007) -1/10 x 0.07 = 1.81
281
-------
Appendix F
TAMPERING AS 'A VEHICLE EMISSIONS PROBLEM
-------
Appendix F
TAMPERING AS A VEHICLE EMISSIONS PROBLEM
The possible areas associated with tampering are:
o Carburetor adjustments to improve driveability at the expense of
emissions
o Installation of replacement of after market parts which are not to
manufacturer's specifications
o Converter catalyst
o Timing and advance
o Exhaust gas recirculation (EGR) interruption
Of the items listed the EGR tampering is the major problem and will be
reviewed as to its effect on emissions.
Exhaust Gas Recirculation (EGR) is used on vehicles to reduce oxides of
nitrogen (NO ). In the heat of combustion (3,500-4,000°F) nitrogen combines
x
with oxygen forming oxides of nitrogen. Combustion temperatures must be
lowered to reduce formation NO • The EGR system consists of a valve, solenoid
X
control, back pressure transducer, temperature control, hoses, clamps, and
wiring. A typical vehicle emissions control system with EGR is presented in
Figure F-l.
The heart of the EGR system is an EGR valve. The valve passes small
amounts of exhaust gas into the intake manifold below the carburetor. Very
285
-------
•WIRING TO SENSORS
t INJECTORS
DISTRIBUTOR
VACUUM SOLENOID
VALVE
ECR VACUUM
SOLENOID VALVE
DISTRIBUTOR
VAC.DELAY
VALVE
•CATALYTIC CONVERTER CTHREE-WAY)
-MAP SERSOR
¦ECONOMY INDICATOR VACUUM SWITCH
DISTRIBUTOR
TO TRANS.
"\
throttle body
iXHAUST BACKPRESSURE
TRANSDUCER
EGR VALVE
¦TO FUEL TANK
DISTRIBUTOR TVS
fuel RAIL
PRESSURE
REGULATOR
¦CAN!STER
:anister purge
Figure F-l. TYPICAL EMISSION CONTROL SYSTEMS SHOWING EGR SYSTEM
«=**=»=» PORTED VACUUM
MANIFOLD VACU
286
-------
little NO^ is formed at idle or light engine loads but formation increases
rapidly during acceleration. As the throttle opens, the EGR valve opens,
recirculating exhaust gases to reduce NO^. EGR valves are carefully matched
to each type of engine. Use of the wrong valve may cause driveability and
performance problems or increased emissions. The valve air flow varies with
temperature, vacuum signal, and atmospheric pressure.
Description of Tampering
o System hoses missing
o Steel ball in vacuum hose
o Top of EGR valve is dimpled reducing stroke thereby the vacuum
status
o Drilled holes for air access
o Coolant thermostat switch alteration
o Vacuum amplifier modification
o Vacuum line notched or cut
The existent of tampering of EGR valve by dealers in a California study
was very extensive. The dealers inspected were in the normal complaint and
inspection routine of the field investigation section of the ARB, El Monte
Vehicle Branch during 1977. In the 400 in-use vehicle surveillance program by
California ARB, tampering occurs as a result of driveability and was in the 18
to 20 percent range.
Vehicle Emissions Effects
The EGR malfunction with a 20 percent failure rate results in approximately
49 percent increase in emissions (reference Table F-l).
287
-------
Table F-l. TYPICAL EMISSIONS BEFORE
AND AFTER TAMPERING REPAIR
TEST TYPE
HC
CO
—x
COg
REMARK
Std I
3.2
39.0
2.0
EMISSIONS BEFORE
REPAIR
CVS-75
(gm/mi)
2.311
19.20
6.78
438.6
18.7 mpg
CVS-72
Recalculated
2.66
26.44
6.43
460.12
HWY Cycle
(gm/mi)
1.129
5.14
8.93
393.8
21.9 mpg
Loaded Mode
69.0
95.0
wo/A 121.0
0.17
0.12
1.55
3106.0
2371.0
136.0
13.65
13.37
13.37
H
L
I
EMISSIONS AFTER
REPAIR
CVS-75
(gm/mi)
2.554
21.49
1.64
571.7
14.5
(CVS-75 12
3.36
28.03
1.62
588.84
HWY Cycle
(gm/mi)
1.073
8.25
1.19
431.0
19.8 mpg
Loaded Mode
wo/A
43.0
86.0
86.0
0.25
0.15
0.70
832.0
657.0
141.0
14.68
14.33
14.00
H
L
I
% Increase
Because of
Tampering
For 20%
Tampering
Emissions
with 20% tempering
Emissions
per certification
Emissions per Vehicle certification
(.80) x 2 +(.20) x 6.78 - (l.QQ) x 2
1.00 x 2
1.6 + 1.356 - 2 = .956 = 49%
2 2
288
-------
Appendix G
COMPILATION OF AIR POLLUTANT EMISSION FACTORS
-------
References for Section 3.1.3
1. Exhaust Emission Standards and Test Procedures. Federal Register. Part II. J6(P8V . ,
l9?l - >¦ '-oj-.-i.fi64, July 2,
2. Control of Air Pollution from Light Duty Diesel Motor Vehicles. Federal Register Part II
20914-20923, October 4, 1972. "
3. Springer, K. J. Emissions from a Gasoline - and Diesel-Powered Mercedes 220 Passenger Car. Southwest
Research Institute. San Antonio, Texas. Prepared for the Environmental Protection Agency, Research Trianele
Park, N.C., under Contract Number CPA 70-44. June 1971.
4. Ashby, H. A. Final Report: Exhaust Emissions from a Mercedes-Benz Diesel Sedan. Environmental Protection
Agency. Ann Arbor. Mich. July 1972.
5. Test Results from the Last 9 Months - MB220D. Mercedes-Benz of North America. Fort Lee, New Jersev
Report El 0472. March 1972.
6. Hare. C. T. and K. J. Springer. Evaluation of the Federal Clean Car Incentive Program Vehicle Test Plan.
Southwest Research Institute. San Antonio, Texas. Prepared for Weiner Associates. Incorporated..
Cockeysville, Md October 1971.
7. Exhaust Emissions From Three Diesel-Powered Passenger Cars. Environmental Protection Agency, Ann Arbor.
Mich. March 1973. (unpublished report.)
291
-------
Appendix H
HEAVY-DUTY, DIESEL-POWERED VEHICLES
-------
Appendix G a
COMPILATION OF AIR POLLUTANT EMISSION FACTOKS
3.1.3 Light-Duty, Diesel-Powered Vehicles
j.1.3.1 General - In comparison with the conventional, "uncontrolled," gasoline-powered, spark-ignited,
automotive engine, the uncontrolled diesel automotive engine is a low pollution powerplaiu. In its uncontrolled
form, the diesel engine emits (in grams per mile) considerably less carbon monoxide and hydrocarbons and
somewhat less nitrogen oxides than a comparable uncontrolled gasoline engine. A relatively small number of
light-duty diesels are in use in the United States.
3.1.3.2 Emissions - Carbon monoxide, hydrocarbons, and nitrogen oxides emission factors for the light-duty,
diesel-powered vehicle are shown in Table 3.1.3-1. These factors are based on tests of several Mercedes 220D
automobiles using a slightly modified version of the Federal light-duty vehicle test procedure.1'" Available
automotive diesel test data are limited to these results. No data are available on emissions versus average speed.
Emissions from light-duty diesel vehicles during a calendar year(n) and for a pollutant (p) can be approximately
calculated using: ..
n
enp = S Cjpn mjn (3.1.2-1)
i=n-12
where: enp = Composite emission factor in grams per vehicle mile for calendar year (n) and pollutant (p)
c- n « The 1975 Federal test procedure emission rate for pollutant (p) in grams/mile for the ith
model year at calendar year fn) (Table 3.1.3-1)
min ~ Tte fr3Ction tota^ light-duty diesel vehicle miles driven by the i^1 model year diesel
light-duty vehicles
Details of this calculation technique are discussed in section 3.1
The emission factors in Table 3.1.3-1 for particulates and sulfur oxides were developed using an average sulfur
content fuel in the case of sulfur oxides and the Dow Measuring Procedure on the 1975 Federal test cycle for
particulate.1,6
Table 3.1.3-1. EMISSION FACTORS FOR UGHT-OUTY
OlESEL-POWERED VEHICLES
EMISSION FACTOR RATING: B
Emission factors.
Pollutant
g/mi
g/km
Carbon monoxide3
Exhaust hydrocarbons
Nitrogen oxides3-'3
(NOx as N02)
Particulate13
Sulfur oxidesc
1.7
0.46
1.6
0.73
0.54
1.1
0.29
0.99
0.45
0.34
5 and 7.
^Reference 4.
cCaiculaced using the fuel consumotion rate reported in Reference 7 and
3ssurr»ng rhe use of a diesei fueJ containing 0.20 percent suifur.
Internal Combustion Engine Sources
Reprinted form "Compilation of Air Pollutant Emission Factors," U.S. Environmental
Protection Agency, February 1976.
295
-------
Appendix H a
HEAVY-DUTY, DIESEL-POWERED VEHICLES
3.1.5 Heavy-Duty, Diesel-Powered Vehicles
3.1.5.1 General1,2 — On the highway, heavy-duty diesel engines are primarily used in trucks and buses. Diesel
engines in any application demonstrate operating principles that are significantly different from those of the
gasoline engine.
3.1.5.2 Emissions — Diesel trucks and buses emit pollutants from the same sources as gasoline-powered vehicles:
exhaust, crankcase blow-by, and fuel evaporation. Blow-by is practically eliminated in the diesel, however,
because only air is in the cylinder during the compression stroke. The low volatility of diesel fuel aiong with the
use of closed injection systems essentially eliminates evaporation losses in diesel systems.
Exhaust emissions from diesel engines have the same general characteristics of auto exhausts. Concentrations
of some of the pollutants, however, may vary considerably. Emissions of sulfur dioxide are a direct function of
the fuel composition. Thus, because of the higher average sulfur content of diesei fuel (0.20 percent S) as
compared with gasoline (0.035 percent S), sulfur dioxide emissions are relatively higher from diesel exhausts.3'4
Because diesel engines allow more complete combustion and use less volatile fuels than spark-ignited engines,
their hydrocarbon and carbon monoxide emissions are relatively low. Because hydrocarbons in diesel exhaust
represent largely unbumed diesel fuel, their emissions are related to the volume of fuel sprayed into the
combustion chamber. Both the high temperature and the large excesses of oxygen involved in diesel combustion
are conducive to high nitrogen oxide emission, however.6
Particulates from diesel exhaust are in two major forms - black smoke and white smoke. White smoke is
emitted when the fuel droplets are kept cool in an environment abundant in oxygen (cold starts). Black smoke is
emitted when the fuel droplets are subjected to high temperatures in an environment lacking in oxygen (road
conditions).
Emissions from heavy-duty diesel vehicles during a calendar year (n) and for a pollutant (p) can be
approximately calculated using:
enps ~ 2 cipnvips (3.1.5-1)
i*n-12
where: enpS = Composite emission factor in g/mi (g/km) for calendar year (n), pollutant (p), and average
speed (s)
cipn = "^e emission rate in g/mi (g/km) for the i^1 model year vehicles in calendar year (n) over a
transient urban driving schedule with an average speed of approximately' 18 mi/hr (29
km/hr)
vips = "^e speed correction factor for the i^1 model year heavy-duty diesel vehicles for pollutant
(p) and average speed (s)
Values for cjpn are given in Table 3.1.5*1. These emission factors are based on tests of vehicles on-the-road
over the San Antonio Road Route (SARR). The SARR, located in San Antonio, Texas, is 7.24 miles long and
includes freeway, arterial, and local/collector highway segments.7 A constant volume sampler is carried on board
12/75 Internal Combustion Engine Sources 3.1.5-1
aReprinted from "Compilation of Air Pollutant Emission Factors," U.S. Environmental
Protection Agency, February 1976.
296
-------
each test vehicle for collection of a proportional part of the vehicle's exhaust. This sample is later analyzed to
yield mass emission rates. Because the SARR is an actual road route, the average speed varies depending on traffic
conditions at the time of the test. The average speed, however, tends to be around 18 mi/'hr (29 km/hr), with
about 20 percent of the time spent at idle. The test procedure emission factor is composed entirely of warmed-up
vehicle operation. Based on a preliminary analysis of vehicle operation data, heavy-duty vehicles operate primarily
(about 95 percent) in a warmed-up condition.
Table 3.1.5-1. EMISSION FACTORS FOR HEAVY-DUTY, DIESEL-POWERED VEHICLES
(ALL PRE-1973 MODEL YEARS) FOR CALENDAR YEAR 1972
EMISSION FACTOR RATING: B
Truck emissions3
City bus emissions'3
Pollutant
g/mi
g/km
g/mi
g/km
Particulate11
1.3
0.81
1.3
0.81
Sulfur oxides0'^
2.8
1.7
2.8
1.7
(SOx as S02)
17.8
Carbon monoxide
28.7
21.3
13.2
Hydrocarbons
^4.5
2.9
4.0
2.5
Nitrogen oxides
20.9
13.0
21.5
13.4
(NOx as N02)
0.2
0.3
Aldehydes0
0.3
0.2
(as HCHO)
Organic acids0
0.3
0.2
0.3
0.2
aTruck emissions are based on over-the-road sampling of diesel trucks by Reference 7. Sampling took Dlace on the San Antonio
(Texas) Road Route (SARR), which is 7.24 miles 111.7 kilometers) long and includes freeway, arterial, and local/collector high-
way segments. Vehicles average about 18 mi/hr 129 km/hr) over this road route.
bBus emission factors are also based on the SARR. 13-Mode emission data from Reference 6 were converted to SARR values using
cycle-to-cycle conversion factors from Reference 8.
cReference 6. Tire wear particulate not included in above particulate emission factors. See tire wear particulate, heavy-duty gaso-
line section.
dData baiwrl on assumed fuel sulfur content of 0.20 percent. A fuel economy of 4.S mi/gal (2.0 km/liter) was used from Reference
9.
The speed correction factor, vjps, can be computed using data in Table 3.1.5-2. Table 3.1.5-2 gives heavy-duty
diesel HC, CO, and NOx emission factors in grams per minute for the idle mode, an urban transient mode with
average speed of 18 mi/hr (29 km/hr), and an over-the-road mode with an average speed of approximately 60
mi/hr (97 km/hr). For average speeds less than 18 mi/hr (29 km/hr), the correction factor is:
Urban + (y • 1) Idle
V = TT (3.1.5-2)
Urban
where: s is the average speed of interest (in mi/hr), and the urban and idle values (in g/min) are obtained from
Table 3.1.5-2. For average speeds above 18 mi/hr (29 km/hr), the correction factor is:
18
42S [(60-S) Urban + (S-l8) Over the Road]
v. _ __ _______(3 _ J .5-3)
H Urban
Where: S is the average speed (in mi/hr) of interest. Urban and over-the-road values (in g/min) are obtained from
Table 3.1.5-2. Emission factors for heavy-duty diesel vehicles assume all operation to be under warmed-up vehicle
conditions. Temperature correction factors, therefore, are not included because ambient temperature has minimal
effects on warmed-up operation.
EMISSION FACTORS 12/7 5
297
-------
Table 3.1.5-2. EMISSION FACTORS FOR HEAVY-DUTY DIESEL VEHICLES
UNDER DIFFERENT OPERATING CONDITIONS
EMISSION FACTOR RATING: B
Emission factors? g/min
Pollutant
Idle
Urban [18 mi/hr (29 km/hrj]
Over-the-road
[60 mi/hr (97 km/hr]
Carbon monoxide
0.64
8.61
5.40
Hydrocarbons
0.32
1.38
2.25
Nitrogen oxides
1.03
6.27
28.3
(NOxasN02)
a Reference 7. Computed f
om data contained in the reference.
References for Section 3.1.5
1. The Automobile and Air Pollution: A Program for Progress. Part II. U.S. Department of Commerce,
Washington, D.C. December 1967. p. 34.
2. Control Techniques for Carbon Monoxide, Nitrogen Oxides, and Hydrocarbons from Mobile Sources. U.S.
DHEW, PHS, EHS, National Air Pollution Control Administration. Washington, D.C. Publication Number
AP-66. March 1970. p. 2-9 through 2-11.
3. McConnei, G. and H. E. Howels. Diesel Fuel Properties and Exhaust Gas-Distant Relations? Society of
Automotive Engineers. New York, N.Y. Publication Number 670091. January 1967.
4. Motor Gasolines. Summer 1969. Mineral Industry Surveys. U.S. Department of the Interior. Bureau of Mines.
Washington, D.C. Petroleum Products Survey Number 63.1970. p. 5.
5. Hum, R. W. The Diesel Fuel Involvement in Air Pollution. (Presented at the National Fuels and Lubricants
Meeting, New York, N.Y.September 17-18, 1969).
6. Young, T. C. Unpublished emission factor data on diesel engines. Engine Manufacturers Association Emission
Standards Committee, Chicago, 111. October 16, 1974.
7. Ingalls, M. N. and K. J. Springer. Mass Emissions from Diesel Trucks Operated over a Road Course. Southwest
Research Institute, San Antonio, Texas. Prepared for Environmental Protection Agency, Ann Arbor, Mich,
under Contract No. 68-01-2113. Publication No. EPA-460/3-74-017. August 1974.
8. Heavy-Duty Vehicle Interim Standards Position Paper. Environmental Protection Agency, Emission Control
Technology Division, Ann Arbor, Mich. January 1975.
9. Truck and Bus Fuel Economy. U.S. Department of Transportation, Cambridge, Mass. and Environmental
Protection Agency, Ann Arbor, Mich. Report No. 7 of seven panel reports. January 10, 1975.
12/75
Internal Combustion Engine Sources
298
3.1.5-3
-------
no ^ „ TECHNICAL REPORT DATA
t I A IOtI *7-* / I'lSdA (Please read Instructions on the reverse before completing)
1. REPORT NO. f 2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Motor Vehicle Inspection/Maintenance
for the State of South Carolina
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Systems Control, Inc.
Environmental Engineering Division
421 East Cerritos Avenue
Anaheim, California 92805
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-2536
12. SPONSORING AGENCY NAME AND ADORESS
Air Programs Branch
Environmental Protection Agency, Region IV
345 Courtland Street
Atlanta, Georgia 30308
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This report presents an analysis of alternative motor vehicle basic inspection
and maintenance programs in terms of related costs and benefits for the State of
South Carolina with specific information covering Lexington, Richland, Charleston,
and Berkley Counties. The study methodology used is described and includes
collecting data, determining criteria for selecting alternative program configuration,
screening program option and evaluating alternative configuration selected through
the screening process. Program alternatives were evaluated in terms of emission
reduction attainable, geographic coverage, effective motor vehicle population,
consumer protection, quality assurance, costs and financial feasiblity.
KEY WORDS AND DC
1CUMENT ANALYSIS
a descriptors
b-IOENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Group
Automobile engine exhaust
Exhaust detection
Exhaust emission
Inspection/Maintenance
Mobile source emission
control Inspection/
Maintenance
18. DISTRIBUTION STATEMENT
Unlimited Distribution
Unclassified
21. NO. OF PAGES
299
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
A 1/0 a 77^ PREVIOUS EDITION IS OBSOLETE
EPA Form 2220-1 (R«v. 4-77) previous
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