1. COMMENT: The commentor indicated that he is opposed to the extension of the new

vehicle inspection exemption from four (4) ye ars to five (5) ye ars but willing to work with the Motor Vehicle Commission (MVC) on a smooth transition and further changes that will benefit the State budget , the public and small businesses. The commentor believes that if the new vehicle inspection exemption period is extended, the time period wh en the motorist will ignore an illuminated Check Engine light will be extended from 4 to 5 y ears, polluting the air for an additional y ear. RESPONSE: The Department evaluated the emission reduction impacts of the proposed extension of the new vehicle inspection exemption period using the protocol s et forth in the USEPA’s fin al rule on I/M requirements . The USEPA protocol requires a demonstration, using the most current version of USEPA’s mobile source emission model, that the equivalency of the emission levels achieved by the State’s proposed enhanced I/M program design be compared to those of the performance standard

. Using this protocol, the results of the model indicate that there is no difference between emission factors for New Jersey ’s existing and proposed enhanced I/M programs for ozone precursors (VOCs and NOx). For these pollutants the magnitude of the increase in emissions due to the increased new vehicle exemption period from 4 y ears to 5 y ears is completely

offset by the reduction in emissions due to the increased effectiveness of New Jersey ’s Private Inspection Facilit ies ( PI Fs )

. The new enhanced I/M program design results in an insignificantly small increase in the predicted carbon monoxide emission factor relative to the existing enhanced I/M program. The increase is well below the USEPA margin of error of +/

- 0.02 grams per mile ( gpm )

. When stated to 4 significant figures, the carbon monoxide emission factors are the same. This demonstrates that the proposed changes to the enhanced I/M program do not compromise the State’s efforts to meet and/or maintain National Ambient Air Quality Standards (NAAQSs) for ozone or carbon mono xide. Also, the State's new enhanced I/M program meets the USEPA low enhanced performance standard. The Department appreciates the commentor’s willingness to work with the State on making a smooth transition into the new I/M program. The Department is also committed to working with the PI Fs, the MVC and other State agencies to ensure that changes to the inspection program continue to protect the health of New Jersey ’s citizens and its enviro nment.
2. COMMENT: The commentor supports upgrading the Private Inspection Facilit y (P IF) inspection effectiveness. However, he notes that PIFs should receive 100% equivalency , and not limit it to 96% as proposed in the SIP revision

. The basis for the c ommentor’s claim is that it is in the best interest of PIF inspectors to identify and point out vehicle defects to their customers.
RESPONSE: The Dep artment commissioned a study to re evaluate the level of PIF effectiveness. The study arrive d at a factor of 96% PIF inspection equivalency foremissions testing

. The study compared C entralized Inspection F acility (CIF) and PIF inspections, assigning a default of 100% credit to CIF inspections. Among the factors examined, the study

looked at emission inspecti on failure rates and suspec ted incorrect emission testing rates for both on - board diagnostics ( OBD ) and tailpipe tests. The study ’s findings support the commentor ’s assertions that the PI F OBD tests should receive 100% credit. Results from tailpipe testing , however , are less conclusive and the Department agrees with the study ’s conclusions that it is prudent to retain the previous estimate of 80% effectiveness . The overall 96% PI F credit results from a weighted blending of 100% PI F credit for OBD and 80% PI F credit for tailpipe tests. Since an increasing percentage of tests are now OBD and not tailpipe, the OBD effectiveness dominates the weighting.
3. COMMENT: The commentor fee ls that the use of OBD effectiveness in supporting lower rates of in

- use deterioration in emissions performance may be flawed. The commentor further contends that motorists do not alway s respond to the OBD m alfunction light and may refuse needed emission repairs if their vehicle is not exhibiting driveability

issues and is not due f

or an I/M test

. The commento r goes on to state that the problem of ignoring needed repairs may have become even worse in recent years as a result of economic concerns reducing money available to motorists for repairs. The commentor believes that the State is missing this e ffect but has no way of calculating it.
RESPONSE: The rate of motorist response to an illuminated Check Engine light in between inspection cycles (off

- cycle) , is a basic function built into the USEPA emission factor model . The Departme nt used the most current version of the model t o estimate the emissions impact of the proposed changes to the I/M program. The USEPA will make changes to the model if key assumptions, such as the motorist’s response rate to an illuminated MIL change over time.

4. COMMENT: The commento r stated that, although aware that the hearing was not addressing safet y - related inspection issues, the same issue regarding lack of motorist response to a Check Engine light applies to safet y - related defects. T he comm enter stated that his association members continue to document instances where motorists bring their cars in for maintenance and are advised of serious safet y issues, and now, without a safet y - inspection program and the need to have the safet y - related item corrected in order to pass inspection, they

are more frequently ignored by the motorist.
RESPONSE: L egislation signed into law on June 28, 2010 , directed the Motor Vehicle Commission to end mechanical inspections on August 1, 2010 for non

- commercial veh icles. The commento r is correct that the NJDEP’s SIP hearing covered only the emissions

- test related aspects of the I/M program and did not address the mechanical inspection program. A s such, comments on the mechanical inspection program will not be addr essed in this document. However, the Department has forwarded the transcripts from the SIP hearing to the MVC for their information.