Location: Nevada

Type of Program: Idle test by licensed service stations, garages and
auto dealers, includes check and adjustment of primary
vehicle specifications.

Sites: Approximately 120 to 125 licensed private stations located in
Clark County, Nevada.

Chronology: Pilot testing and inspection program initiated July 1974
for change of ownership vehicles in Clark County. Annual
inspection program scheduled for July 1, 1975, postponed.
State Environmental Commission directed to conduct a
thorough study of a compulsory annual I/M program. Nevada
Assembly Bill 464 effective July 1, 1977. Mandatory I/M
in all counties with population greater than 100,000 to be
phased in by July 1, 1979.

Geographic Coverage: Presently Clark County only, light-duty vehicle
population about 200,000. Annual Inspection and
Maintenance to be established in both Clark and
Washoe Counties by July 1979.

Adminstering Agencies: Department of Motor Vehicles
Department of Human Resources

Staff Contacts: E. J. Silva, Vehicle Compliance and Enforcement Section,
D. M. V. (702) 885-5396.

Capital Costs: Not reported. D. M. V. outfitted with exhaust analyzer,
calibration gases and pick-up truck.

Operating Costs: Recovered from fees - $2 - Certificate of Compliance fee
$25 - Annual station license fee.

Cost to Motorists: Inspection fee equal to sum of $2 certificate fee
plus labor charges. Total fee ranges from $8.50
to 17.00 due to variations in prevailing shop labor
rates. Stations permitted to set own fee with D.M.V.
approval.

Standards: CO and HC standards for three model-year groups.

Enforcement: Vehicles cannot be registered without Certificate of
Compliance.

Instrumentation: Nevada list of approved exhaust gas analyzers.

Data Collection: Vehicle description, motor vehicle specification settings,
and CO and HC tailpipe concentrations.

55


The idle mode test is the test 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
jtest at the normal idle speed is taken at the manufacturers’ recommended idle,
|measured in revolutions per minute (rpm), and then the engine speed is in-
creased to 2,250 (+10 percent) rpm for the high idle speed test. The standards
must be at both levels.

The loaded mode test is the test of the exhaust emissions with the vehicle
in a forward drive gear and operating at simulated driving conditions. Pollu-
tants are measured at various test conditions as specified by a testing pro-
cedure. Two types of testing procedures exist: steady state and transient.
The steady state loaded mode test is a test of emissions at high cruise, low
cruise, and idle mode operating states. A chassis dynanometer loads the
vehicle to simulate these driving conditions. Both the Clayton Key mode and
the Federal Three mode are acceptable steady state tests. The specifications
for each test aggregate all light-duty vehicles by weight classes. The actual
performance of the test depends upon the speed and load factors specified for
each testing state for each weight class. Emissions are measured by the volu-
metric procedure; i.e., by a standard exhaust emission analyzer. The vehicle
is operated in each mode until the emissions stabilize.

The transient loaded mode test collects a composite emission sample from
a specified driving schedule. The composite sample is collected into a Con-
stant Volume Sample (CVS) unit for further analysis to determine pollutant
concentration. Again, a chassis dynamometer loads the vehicle to simulate the
desired driving schedule. However, for this test, the dynamometer must be
capable of performing at variable inertia weights and road load settings. The
driving schedule for the transient test simulates a portion of an urban driv-
ing cycle. Two acceptable cycles are the Composite New Jersey/New York test
and the Federal Short Cycle test. The Federal Short Cycle is a 9-mode CVS test
of 125 second duration while the New Jersey/New York Composite test is a
6-mode CVS test requiring 75 seconds as specified below:

New Jersey/New York composite test

Time in mode,

Mode seconds

Idle 22
0 to 30 mph acceleration 15
30 mph cruise 15
30 to 10 mph deceleration 12
10 mph cruise 7
10 to 0 mph deceleration 4

75

21


Prepared for

U.S. ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C.

Contract No. 68-01-4458

EPA Project Officer
Gary C. Hawthorn

February 1978

INFORMATION DOCUMENTS ON
AUTOMOBILE EMISSIONS
INSPECTION AND MAINTENANCE
PROGRAMS

Final Report

by

Benjamin F. Kincannon

Alan H. Castaline

GCA-TR-77-14-G(a)


"9

6. Arizona--Loaded (1976)

Hi-cruise Lo-cruise Idle

Engine Model Curb No. of

type year weight cycles HC co HC co HC co
4-stroke All 2000 All 700 ppm 8.6% - - 1,050 ppm 7.5%
4~stroke pre-68 > 2000 4 or less 1,000 5.0 1,000 ppm 6.0% 1,300 9.5
4-stroke pre-68 > 2000 5 or more 700 4.25 700 5.25 950 7.75
4-stroke 68-71 > 2000 4 or less 450 3.75 450 4.25 500 6.0
4-stroke 68-71 > 2000 5 or more 380 3.0 380 3.5 450 5.5
4-stroke 72-74 > 2000 4 or less 380 3.0 380 3.5 450 5.5
4-stroke 72-74 > 2000 5 or more 300 2.5 300 3.0 350 4.0
4-stroke 75+ > 2000 All 100 0.9 120 1.0 150 1.5
2-stroke All All All 23,000 m» 8.0 23,000 6.0
Diesel All All All ( -- 20% opacity --)

Arizona--Idle(1977) (diagnostic evaluation conducted at 1976 loaded mode standards compliance
required at 1977 idle standards only.)

Idle

Engine Model Curb No. of

type year weight cycles HC co
4-stroke All MC All 2000 ppm 9.0%
4-stroke pre-1968 > 2000 4 or less 2000 9.5
4-stroke pre-1968 > 2000 5 or more 1500 9.5
4-stroke 68-71 > 2000 4 or less 850 8.0
4-stroke 68-71 > 2000 5 or more 750 8.0
4-stroke 72-74 > 2000 4 or less 450 7.2
4-stroke 72-74 > 2000 5 or more 400 7.0
4-stroke 75+ < 6000 All 250 3.3
4-stroke 75+ > 6000 All 400 7.0
2-stroke All All All 18,000 6.0


(2) Hydrocarbon idle emission values not to be exceeded:

Base
standard

No HC check

1600 ppm

1300 ppm

800 ppm
600 ppm
500 ppm
400 ppm
300 ppm
200 ppm

125 ppm

Enforcement
tolerance
through June, 1977

250

250

200
200
200
200
200
100

100

All two-stroke cycle engines & diesel
ignition.

Pre-1968 4 or less cyclinder engines, 4 or
less cylindered noncomplying imports, and
those engines less than 50 cu. in. (820 cc)
displacement.

Pre-1968 with more than 4 cylinder engines,
and noncomplying imports with more than

4 cylinder engines.

1968 through 1969, 4 cylinder.

All other 1968 through 1969,

All 1970 through 1971.

All 1972 through 1974, 4 cylinder.

All other 1972 through 1974.

1975 and 1976 without catalyst.

1975 and 1976 with catalyst.

(3) There shail be no visible emission during the steady-state unloaded
engine idle portion of the emission test from either the vehicle's exhaust

system or the engine crankcase.

In the case of diesel engines and two-stroke

cycle engines, the allowable visible emission shall be no greater than 20 per-

cent opacity.

(4) The Director may establish specific separate standards, differing
from those listed in subsections (1), (2), and (3), for vehicle classes which
are determined to present prohibitive inspection problems using the listed

standards.

75


respectively, credits. in’ percent emission reductions that can be achieved
through inspection/maintenance programs. The "basic" reductions (i.e., those
that are achieved through an annual inspection of light-duty vehicles) are
broken down by Technology I and Technology II vehicles. Technology I vehicles
include those light-duty vehicles subject to pre-1975 federal emission standards;
Technology II vehicles are subject to 1975 and later model year federal exhaust
emission standards. The percent reductions given in Tables 2 and 3 for mechan-
ics training and semi-annual inspections (as opposed to annual) are additive
to the other'emission reductions. The percent reductions for Technology I,
Technology II, heavy duty, and motorcycles and light duty trucks must be
applied separately to each class of vehicle included in the I/M program and
then a weighted average, based on the vehicle type distribution, is used to
provide the overall emission reductions obtained through the I/M program.

(The reader is referred to the proposed revision of Appendix N (FR 24(89):
22177-22183, May 2, 1977) for a more detailed discussion. The final revised
Appendix N should be consulted when it appears in the Federal Register.

EMISSION DETERIORATION

Emission deterioration refers to the increase in vehicle emission rates
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 in emissions due to
tampering or poor maintenance. Since both vehicles exposed and not exposed to
an I/M program will experience emission deterioration, the question is how
much less deterioration occurs as a result of an I/M program.

Not only is the absolute emission level to which vehicles rise important,
and the time it takes them to rise to it, but the shape of the deterioration
curve can be quite significant in affecting the benefits from the emission
control devices and the I/M program. For example, there could be a very rapid
initial deterioration (possibly due to tampering) with a gradual leveling off.
Such deterioration would negate most of the benefits of the I/M program.
Conversely, the deterioration could be very slow for most of the year with a
rapid climb at the end. This would mean much larger benefit as a result of
the program. Possible deterioration rates are diagrammed in Figure 1.

The only major study to date has indicated that deterioration is more
likely to be very slow for most of the year with a rapid climb at the end.
Thus, the overall effectiveness of I/M in the first year of the program would
be approximately 70 percent of the immediate reduction following repair at
the start of the year. Although this study is not definitive, it concludes
that previous deterioration estimates with I/M may be too high.

A subjective analysis was done of the theoretical differences between
I/M and non-I/M fleets that could affect deterioration rates. It is
felt that a lower deterioration rate could be achieved by an I/M fleet be-
cause of better and more frequent maintenance. The emissions of vehicles not
meeting cut points should improve, while the emissions of all vehicles across
the board should benefit because the quality of maintenance services should

11


FERRARL

1975 and 1976
1971 through 1974
1968 through 1970
pre-1968

FIAT

1975 and 1976 noncatalyst

1975 and 1976 catalyst equipped

1974

1972 through 1973 124 spec. sedan
and wagon

1972 through 1973 124 sport coupe
and spider

1972 through 1973 850

1971 850 sport coupe and spider

1971 850 sedan

1968 through 1970, except 850

1968 through 1970 850

pre-1968

FORD - see FORD MOTOR COMPANY

Enforcement

Base standard tolerance, %

%

ARNO
coun

NOR
Ouunu

DARUAWYW
eooooo

FORD MOTOR COMPANY (Ford, Lincoln, Mercury, Capri,

1975 and 1976 noncatalyst

1975 and 1976 catalyst equipped

1972 through 1974, except 4 cyl.

1972 through 1974, 4 cyl., except
1971 through 1973 Capri

1971 through 1973 Capri only

1970 through 1971

1968 through 1969

pre-1968

Above 6000 GVW, 1968 through 1971

Above 6000 GVW, 1972 through 1973

Above 6000 GVW, 1974 through 1976

NROR
oouo

NwWEAWNN

eooooMuOH

through June, 1977

GENERAL MOTORS (Buick, Cadillac, Chevrolet, GMC, Oldsmobile, Pontiac)

1975 and 1976 noncatalyst

1975 and 1976-catalyst equipped
1972 through 1974

1970 through 1971, except 4 cyl.
1970 through 1971, 4 cyl.

1968 through 1969

70


TABLE 10, REPAIR COST SUMMARY FOR EXISTING 1/M PROGRAMS

New Jersey Oregon
Less than $10 29.7% No cost 27%
$10 to $25 26.4% Less than $10 37%
$25 to $50 22.1% $10 to $30 18%
$50 to $100 16.1% $30 to $50 8%
More than $100 5.6% $50 to $75 5%
More than $100 2%
N = 16,000 N= 1, 400 (primarily newer
Avg. repair cost = $32.40 cars)
Median: 50% of repairs cost Avg. repair cost = 16.00
less than $20 Median: 50% or repairs cost
65% of repairs cost less less than $8
than average 71% of repairs cost less

than average

Arizona

Less than $5 27%
$5 to $10 17%
$10 to $25 24%
$25 to $50 20%
$50 to $100 10%
More than $100 2%
N = 2000

Avg. repair cost = $23.40

Median: 50% of repairs cost
less than $15

64% of repairs cost less than
average

28


TABLE 11, EXTENT OF STATES' CONSIDERATION OF INSPECTION/

MAINTENANCE
Strategy Preliminary .
State city requirement review or Enabling . lent eation*
SIP research amp
Alaska Fairbanks x x
Arizona Phoenix x x x x
Tucson x x x x
California Los Angeles x x x
Sacramento x x
San Diego x x
San Francisco x x
San Joaquin x x
Colorado Denver x x x
Connecticut All x
District of x x x
Columbia
Florida Tampa x
Illinois Chicago x x x x
Indiana Indianapolis x
Kentucky Covington x
Louisville x
Maryland Baltimore x x
D.C. Metro Area x x
Marsachusetta Boston x x
Springfield x x
Minnesota Twin Cities x
Missouri St. Louis x x
Nevada Las Vegas x x x x
Reno x x x x
New Jersey Alt x x x x
Now York New York City x x
North Carolina Charlotte x
Ohio Cincinnati x x x x
Dayton x
Oregon Portland x x x x
Pennaylvania Philadelphia x x x
Pittsburgh x x x
Remainder of x
State
Rhode Tetand All x x x x
Tenncrace Nashville x
‘Texas Dallas x x
Houston x x
Utah Salt Lake City x x x
Virginia D.C, Metro Area x x
Washington Seattle x x
Spokane x x

¥
Refer to fact sheets in Section 7 for detailn on the implementation of these programa,

35


Location: Rhode Island

Type of Program: Idle test by certified private garages. Performed in

conjunction with safety inspection.
Sites: Approximately 600 private garages statewide,

Chronology: Inspection began November 1, 1977 with voluntary maintenance.
Fully Mandatory I/M program commences January 1, 1979.

Geographic Coverage: Entire State of Rhode Island (0.5 million LDV's)
Administering Agency: Rhode Island Department of Transportation.

Staff Contact: Alfred Masserone, Chief Safety and Emissions (401) 277-2983
Thomas Getz, Rhode Island Department of Health (401) 277-2808

Capital Costs: $1,000,000 (includes first year operating costs) for con-
struction of State-Run Challenge Lane Facility.
Capital to be repaid from inspection fee.

Operating Costs: First year included in Capital Cost appropriation.

Cost to Motorists: $4,00 inspection fee - $1.00 to state, $3.00 to
private garage,

Standards: Adopted New Jersey Phase I standards as interim guideline during
first year of program, As of December 18, 1977, 69.6 percent
passed, 28,9 percent failed (1.4 percent unclassified), Of the
failed vehicles, 28.7 percent were voluntarily repaired.

Enforcement: Windshield stickers, staggered basis.

Instrumentation: Approved list of exhaust analyzers based on California list.
Data Collection: Data to be collected include initial emission concentration
of HC and CO, type, make, year, and mileage of vehicle,

repairs and cost, emission concentrations after voluntary
maintenance,

Mechanic Training: First year - Mechanic orientation seminars required for

“approval to inspect vehicles." Existing programs at
Vocational School System based on EPA-approved program
developed at Colorado State University.

Waiting Time: Inspection takes approximately 30 to 40 minutes, most garages

use an appointment system,
Other Aspects: State-run central inspection facilty is used as a referee
station for individuals who challenge the findings of a
private garage. This facility also inspects taxicabs,

buses, jitneys, and other vehicles used for the transportation
of passengers for hire,

60


has developed a mechanics' handbook which describes a repair sequence, or
step-by-step procedure, for each type of emissions failure. Mechanics are
instructed to proceed only as far as the step that corrects the malfunction.
This California program was developed to meet a législative requirement that
mechanics repair vehicles according to specifications established by the Bureau
of Automotive Repair. The specifications are an attempt to eliminate the guess-
work involved in repairs and also serve as a basis for the evaluation of repair
work,

The training program should be composed of an informational seminar and
technical workshops in which mechanics can gain practical experience. Mechanic
certification could be contingent on the successful completion of an examina-
tion administered by the cognizant government agency. Preparation for the
exam would involve participation in a technical training session or course-
work at a local technical school. Materials from the Colorado State University
Automotive Emission Control Technician Course can be applied to a program of
this type.

Repair Facility Certification and Information Dissemination

The certification of repair shops for emission work serves two purposes.
First, it gives vehicle owners some guarantee of the credibility and compe-
tence of the repair facility. Second, to retain its certification, a repair
facility would be required to perform quality work, Certain criteria could be
established upon which to base decisions concerning certification, Minimum
criteria should include the employment of a certified mechanic and ownership
(or leasing) of approved emission analyzer instrumentation. Additional re-
quirements could be established with regard to the availability of tools and
service manuals required to perform effective repairs. If certification of
repair shops is impractical, the following alternatives are possibilities
for implementation.

ry The agency administering the I/M program can keep a record
of complaints voiced by vehicle owners and investigate any
problems which arise,

° Records of vehicles which fail reinspection upon maintenance
can serve to identify those shops with a high incidence of
inadequate repair work.

° Lists of service establishments with approved emission
analyzers can be published to maximize the patronage of repair
shops that can check the results of their work.

. Repair facilities can be merely licensed on the basis that the
facility (1) employs at least one mechanic who is trained in
the use of emissions analyzer and (2) owns one operational
analyzer on the premises.

By limiting the chance of exploitation of vehicle owners a major concern
on the part of the public can be mitigated.

31


5. Nevada--Idle

Model year HC co
pre-69 1200 ppm 7.5%
68-69 600 5.0
70, 400 4.0
Ti+ 400 4.0

*
In Nevada 1971 and later vehicles must also be tuned to manufacturer's
emission control specifications.

63


are two States with a few state operated facilities but most of the inspections
in these states are done by service stations. The remaining two states perform
inspection using state facilities, but these operations are confined to only

a few cities. Seven states have no safety inspection programs.

Given the widespread existence of safety inspection programs, the com-
bination of safety and emissions testing must be considered. Two obvious
alternatives for doing so exist. The first is to simply add emissions test-
ing to the list of items to be tested. The second alternative is to create
a new combined testing program of a form different from the existing safety
inspection program.

In deciding which alternative to follow, several factors would appear to
be important in reaching a final decision. These are the following:

e public reaction to the existing safety inspection program
e nature of the existing safety inspection program

e commercial garage interest in the existing safety inspec-
tion program

The first aspect to consider when deciding how to combine safety and
emissions testing is the degree of public acceptance of the existing safety
inspection program. If the public respects the safety program and perceives
that it is nontrivial in scope, just in testing, and efficiently: administered,
it would appear to be best to simply add emission testing to the list of items
to be inspected, all other things equal. On the other hand, if there is low
public regard for the safety inspection program, the decision is not as clear-
cut. In instances where the safety inspection is regarded as a sham, the
inclusion of emission testing with its resulting higher inspection fee is
likely to be perceived as, at a minimum, a further unjustified annoyance.
Where this is the case, it may be wise to, in cases where the safety inspection
is conducted by private commercial garages, develop a centralized combined
test. If this course of action is not possible, at a minimum the combined
program should be more rigidly enforced and more effort put into its
administration.

The nature of the existing safety inspection program is a second
consideration. If it is conducted at centralized facilities run by the state,
it would appear to be easiest to have emissions testing conducted there as
well. This is due to the existing capital investment made by the state in
land and buildings. Although some investment in the equipment necessary to
perform safety testing would have been undertaken by service stations and
garages, it is not typically of a significant enough magnitude to preempt
the consideration of a combined testing program in a centralized facility.

Finally, commercial garage interest in the testing of vehicles must be
considered. If service stations and garages exhibit no interest in perform-
ing emission testing, then the choice of action is obvious. Where this group
does have an interest in emissions testing, then the combining of safety and

41


Hall, Owen P., Jr. and Neal A. Richardson. The Economic Ef-
fectiveness of Vehicle Inspection/Maintenance as a Means for
Reducing Exhaust Emissions: A Quantitative Appraisal.
(Report on CRC-APRAC Project CAPE-13-68). TRW, Inc. Paper
No. 740131. (Paper Presented at SAE Automotive Engineering
Congress. Detroit. February 1974.)

Midler, Joseph L. and Owen P. Hall, Jr. Critical Uncertainties
in Cost-Effectiveness of Exhaust Emission Control Programs.
TRW, Inc. (Paper Presented at APCA Annual Meeting. Boston.
1975.)

C. Public Opinion

*1,

Conderacci, Greg. Vehicle Inspection and Maintenance for
Massachusetts: A Sampling of Interest Group Opinion. Prepared
for U.S. Environmental Protection Agency, Region I. May 1976.

Lilley, Frank W. Public Opinion Survey of the Proposed
Massachusetts Inspection Maintenance Program. New England
Consortium of Environmental Protectiog. (Presented at MVECC-V.
Hyannis. October 26, 1976.)

VI. RELATED ISSUES

A. High Altitude

1.

Automotive Testing Labs, Inc. An Evaluation of High Altitude
Engine Modification Devices (Econo-Kit). Prepared for U.S.
Environmental Protection Agency, Region VIII. March 1976.

Automotive Testing Labs, Inc. Vehicle Testing to Determine
Feasibility of Emission Inspection at High Altitudes. Prepared
for U.S. Environmental Protection Agency. September 1972.

Olson Laboratories, Inc. High Altitude Vehicular Emissions
Control Program. Prepared for State of Colorado and U.S.
Environmental Protection Agency, Region VIII. December 1975.

Sorrels, Donald E., Douglas R. Liljedhal, and Jerry L. Terry.
An Investigation of Idle Emissions Inspection and Maintenance
at Altitude. Colorado Department of Health and Automotive
Testing Laboratories, Inc. J Air Pollut Contr Assoc. 26(4),
April 1976.

U.S. Environmental Protection Agency. Approval of Emission
Control Modification for High Altitudes on New Motor Vehicles
or Engines. June 1972.

TRW Transportation and Environmental Operations, Automotive
Testing Labs and Olson Labs. High Altitude Vehicular Emission
Control Program. Prepared for State of Colorado, Department

83


provisions of the Clean Air Act do not provide for pollution-free or maintenance’
free vehicles. Emission control devices, like other components of an automo-
bile, require periodic maintenance and adjustment.

. Even with these federal enforcement programs, many vehicles are not meeting
emissions standards for the following reasons:

e Many in-use vehicles are found with disabled control systems.
Emission control equipment may be deliberately disconnected
and adjustments varied to affect vehicle performance.

e Many owners are not aware of proper vehicle maintenance schedules
and requirements. Emission-controlled vehicles which meet manu-
facturers' specifications would generally be low emitters.

° Not all vehicles can be inspected at the end of the assembly line.
Vehicle types that pass certification may be assembled within
reasonable tolerances. However, some vehicles may still not
meet standards.

In short, if motor vehicles are to continue to meet emission standards
after they have been in use, they must receive periodic maintenance. An
inspection/maintenance program would ensure that vehicles are properly main-
tained. Thus, inspection/maintenance is an integral part of a comprehensive
motor vehicle emission control program. Its goal is to increase the frequency
and quality of the maintenance of motor vehicles and thereby reduce average
emissions per vehicle mile traveled. Implementation of I/M is also attractive
for the following reasons.

First, the proper implementation of an inspection/maintenance program
ensures that, other things being equal, total automobile related pollutants
for a given fleet will decline. This is important since it has, at least in
the past, been relatively difficult to induce people to make less use of their
automobiles. This is not to say that strategies such as transit improvements,
carpooling and vanpooling, and parking control have not been proven to be
successful in several instances. However, the extent of their success is li-
mited to the number of people who actually jstop using their automobiles. This
is difficult to predict. On the other hand, the success of I/M in reducing
emissions can be determined given the number of vehicles inspected, the emis-—
sion standards established, and the frequency of inspection. In short, there
are fewer unknowns associated with an I/M program.

Secondly, I/M provides an incentive for an individual to keep his auto-
mobile in good operating condition. It requires only that necessary main-
tenance be performed. As such, it provides a payoff to automobile owners in
terms of improved fuel economy and the potential for long-term improved ve-
hicle performance and longer vehicle life.

Lastly, the ability to administer I/M has been demonstrated in several
different areas already. It involves a number of different agencies and thus


ABSTRACT

This document provides information on motor vehicle emissions testing
programs, usually referred to as inspection/maintenance programs. Based upon
the most recent and reliable information available, background information
on these programs and a review of the major issues in this area are presented
More specifically, the effectiveness, costs, and the environmental, energy,
and economic impacts of inspection/maintenance programs are discussed.

In addition to the main text, a comprehensive bibliography area is

presented, Fact sheets on existing inspection/maintenance programs are also
included.


SECTION 6

‘INSPECTION/MAINTENANCE PROBLEM AREAS

This section deals with four major problems associated with inspection/
maintenance programs. These are the following:

e Quality control of private garages

e Adequacy of the repair industry to perform emissions
related work

e Combined safety and emissions testing
e Impact of waivering repair requirements for certain vehicles
QUALITY CONTROL OF PRIVATE GARAGES

As mentioned in a previous section, there are essentially two opera-
tional options for an I/M program. These are a centralized inspection system
(government or contractor operated) and a decentralized system (private
commercial garages). Among the disadvantages of a decentralized system are
potential problems in the area of quality control.

The two major quality control problems associated with a decentralized
system are nonuniformity of enforcement criteria and cumbersome and potentially
inadequate data collection and handling. The first of these problems results
in variation in the quality or stringency of the test from station to station.
This problem is, of course, of the same type as the one present where safety
inspections are performed by private commercial garages. Some stations are
less diligent than others in both the care of the testing equipment and in
the actual performance of the test.

The second problem, inadequate data collection, leads to difficulties in
monitoring the success of the problem. Unless adequate before and after
inspection emissions data is properly collected, necessary adjustments in the

program, such as the stringency of the emissions standards, cannot be made
since problems would go undetected.

These disadvantages or drawbacks to testing at private commercial

garages are offset by the greater conveniences offered the motorist. Since
there are typically a large number of stations performing the test (compared

38


Enforcement
Base standard tolerance, %
% through June, 1977

CHRYSLER CORPORATION (Plymouth, Dodge, Chrysler) (continued)

pre-1968 6.0 0.5

Above 6000 GVW, 1968 through 1971 4.0 1.0

Above 6000 GVW, 1972 through 1976 2.0 1.0
CITROEN

1971 through 1974 3.0 1.0

1968 through 1970 4.0 1.0

pre-1968 6.0 0.5
COLT, Dodge

1975 and 1976 3.0 0.5

1971 through 1974 5.0 1.0

pre-1971 6.0 0.5
COURIER

1975 and 1976 1.5 0.5

1973 through 1974 2.0 1.0

pre-1973 4.0 1.0
CRICKET, Plymouth

1973 through 1974 (twin carb. only) 3.0 1.0

1972 (twin carb. only) 4.5 1.0

pre-1972 (and 1972 through 1973 7.5 0.5

single carb. only) ,

DATSUN

1975 and 1976 2.0 0.5

1968 through 1974 2.5 1.0

6.0 0.5

pre-1968
DE TOMASO - see FORD MOTOR COMPANY
DODGE - see CHRYSLER CORPORATION

DODGE COLT - see COLT, Dodge


10.

il.

12.

13.

14,

1s.

*16.

17.

18.

19.

*20.

21.

Morris, J. Roger. Control of Automobile Related Air Pollution:
Past Results and Future Prospects. Office of Mobile Source

Air Pollution Control, U.S. Environmental Protection Agency.
Draft. 1976.

Panel on Air Quality, Noise and Health, E-Tuerk, U.S. EPA Chair-
man. Air Quality, Noise and Health. Report of a panel of the
Interagency Task Force on Motor Vehicle Goals Beyond 1980.
Interim Report. March 1976.

Shutler, Dr. Norman D. Overview of Inspection/Maintenance.
U.S. Environmental Protection Agency. (Presented at MVECC-IV.
Anaheim. November 1975.)

TRW. A Study of Mandatory Engine Maintenance for Reducing
Vehicle Exhaust Emissions. Executive Summary. July 1973.

U.S. Department of Transportation (National Highway Traffic
Safety Administration). Costs and Benefits of Motor Vehicle
Inspection. January 1975.

U.S. Environmental Protection Agency, Region I. A Citizens
Guide to Automotive Inspection. 1976.

U.S. Environmental Protection Agency. Control Strategies for
In-Use Vehicles. November 1972.

U.S. Environmental Protection Agency. Inspection/Maintenance
Binder of Background Materials. April 1976.

U.S. Environmental Protection Agency, Region I. Issues on
Inspection and Maintenance. March 1975.

U.S. Environmental Protection Agency. Strategies and Air
Standards Division. Inspection and Maintenance: A Guide for
Implementation. February 1974.

U.S. Environmental Protection Agency. I/M: Cost-Effectiveness

and Feasibility of Implementation. Preliminary Working Draft I.
May 1976.

Walsh, Michael P. The Need for and Benefits of Inspection and
Maintenance of In-Use Motor Vehicles. U.S. Environmental

Protection Agency. Motor Source Enforcement Division. November
1976.

Weaver, Harry B. Status of Air Pollution Control Systems.
Manager, Environmental Engineering Department, Motor Vehicle
Manufacturers Association. (Paper Presented at American

Association of Motor Vehicle Administrators. Stouffers North—
land Inn. April 29, 1976.)

78


United tes Office of Air and EPA-400/2-78-001

ed Sta’
Environment ‘tal Protection Waste Mangement (AW-445) February 1978
Agency Washington, D.C, 20460
Air

SEPA Information Document
- on Automobile
Emissions Inspection and

Maintenance Programs



PREFACE

The Clean Air Act Amendments of 1977 (Public Law 95-95) require the
Environmental Protection Agency to make available to appropriate Federal
agencies, states, and air pollution control agencies information regarding
processes, procedures, and methods to reduce or control motor vehicle emissions
by inspection and maintenance programs (Section 108 (f) (1) (A) (i)). ‘this
document therefore is intended to provide basic and current information to
those who have little knowledge of the subject area and to provide reference
information and guidance for those who wish to pursue specific inspection/
maintenance topics further, A bibliography is included,

iii


Effect of Vehicle Systems on Emissions

A change in the operation of many vehicle Systems and vehicle components
can effect a change in emissions. Table 7 lists the most common of these sys-
tems and components, their mode of operation causing the change in emissions,
and the resultant effect on carbon monoxide and hydrocarbon emissions. Carbu-
retor problems and air-fuel mixture imbalance have proven to be the major causes
of high carbon monoxide emissions. Malfunctions in the ignition system or asso-~
ciated components primarily result in high hydrocarbon emissions. Malfunction
of the emission control devices including breakdown of the catalytic converter
affect both pollutants. Table 8 summarizes the major causes of exhaust
emissions.

Costs of Repair

Data on the types of repairs required to comply with an I/M program and
the costs of these repairs have been compiled by the existing I/M programs.
Table 9 presents the distribution of the types of repair as reported by the
Portland, Oregon I/M program. Most repairs focus on carburetor and ignition
systems malfunctions. These data are typical of reports emanating from I/M
programs elsewhere. As reported by four programs, the overall average cost of
repairs is approximately $27.00, though well over half these repairs fell under

this figure. Detailed cost information from various programs is presented in
Table 10.

TABLE 7, EFFECT OF ENGINE COMPONENT OPERATION ON EMISSIONS

Change in emissions

Component.
Carbon monoxide Hydrocarbon

Decreased air-fuel ratio

Increase Increase
Decreased engine idle speed Increase Increase
Restricted PCV valve Increase Increase
Restricted air filter Increase Increase
Choke malfunctions Increase Increase
Carburetor malfunctions Large increase Increase

Ignition system malfunctions Large increase

Advanced spark timing

Decrease
Stuck heat riser valve Increase
Exhaust valve leak Increase
Intake manifold leaks Increase Increase
Emission control device malfunction Increase Increase

‘Catalytic converter breakdown Large increase Large increase

26


Aymar, Arthur A. Arizona Key Model Auto Inspection. Arizona
Department of Health Services. ~APCA Téchnical Paper 75-424.
(Presented in Boston. June 1975.)

Hamilton Test Systems. A Summary of Factual Information Con-
cerning Emissions Testing. March 1976.

Iacobelli, Fred and Jack Hesse. The Arizona Emissions Inspection
Program— Initial Operations. Arizona Department of Health
Services. (Presented at 1976 SAE Fuels and Lubricants/Powerplant
Meeting. June 8, 1976.)

Iacobelli, F. R. The Arizona Inspection/Maintenance Program.
Arizona Department of Health Services. (Presented at NVECC-IV.
Anaheim. November 1975.)

California

1.

*6,

Dolan, John H. Briefing on the California Vehicle Inspection
Program and Detailed Description of the Phase I Riverside Trial
Program. Program Manager, Vehicle Inspection Program. (Pre-
sented at MVECC-IV. Anaheim. November 1975.)

Kelly, Warren. Exhaust Emissions and Cost Evaluation of the
State of California's Roadside IDLE Emission Inspection
Program. Scott Research Labs, California. PB 235-990.
December 1973.

Olson Laboraotires, Inc. South Coast Air Basin Vehicle Emis-
sion Inspection Program Design Study— Volume 1, Summary. Pre-
pared Under Contract EST No. 77-107 With the State of California
Department of Consumer Affairs, Bureau of Automotive Repair,
Anaheim, California. May 1975.

Rubestein, G., R. Ingels, R. Weis, and A. Wong. Vehicle In-
spection and Maintenance— The California Program. California
Air Resources Board. SAE Paper No. 760557. (Presented at
Fuels and Lubricants Meeting. St. Louis. June 7-10, 1976.)

State of California. Joint Committee on Motor Vehicle In-
spections, Motor Vehicle Emissions Inspection Program, Public
Hearing. Sacramento. December 8, 1976.

State of California Air Resources Board. Evaluation of Mandatory
Vehicle Inspection and Maintenance Programs: Summary Report.
May 1976.

Task Force Report on Periodic Vehicle I/M for Emission Control
and Recommended Program. California. October 1972.

85


*5,

Panzer, J. IDLE Emissions Testing- Part Il. Exxon Res. & Eng.

Company. Paper No. 740133. (Paper Presented at SAE Automotive
Engineering Congress. Detroit. February 1974.)

Panzer, J. IDLE Emissions Testing— Part III. Exxon Res. & Eng.

Company. Paper No. 74-130. (Paper Presented at APCA. June
1974.)

Panzer, J. IDLE Emissions Testing: Some Effects of Engine
Malfunctions on Emissions. Exccon Res. & Eng. Company. (Paper
Presented at MVECC-IV. Anaheim. November 1975.)

B. Loaded Mode Testing

1.

2,

Clayton Manufacturing Company. The Key Mode Engine Evaluation
System. 1971.

Clayton Manufacturing Company. Clayton Blue Book: Literature
Germane to Mobile Source Emission Control Through Corrective
Action.

Cline, E. L. and Lee Tinkham. A Realistic Vehicle Emission
Inspection System. Dynamometer Division. Clayton Manufactur-
ing Company, El Monte, California. Paper No. 68-052. APCA
Annual Meeting. June 1968.

Cc. Analysis of Testing Procedures

1.

Blanke, John D. and Donel R. Olson. Adding Oxygen Analysis to
Existing I/M Programs Can Increase Diagnosis Accuracy. Olson
Engineering, Inc. (Presented at MVECC-V. Hyannis. October 26,
1976.)

Carlson, R. R., Burke-Carlson Associates; T. A. Huls and S. C.
Kuhrtz, U.S. Environmental Protection Agency; and G. M. Wilson,
Olson Laboratories, Inc. Effectiveness of Short Emission In-
spection Tests in Reducing Emissions Through Maintenance. Paper
No. 73-80. (Presented at the 66th Annual Meeting of APCA.
Chicago. June 24-28, 1973.)

Dekany, John P- and F. Peter Hutchins. Development of a Short
Test for 207(b): A Status Report. U.S. Environmental Pro-
tection Agency, Emission Control Technology Division. (Pre-
sented at MVECC-IV. Anaheim. November 1975.)

Hinton, M. G., J. C. Thacker and U. D. Lee. Federal Test Pro-
cedures and Short Test Correlation Analyses. The Aerospace
Corporation, El Segundo, California for U.S. Environmental
Protection Agency, Office of Air and Waste Management, Office
of Mobile Source Air Pollution Control, Ann Arbor, Michigan.
Report No. EPA-460/3-76-011. April 1976.

80


nitrogen from automobile emissions and should therefore be considered in areas
where there is a defined No. problem.

Tampering Inspection--

Various engine components and emission control devices can deteriorate or
be disabled and have no noticeable effect on the way the car drives or its fuel
consumption. Such conditions, however, will lead to major adverse effect on
vehicular emissions. Malfunctioning vehicles may go unrepaired for thousands
of miles before overt indications of disrepair are noticed by the operator. In
many cases, these malfunctions result from deliberate actions of the operator
or an operator's agent to vary the operation of the motor vehicle.

To guard against deliberate tampering, the Federal Government and many
states have adopted Motor Vehicle Emission Control legislation which includes
clauses prohibiting the operation of motor vehicles when air pollution control
devices have been removed, altered or rendered inoperative. The status of
state antitampering laws are presented in Table 1. These laws are virtually

ineffective in most situations, since the existence of a strong deterrent to
tampering does not exist.

The performance of a tampering inspection as part of an I/M program could
represent a suitable deterrent to tampering since there exists the threat of
not meeting the I/M emission standards. In this respect, a tampering inspec-
tion program in conjunction with an emissions inspection could result in addi-
tional reduction in total vehicular emissions. The exact amount of such reduc—
tion would depend upon the sophistication of the tampering inspection.

Mechanics Training--

The air quality benefit from an I/M program is dependent, in part, on
the ability of the service industry to properly perform the repair work neces-
sary 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 train-

ing since the mechanics would be familiar with the problems and the best
solutions.

Vehicle Exemptions-—

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. 1/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--
In order to determine how frequently vehicles should be inspected for

emissions, it is necessary to know about how long emission-related repair

work - such as correction of carburetion - is likely to last. The increase


Waiting Times: No problems.
Problems: Recent figures show less than 20 percent of city's registered
vehicles are being inspected.

City position favors mandatory I/M programs with three con-
ditions:

1. Federal Government and auto manufacturers| concurrence on a
warrantee program. (See 207(b) of Clean Air Act).

2. Auto Manufacturers compliance with statutory emissions
standards.

3. I/M to be implemented regionally because of the large per-
centage of travel on city streets by non-Chicago vehicles.

Achievements: Communication channels established with Auto Manufacturers
regarding high emission levels of late model vehicles.

50


3.

An Act Establishing an Inspection System for all Motor
Vehicles. Chapter 31-38. State of Rhode Island in General
Assembly January Session 1977. Effective November 1977.

Act No. 81. Vehicle Code, Section 4531. Emission Control
Systems. State of Pennsylvania.

IX. MISCELLANEOUS ARTICLES

1.

#4,

*7,

Motor Vehicle Manufacturers Association. Factors Affecting Idle
Emission Measurements of New Vehicles. June 1974.

Panzer, Jerome. Automotive Emissions Testing. Environ Sci Technol.
8(12):974-5, November 1974.

Patterson, D. J. and N. A. Henein. Emissions From Combustion
Engines and Their Control. Ann Arbor Science Publishers, Inc., Ann
Arbor, Michigan. 1972.

Price, William F. Vehicle Emission Related Diagnostics and
Repairs. PVI Program Manager, Bureau of Vehicular Emissions
Inspection, Division of Environmental Health Services, Arizona
Department of Health Services. (Draft). March 29, 1976.

Three Auto Makers Notified of CO Emission Failures. U.S.
Environmental Protection Agency. Environmental News.
July 21, 1976.

Elston, John C. Auto Emission Inspection Test Variability.

New Jersey Department of Environmental Protection. Presented
at the 70th Annual Meeting of Air Pollution Control Association.
Toronto, Ontario, Canada. June 20, 1977.

Iacobelli, R. Fred. Inspection/Maintenance and Public
Acceptance. Arizona Department of Health Services. Presented
at 70th Annual Meeting of Air Pollution Control Association.
Toronto, Ontario, Canada. June 20, 1977.

92


Enforcement
Base standard tolerance, %
a through June, 1977
GENERAL MOTORS (continued)
pre-1968 6
Above 6000 GVW, 1968 through 1971 4.
Above 6000 GVW, 1972 through 1973 3.
Above 6000 GvW, 1974 through 1976 2.
GMC - see GENERAL MOTORS
HONDA AUTOMOBILE
1975 and 1976 CVCC 1
1975 and 1976, except CVCC engine 1
1973 through 1974 3
pre-1973 5
INTERNATIONAL-HARVESTER
1975 and 1976 2.5
1972 through 1974 3.0
1970 through 1971 4.0
1968 through 1969 5.0
pre-1968 6.0
JAGUAR - see BRITISH LEYLAND
JEEP - see AMERICAN MOTORS
JENSEN-HEALEY
1973 and 1974 4.5 1.0

JENSEN INTERCEPTOR & CONVERTIBLE - see CHRYSLER CORPORATION

LAND ROVER - see BRITISH LEYLAND, Rover
LINCOLN - see FORD MOTOR COMPANY
L.U.V., Chevrolet

1974 through 1976 1
pre-1974 3

BR
oo

MAZDA

1975 and 1976 1
1968 through 1974, Piston Engines 4,
1974, Rotary Engines 2
1970 through 1973, Rotary Engines 3

OoOFO

uuu

71


REFERENCES

1. Walsh, Michael P, The Need For and Benefits of Inspection and Maintenance
of In-Use Motor Vehicles. U.S. Environmental Protection Agency, Mobile
Source Enforcement Division. November 9, 1976,

32


Location: Arizona

Type of Program: Contractor operated, permanent and mobile facilities,

with loaded mode capabilities. Vehicle emission to
comply with idle standards only.

Sites: 12 permanent sites, 36 lanes (9 "metro" stations of 3 to 5 lanes
and 3 one-lane stations in outlying areas.) One mobile station.

Chronology: Voluntary testing began December 1975; became mandatory
January 1976, and maintenance became mandatory January 1977.

Geographic Coverage: Maricopa (Phoenix) and Pima (Tucson) Counties,

approx. 1.1 million vehicles including trucks and
motorcycles.

Administering Agency: Arizona Department of Health Services

Operated by: Hamilton Test Systems, Inc.

Staff Contacts: ADHS - Fred Iacobelli, (602) 271-4548
HTS - Jack Hesse (Assistant Manager, (602) 955-9670
Dan Stone (Manager), (602) 955-9670

Capital Cost: $134,000 one-time appropriation by State.
$9 million to HTS, including location studies, admin-
istrative start-up, etc., as well as equipment, land
acquisition, and construction.

Operating Cost: Est. $0.5 million by HTS in 1976.
Cost to Motorist: $5, includes one free retest.

Standards: HC and CO standards at low cruise, high cruise, and idle
dependent on engine type (2 or 4 stroke), model year (4 stages)
curb weight, and number of cylinders. Vehicles required to
comply with idle emission standards only. Dynamic evaluation
for diagnostic purposes. Twenty percent opacity standard for
diesels. Projected 1976 stringency factor was 35 percent but
approximately 45 percent of vehilces actually failed to meet
standards. Revised standards for 1977 estimated to achieve a
rate of 25 percent, but during the first half of the year
only 16 percent of the vehicles did not meet standards at
time of the first inspection. All 50 cc and larger engines
are covered, including two strokes and diesels. Golf carts
are exempted. New cars are not inspected until 1 year old.
Thirteen year and older "moving exemption;" e.g., in 1977,
model years 1964 and older are exempted.

4h


Location: Chicago

Type of Program: City-operated vans, idle mode. Mandatory inspection
with no enforcement = voluntary inspection. Voluntary
maintenance.

Sites: Five permanent sites with two lanes each; plus six mobile sites
with two lanes each, Permanent sites have varied in past years
with a high of 9.

Chronology: Began inspection in June 1973, EPA Region V issued enforce-
ment (s 113) order to city to meet inspection rate of 3000
vehicles/day by December 1975, If failing to comply with
this requirement the city was to implement full mandatory
inspection/maintenance in March 1976; all Cook County vehi-
cles entering the loop would also have been required to
undergo full I/M., One year later, Chicago has not met
established rate and EPA has not initiated action,

Geographic Coverage: City of Chicago only (1.0 million LDV's), but any
vehicle coming in will be inspected. Remainder of
Cook County is far behind in implementation.

Administering Agency: City of Chicago, Department of Environmental Control.

Staff Contact: John Winkler - (312) 744-7152; Joe Seliber (312) 744-5958.

Capital Cost: $2 million, including $350,000 design and start-up.

Operating Cost: 1977 Budget: $1.448 million.

Cost to Motorist: No fee collected at time of inspection. Portion of

annual city vehicle registration fee allocated to cover

program costs.

Standards: CO and HC standards for four model-year groups - estimated
30 to 35 percent stringency factor.

Enforcement: None, although Vehicle Emission Testing Ordinance adopted by
City of Chicago during 1973.

Instrumentation: 18 Sun #910 I Analyzers, modified to include C02 testing
and computer control. Eleven backups w/o CO2 modification.

Data Collection: Record kept on emissions by Make and by Model year, es-—
pecially late model years 1975 to 1977's which are failing
at above 25 percent. Study done during 1975 to 1976 in
conjunction with EPA's Emission Factor Program showed
1975's failing at 28 percent (on Chicago test).

Mechanic Training: Definite need, but none to date.

49


Enforcement: Vehicles could not be registered without proof of inspection
in 1976, or proof of passed inspection in 1977. Proof con-
sists of embossed stamp on registration form by Hamilton.
Under-hood check for tampering and PCV operation. Besides
annual registration, vehicles must also be inspected at title
change. Scrap and auction sales, and sales between private
individuals are exempt.

Instrumentation: All Otto-cycle vehicles tested on Hamilton infrared (NDIR)
exhaust analyzers for HC, CO, and C07. Wider range meter
for two-stroke engines. Opacity testing. Clayton dyna-
mometers. Computer link provides automatic printout of
results (no engine hookup as in Riverside).

Data Collection: Vehicle ID information, all test results, lane location,
time of day, etc. for all vehicles.

Mechanic Training: ADHS has conducted 2-day seminars for mechanics.
Seminars held monthly.

Waiting Times: Some problems experienced at start of program, but these
are expected to disappear due to optimizing hours of
operation and better public awareness of all station lo-
cations. Ten minutes is the planned maximum wait during
a typical peak hour. Problems experienced at end-of-month
and peak hours. Total inspection time is 5 minutes.

Other Aspects: If the State should renege on its 5-year contract with
Hamilton, a guarantee provides that Hamilton shall receive
a sum, prorated over the remainder of the 5 years. After
5 years, the program will discontinue operation or Arizona
may operate the program on its own, having to compensate
Hamilton only for its nondepreciated capital holdings. The
State may also continue to contract the I/M program, with
Hamilton having exclusive contract rights for an ensuing
10-year period. Of the $5 inspection fee, 55¢ goes to the
State. Part of this money is used for its own operating
expenses and the remainder is deposited in a special fund
to be used for future expansion, contingencies, etc.
Hamilton's $4.45 share of the fee includes profit and pro-
gram public relations.

Problems: Initial adverse public reaction.
Repeal proposition on November 1976 referendum ballot (did not
pass).

Achievements: Nation's first contractor-operated program keeps cost to
State minimal.

45


Enforcement
Base standard tolerance, %
% through June, 1977

VOLKSWAGEN

1976 Rabbit and Scirocco

1976 All Others

1975 Rabbit, Scirocco, and Dasher
1975 All Others

1974 Dasher

1974 Type 4 Fuel Injection 1.8 liter
1972 through 1974, except Dasher
1972 through 1974 Dasher

1968 through 1971

pre-1968

WooouUouuuu

SCUMBdUUUUMN

OPRPFOrFOGDOO

DAwWwNwunnonoe

‘VOLVO

1975 and 1976 6 cyl. 1
1975 and 1976 4 cyl. 2
1972 through 1974 3
1968 through 1971 4
pre-1968 6

NONCOMPLYING IMPORTED VEHICLES

All 6.5 0.5
DIESEL POWERED VEHICLES

All 1.0 0.5

ALL VEHICLES NOT LISTED AND VEHICLES FOR WHICH NO VALUES ENTERED

1975 and 1976 noncatalyst, 4 cyl. 2.
1975 and 1976 noncatalyst, all 1.
except 4 cyl.
1975 and 1976 catalyst equipped 0
1972 through 1974 3
1970 through 1971 4
1968 through 1969 5
pre-1968 and those engines less than 6
50 cu. in. (820 cc) displacement

74


of Health and U.S. Environmental Protection Agency Region VIII
under Contract Nos. C290526 and 62-02-0048. Seven Volumes.
January 1974.

B. Position Papers

1.

*2,

General Motors Position on Motor Vehicle Emission Inspection
Procedure. February 28, 1975.

Stork, Eric 0. Mobile Source Emission Control Strategy Paper.
Deputy Assistant Administrator, Mobile Source Air Pollution
Control. 1976.

U.S. Environmental Protection Agency. Policies for the In-
clusion of Carbon Monoxide and Oxidant Controls in State
Implementation Plans (TCP Policy Paper). December 1975.

Cc. Warranty Provisions - 207(b)

Ll. U.S. Environmental Protection Agency. Emission Control System
Performance Warranty Regulation. May 25, 1977.

2. U.S. Environmental Protection Agency. Regulatory Support
Document - Section 207(b) NPRM. Emission Control Technology
Division. Office of Mobile Source Air Pollution Control,
November 30, 1976.

D. Miscellaneous

1. Interagency Clean Car Advisory Committee. Report on Low Emis-
sion Vehicle Certification Program Under Section 212 of the
Clean Air Act. Submitted to the Low Emission Vehicle
Certification Board. November 1974.

2. Jones, Martin V. and Richard M. Jones. Diagnostic Motor Vehicle

Inspection: Potential Indirect, Societal Impacts. Report to
Avco Systems Division. June 1975.

VII. STATES' EXPERIENCE WITH INSPECTION/MAINTENANCE

A. Arizona

1.

Arizona's Vehicle Inspection Program: About Air and Autos and
Arizona. Cleaner Air for Arizona. A 5-Minute Test to Help
Everyone Breathe Easier. Preserving a Healthy Environment in

the Age of the Automobile. (Four Pamphlets From Arizona Vehicle
Emissions Inspection Program.) 1976.

Arrigo, Anthony J. State of Arizona Vehicular Emissions Control
Program. (Presented at Second North American Conference on
Motor Vehicle Emission Control. Denver.) 1973.

84


to the number of facilities under the centralized alternative), the probability
of a testing site being nearer to a given individuals home or office is greater.
In addition, waiting lines would tend to be smaller given the wide choice of
testing sites. Thus, the question becomes one of determining what can be done
to mitigate the drawbacks associated with this option.

EPA has addressed this issue in the revised edition of Appendix N. In
addition to the minimum requirements for all I/M programs, for a state to
receive the basic emission reduction benefits for a decentralized program,
five additional provisions must be made.

The first of these additional provisions is the licensing of inspection
facilities by the agency governing the program. While the exact requirements
are determined by the governing agency, EPA has provided certain guidelines.
First, the facility must have the necessary instrumentation which has been
approved by the governing agency and employ someone competent in the use of
such equipment. Secondly, the facility must agree to perform the specified
recordkeeping and submit themselves to inspection.

The next two provisions involve recordkeeping. First, the records should
include a description of each vehicle with its emission test results plus in-
formation on the calibration of the emission analyzers. Copies of these in-
spection records must then be submitted on a periodic basis to the governing
agency for auditing.

The last two provisions concern the monitoring of the inspection facility.
EPA stipulates that each facility licensed must be inspected at least once
every 90 days. ‘In addition to these periodic checks, EPA requires that the
governing agency have a program of unannounced/unscheduled inspections to
handle complaints and to keep the station "honest."

It should be emphasized that without at least the above provisions, a
decentralized I/M could become nothing more than a sham. Unless such pre-
cautions are taken, the effectiveness of this I/M approach could be minimal.

ADEQUACY OF THE REPAIR INDUSTRY TO PERFORM EMISSIONS-RELATED WORK

The ability of the repair industry to perform emission-related repair
work is crucial to the overall success of an I/M program. If inadequate or
incorrect adjustments are made to vehicles requiring maintenance, then by
definition the overall effectiveness of the program in terms of emission
reduction is decreased. In addition, inadequate or incorrect repairs can
lead to public distaste for the program. Unless repairs are performed pro-
perly the first time a vehicle comes in, an increased dissatisfaction on the
part of motorists is likely to result. Thus, the repair industry is at the

center of any I/M program.

The question of the adequacy of the repair industry to perform emissions~
related work is compounded to some extent by an element of distrust on the
part of the motoring public. Rightly or wrongly, it is often perceived that
the quality of repair work in general is, upon occasion, questionable and that

39


DISCLAIMER

This Final Report was furnished to the U.S. Environmental Protection
Agency by GCA Corporation, GCA/Technology Division, Bedford, Massachusetts
01730, in fulfillment of Contract No. 68-01-4458, The opinions, findings, and
conclusions expressed are those of the authors and not necessarily those of
the Environmental Protection Agency or of cooperating agencies. Mention of
company or product names is not to be considered as an endorsement by the
Environmental Protection Agency.

This air pollution report is issued by the Office of Air and Waste Manage-
ment, U.S. Environmental Protection Agency, to assist state and local air pollu:
tion control agencies in carrying out their program activities. Copies of this
report may be obtained, for a nominal cost, from the National Technical Infor-
mation Service, 5285 Port Royal Road, Springfield, Virginia 22151.

ii


COMPILATION OF EMISSION STANDARDS FOR I/M PROGRAMS

Chicago and Cincinnat

i--Idle

APPENDIX A

BS

x

Model year HC co
(nonfleet pre-68 1000 ppm 6.0%
vehicles) 68-69 600 5.0
70-74 500 4.0
75+ 250 1.5
New Jersey--Idle

Model year HC co

Phase I, pre-68 1600 ppm 10.0%
effective 68-69 800 8
Feb. 1, 1974 70-74 600 6
Phase II, pre-68 1400 ppm 8
effective 68-69 700 7
November 1, 1975 70-74 500 5
75+ 300 3
Phase III, not pre-68 1200 ppm 7
effective 68-69 600 6
until at least 70-74 400 4
January. 1978 75+ 200 2.

Washington, D.C.--Idle (volunteer program partially sponsored by U.S. DOT

NHTSA Diagnostic Demonstration Project)

Rhode Island--Idle

Model year HC Ci
pre-68 700 ppm 6.
68-70 400 5.
71+ 300 4

Model _ year HC

pre-68
68-69
70-74
75+

1600 ppm 1
800
600
300

62

0%

8.0%
6.0%
3.0%

CSoOuUCTCON oo


Problems: No action at this time on I/M in remainder of State.
Achievements: Public reaction has been excellent. Unique combination

of exhaust analysis, engine monitoring, and computer
technology. Diagnosis helps insure satisfied consumer.

48


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.

tepeatability: 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
meaningful results after a step change in gas concentration level
initiated at the tailpipe 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.

tampering: The illegal alteration, modification, or disconnection of emis-
sion 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
allowable concentrations of pollutants (e.g., parts per million).
However, a standard could also be expressed in terms of mass emissions
per unit of time or distance traveled (e.g., grams per mile).

97


Loaded mode testing is a better indicator of actual emissions since it in-
volves the simulation of actual driving conditions. In addition, the simulation
has the capability to provide better diagnostic information to a mechanic in
terms of actual engine maladjustments and malfunctions. These advantages come
at the expense of greater testing cost due to the need for a chassis dynamometer.
The time required to test a vehicle is also increased.

In addition, the transient test is expected to yield better correlation
than the steady state test with respect to Federal Test Procedure (FTP) emis-
sions. However, the transient type test is more expensive to perform and
requires more time.

The idle mode test also provides a viable method for identifying vehicles
with high emission levels. This test procedure is simple to perform and re-
quires relatively little technician training. Inspection lanes which use the
idle mode test will have a greater capacity and thus will result in lower costs
per vehicle inspection. An additional advantage of this test is that it can be
easily duplicated at service garages to confirm that emission-related mainte-
nance has been successful. While the idle mode test does not give as much
diagnostic information as the loaded test, other considerations, such as cost,
may justify the selection of this test procedure.

Table 6 summarizes the characteristics of idle and loaded mode testing
procedures. The U.S. EPA and private research organizations have found idle
mode testing to be virtually as effective as the loaded mode test in identifying
gross emitters, and thus a viable inspection technique.

Administration of the Test

An I/M program can be conducted at either a network of centralized in-
spection lanes or a network of certified private garages. A public authority
can be delegated the responsibility of establishing the network of centralized
inspection lanes, or a contractor may be commissioned to design, finance, con-
struct and operate the program. The contractor is selected through a com-
petitive bid process and is monitored by and accountable to the responsible
state agency. A third alternative is to license and certify private service
stations and garages to operate the program using their existing facilities.
These facilities would also be monitored by and accountable to the public
authority responsible for overall program administration. A fourth alternative
is to have a system with some combination of testing at both central lanes and
private garages. In New Jersey, for example, the initial testing is performed
at the state operated lane while the retesting of vehicles is done either at
central lanes or certified garages. Rhode Island's program has testing
done at private garages with a central station run by the state serving as a
referee lane.

Each alternative has its advantages. The private garage approach provides
the greatest convenience to the public. Since inspection and maintenance can
be accomplished with one stop, indirect costs to the consumer are minimized.
Test lanes constructed by governmental authority are designed for high capacity.
This high capacity and the economy of constructing multilane testing centers

22


REFERENCES

Olson Laboratories, Inc. Degradation Effects on Motor Vehicle Exhaust
Emissions. Prepared for the California Air Resources Board. 1976.

Hamilton Test Systems. Short Test Correlation and Effectiveness Study.
Being Prepared for the U.S. Environmental Protection Agency under contract
No. 68-03-2513,

Kincannon, B. F., A. H. Castaline, K. U. Hill, and D. A. Lynn, Viable
Alternative Types of Inspection/Maintenance Programs for St. Louis.
Prepared by GCA/Technology Division for the U.S. Environmental Protection
Agency under Contract No. 68-02-1376, Task Order No. 28. June 1977.

U.S. Environmental Protection Agency, Region I. A Citzens Guide to
Automotive Inspection. 1977.

Michael P. Walsh. The Need For and Benefits of Inspection and Maintenance
of In-Use Motor Vehicles. U.S. Environmental Protection Agency, Mobile
Source Enforcement Division. November 9, 1976.

18


INSPECTION/MAINTENANCE AND THE REPAIR INDUSTRY

The success of an I/M program is heavily dependent upon the quality of the
work provided by the automobile repair industry. Consumer concerns with the
industry include the chance of being exploited and the frustration of being
rejected during reinspection. It is important that maintenance services be
convenient, be of reasonable cost and be of quality workmanship. A great deal

can be accomplished in the latter areas. Programs to improve the quality and
cost of the mechanic's work include: .

e training of emission inspectors
e mechanic training and certification
e repair facility certification

Training of Emission Inspectors

There are two major types of emissions inspectors. The first is the
centralized lane inspector. This individual is employed by the locale or
.contractor to perform vehicular emission tests. His competence should be
demonstrated by completion of a training program or examination, The emission
inspector must be knowledgeable of such things as the operation and care for
the inspection instrumentation, type and operation of emission control devices
and engine components which contribute to excess emissions of HC and CO, and
other test procedures; for example, safety and smoke detection. An EPA spon-
sored program conducted by Colorado State University developed an Emissions
Inspectors Course for the training of emission inspectors. This course has
been adopted by many vocational schools and community colleges, and has been
used by I/M program personnel to train their inspectors.

The private service station inspector is the second group. Typically,
these inspectors would be the mechanics who work regularly at these automobile
repair facilities. These mechanics must become familiar with the above men-
tioned topics. The Colorado State University program is also applicable as
an instructional program to qualify mechanics as emission inspectors. The
proper training and certification of inspection personnel facilitates an ob-
jective and competent emission testing of motor vehicles.

Mechanic Training and Certification

Mechanic training increases the efficiency of the repair industry per-
formance and is prerequisite to the effective testing and proper maintenance
of vehicles, Familiarity with the emission test procedure and equipment pro-
motes objective and competent testing as well as insuring that emission test-
ing is uniform and consistent among stations. Mechanics need to understand
the functioning and maintenance of emission control devices in addition to

knowing which engine parameters affect emissions and how to tune minimize
emissions,

Mechanic training helps alleviate the problems of ineffective repairs and
excessive repair. The latter is caused by overadjustment by an uniformed

mechanic in an effort to avoid missing the problem. For instance, California

30


Instrumentation:

125 specially modified Sun "EET 910" analyzers w/color~
coded scales and pass/fail lights.

Replacement equipment purchase budgeted for FY78.

Data Collection: Records kept for initial emissions test. Initial

Mechanic Training:

Waiting Times:

refailure rate of 40 percent had dropped to 18 percent
during Phase I. Phase II refailure rate has stabilized

at 25 percent. NJDEP also conducts periodic surveillance

on groups of 1000 vehicles.

Training program to be conducted at vocational schools
starting fall 1977. Program instructors trained
during spring 1977.

Plans to certify mechanics thorugh NIASE. Exxon has
already conducted mechanic training for emissions,
affecting about 15 percent of all service stations
in state.

Major delays predated the advent of emission inspection
and continued into both emission Phases I and II. Delays
cause many vehicles to needlessly fail the CO emissions
test because of the "hot idle" effect. These vehicles

return to be retested for CO, making waiting lines even
longer.

Problems (other): Two year exemption for new cars means approx. 30,000

Achievements:

miles pass before cars are first inspected. Lack of
capital - capacity improvements cannot be made.

DMV resistance to the incorporation of Phase III

standards. Refailure rate has stabilized at 25 percent -

considered unsatisfactory.

Nation's longest ongoing I/M program. Thirteen percent
improvement in ambient CO readings since program began.
This reduction is holding. Four thousand, two-hundred
garages have installed exhaust analyzers (as of January
1977). This number has risen with the inception of the
private garage reinspection program.

54


Enforcement
Base standard tolerance, %
& through June, 1977

MERCURY - see FORD MOTOR COMPANY
MERCEDES-BENZ

1975 and 1976 noncatalyst, 4 cyl 1.0
1975 and 1976, all other 0.5
1973 through 1974 2.0
1972 4.0
1968 through 1971 5.0
pre-1968 6.0
Diesel Engines (all years) 1.0

MG - see BRITISH LEYLAND
OLDSMOBILE - see GENERAL MOTORS
OPEL

1975 and 1976

1973 through 1974

1970 through 1972

1968 through 1969
pre-1968

DwWwwne
ooounw

OrRPFFO
wooou

PANTERA - see FORD MOTOR COMPANY

PEUGEOT
1975 and 1976 1.5 0.5
1971 through 1974 3.0 1.0
1968 through 1970 4.0 1.0
pre-1968 6.0 0.5
Diesel Engines (all years) 1.0 0.5

PLYMOUTH - see CHRYSLER CORPORATION

PLYMOUTH CRICKET - see CRICKET, Plymouth

PONTIAC ~ see GENERAL MOTORS

PORSCHE
1975 and 1976 2.5 0.5
1972 through 1974 3.0 1.0
1974 Fuel Injection'1.8 liter (914) 5.0 1.0
1968 through 1971 5.0 1.0
pre-1968 6.5 0.5

72


can result in lower inspection costs. In addition a central test lane approach
lends itself to simplied data handling and greater qualit control. A private
firm contracted by governmental authority to construct and operate the facili-
ties reduces the financial burden of raising public funds for capital investments

EMISSION TESTING INSTRUMENTATION

The emission testing instrumentation required is dependent upon the emis-
sion testing procedure selected for use. As mentioned previously, an idle mode

test requires only an exhaust gas analyzer while the loaded mode test has the
additional requirement of a chassis dynamometer.

Exhaust Gas Analyzers

The exhaust gas analyzer is central to the objectives of an Inspection and
Maintenance program. The instrument must be reliable and be easily calibrated
in order to assure the quality of emission testing. Accuracy and repeatability

of all inspection lane and repair industry analyzers is crucial to system
efficiency.

The use of the basic analyzer is quite simple. A probe is inserted into
the vehicle tail pipe. Sensors on the probe detect the presence of pollutants
in the vehicle exhaust and relay their relative quantities to the analyzing
mechanism of the instrument. The actual pollutant concentrations are then
displayed by two meters located on the instrument's face. One meter indicates

the carbon monoxide concentration, and the other the concentration of hydro-
carbons in the vehicle exhaust.

The potential for significant variability in emission measurements exists
among instruments manufactured by either the same or different manufacturers.
Because of this variability, basic specification criteria have been developed
to minimize the effects. Various public agencies have performed analyzer

certification programs, distributing to the repair industry and others their
lists of approved exhaust gas analyzers.

As with other types of analytic equipment, periodic maintenance and cal-
ibration is essential if accurate measures of emissions are to be obtained
from the analyzer.

Chassis Dynamometer

A chassis dynamometer is required, in addition to an emission analyzer,
if a loaded mode test is performed. The dynamometer consists of two rollers,
upon which a vehicle's driving wheels are placed. As the wheels of the vehicle

are rotated, the dynamometer produces a drag on the engine, thus simulating
actual on-the-road operation.

24


c.

Modifications to Motor Vehicle Emission Inspection Program.

Chapter 182, House Bill 2080. State of Arizona, 32nd
Legislature, 2nd Regular Session. Approved by Governor on
June 29, 1976.

3. Providing for Referendum for Repeal of Motor Vehicle Emission In-
spection Program. Chapter 167, Senate Bill 1203. State of
Arizona, 32nd Legislature, 2nd Regular Session. Approved by
Governor on June 27, 1976.

4. Publicity Pamphlet— 1976. State of Arizona. Proposition to be
Submitted to the Qualified Electors of the State of Arizona at
the General Elections November 2, 1976. Compiled and Issued by
Wesley Bolin, Secretary of State.

5. Regulating Vehicle Fleet Emission Inspection and Inspection
Stations. Chapter 85, House Bill 2313. State of Arizona, 32nd
Legislature, First Regular Session. Signed by Governor on
May 22, 1975.

6. Vehicle Emissions Program Operating Rules and Regulations.
Arizona Department of Health Services. 1975.

California

1. Assembly Bill No. 723. Air Pollution: Motor Vehicle In-
spection. February 6, 1975. Amended in Assembly March 31, 1975.

2. Assembly Bill No. 4161. Air Pollution: Motor Vehicle In-
spection. March 22, 1976. Amended in Assembly May 3, 1976.

3. Assembly Bill No. 4161. Air Pollution: Motor Vehicles In-
spection. Amended in Conference August 31, 1976.

4. Senate Bill No. 479. Air Pollution; Motor Vehicles. Approved
by Governor on October 2, 1973.

Chicago

1. Vehicle Emission Testing Ordinance. City of Chicago, Department
of Environmental Control.

Colorado

1. House Bill No. 1245. A Bill of an Act Concerning Motor Vehicles,
and Providing for an Exhaust Emission Inspection Program
Thereof. 1976. (Did Not Pass).

2, Senate Bill No. 231. Providing for the Issuance of Certificates

of Emissions Inspection for Certain Motor Vehicles in Connection

With State Air Pollution Control Activities. Effective
July 1977.

90


allows for certain managerial economies. Typically, the state air pollution
control agency can run an I/M program in conjunction with the department of
motor vehicles or the state police. This limits any major problems involving
overlapping functions. In addition, few additional administrative staff are
required. Approximately nine new hires, including clerical workers, are needed
to administer a centralized I/M program covering approximately one million
vehicles.

In conclusion, I/M would appear to be a very reasonable control measure.
It does not interfere with existing socioeconomic patterns but instead acts
only as an inducement to keep motor vehicles in good operating condition. Of
all of the air pollution control measures, I/M is one of the most intuitively
appealing,


RENAULT

1976 Carbureted

1975 and 1976 fuel injection
1975 carbureted

1971 through 1974

1968 through 1970

pre-1968

ROLLS-ROYCE and BENTLEY

1975 and 1976
1971 through 1974
1968 through 1970
pre-1968

ROVER ~ see BRITISH LEYLAND
SAAB

1975 and 1976

1968 through 1974, except 1972
99 1.85 liter

1972 99 1.85 liter

pre-1968 (two-stroke cycle)

SUBARU

1975 and 1976

1972 through 1974

1968 through 1971, except 360's
pre-1968 and all 360's

TOYOTA

1975 and 1976 Catalyst equipped
1975 and 1976 4 cyl.

1975 and 1976 6 cyl.

1968 through 1974, 6 cyl.

1968 through 1974 4 cyl.
pre-1968

TRIUMPH - see BRITISH LEYLAND

73

Base standard
4’

Enforcement
tolerance, %
through June, 1977

OFFS
uoou


B. As a Transportation Control Strategy

1. Easterline, Mahlon. The Role of Periodic Motor Vehicle In-
spection in Air Pollution Abatement. (Prepared for the 53rd
Annual Meeting of the Highway Research Board. January 1974.)

2. Horowitz, Joel. I/M for Reducing Automobile Emission:
Effectiveness and Cost. U.S. Environmental Protection Agency.
J Air Pollut Contr Assoc. 23(4), April 1973.

3. Horowitz, Joel and Steven Kuhatz. Transportation Controls to
Reduce Automobile Use and Improve Air Quality in Cities: The
Need, the Options, and Effects on Urban Activity. U.S. En-
vironmental Protection Agency. November 1974.

4. Horowitz, Joel. Transportation Controls are Really Needed in
the Air Cleanup Fight. U.S. Environmental Protection Agency,
Washington, D.C. Envir Sci and Technol. 8(9):800-805.
September 1974,

5. IPA, Teknetron Inc., and TRW Inc. Evaluating Transportation
Controls to Reduce Motor Vehicle Emissions in Major Metropolitan
Areas. Prepared for U.S. Environmental Protection Agency,
November 1972.

6. Schwartz, S. I, Reducing Air Pollution by Automobile I/M: A
Program Analysis. University of California, Davis. J Air
Pollut Contr Assoc. 23(10), October 1973.

7.  TRW Inc. Socio-Economic Impacts of the Proposed State Trans-
portation Control Plans—An Overview. November 1973.

*B. 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. Federal Register, 24(84):22177-22183. Monday,

May 2, 1977.

9. U.S. Environmental Protection Agency. Office of Air and
Water Programs. The Clean Air Act and Transportation Controls:
An EPA White Paper. August 1973.

II. TECHNICAL ASPECTS OF INSPECTION/MAINTENANCE

A. Idle Mode Testing

*1. Elston, John C. A Comparison of Nationwide Inspection Program
Idle Emission Data. N. J. Department of Environmental Pro-
tection. (Presented at MVECC-V. Hyannis. October 26, 1976.)

2. Panzer, J. IDLE Emissions Testing. Exxon Res. & Eng. Company.

Paper No. 720937. (Paper Presented at SAE National Fuels and
Lubricant Meeting. Tulsa. November 1972.)

79


SECTION 1

INTRODUCTION

This document presents information on inspection/maintenance programs, a
means of reducing vehicular emissions which has been successfully adopted by
several states. The increased interest in this strategy has led to a need for
an inspection/maintenance primer. It is this need to which this report is
addressed.

The objectives or purposes of this compendium are twofold. First, it is to
provide basic information on a number of both the technical and nontechnical
aspects of I/M and, second, to do so in a manner which is virtually free of
esoteric terms. Such information will hopefully be of use to both policy makers
and interested citizens.

RESEARCH METHODOLOGY

The discussion which follows is based upon a review of literature obtained
from a variety of sources. Among those contacted were the following:

e agencies and individuals responsible for the planning, im-
plementation, operation, and analyses of existing and proposed
I/M programs for various locales throughout the country;

e individuals at private facilities responsible for the conduct
of research programs involved with the technical issues of I/M;

e manufacturers of vehicle emission inspection instrumentation;

e individuals at those federal, state, and local government agencies
responsible for enforcement, technical, and policy issues.

From the articles, data, and miscellaneous information thus obtained,
key topics were selected for review. The resulting discussions present the
major elements essential to the understanding of each of the topics covered.

REPORT ORGANIZATION

The report is organized as follows. Section 2 discusses the purpose of
inspection/maintenance programs and Section 3 presents the benefits which re-
sult from their implementation. The various approaches to I/M programs are
discussed in Section 4. The implementation of I/M programs is presented in
Section 5, Section 6 discusses some of the problems associated with I/M.


INSPECTION AND MAINTENANCE BIBLIOGRAPHY

I. OVERVIEW OF INSPECTION/MAINTENANCE

A.

General

1.

Automotive Industry Coordinating Committee to Conserve Energy.
The Need for a Nationwide System of Comprehensive Periodic
Motor Vehicle Inspection. Teaneck, New Jersey. 1976.

Calhoon, Joseph C. Experience With Inspection and Maintenance
Programs: A Manufacturer's Viewpoint. Environmental Activities
Staff. General Motors Corporation. (Presented at NVECC-IV.
Anaheim. November 1975.)

Castaline, Alan H. and Benjamin F. Kincannon. An Overview of
Inspection/Maintenance Issues. GCA Corporation, GCA/Technology
Division, Bedford, Massachusetts. (Presented at 15th Annual
Purdue Air Quality Conference. Indianapolis. November 9,
1976.)

Collins, Frank and Gerald J. Thurson. State Inspection of
Automobiles to Monitor the Performance of Exhaust Gas Emission
Control Systems. (Presented at the 40th National Conference of
the Opinion Research Society of America.)

Gorman, George J. I/M Program Checklist. U.S. Environmental
Protection Agency, Region III, Philadelphia, Pennsylvania.
PB 247825. 1975.

Hamilton Test Systems. A Pocket Guide to Emissions Inspection.

Hamilton Test Systems. A Pocket Guide to Periodic Motor Vehicle
Inspection.

Meltzer, J., et al. A Review of Control Strategies for In-Use
Vehicles. Aerospace Corporation, California, for U.S. Environ-
mental Protection Agency. Emission Control Technology Division.
PB 241768. December 1974.

77


He

6,

8.

Elston, John C. New Jersey's Automotive Emission Inspection
Program. (Presented at Second North American Conference on
Motor Vehicle Emission Control. Denver. September 1973.)

New Jersey Department of Environmental Protection. New Jersey
Motor Vehicle Emission Inspection Program Summary and Report—
Phase I. Trenton, New Jersey. June 1976.

New Jersey Department of Environmental Protection. Your Car and
Its Pollution Test. Plain Facts About New Jersey's
Environment. 1975.

New Jersey Checks Auto Exhaust. Environ Sci Technol. 6(9):785,
September 1972.

Portland, Oregon

1.

Beck Consultants, Inc. A Study of the Development of the Oregon
Department of Environmental Quality Motor Vehicle Inspection/
Maintenance Program. Prepared for U.S. Environmental Protection
Agency, Region X. September 1974.

GCA/Technology Division. Analyses of Traffic and Air Quality
Trends, TCP Effectiveness, and a Voluntary I/M Program in
Washington and Oregon. Prepared for U.S. Environmental Pro-
tection Agency, Region X. May 1975.

Householder, Ronald C. Oregon's Motor Vehicle Emission Control
Inspection Program. Administrator, Vehicle Inspection Program
Oregon Department of Environmental Quality. (Presented at
MVECC-IV. Anaheim. November 1975.)

Oregon Department of Environmental Quality. Inspection Testing
Statistics. July 1975 to July 1976.

Oregon Department of Environmental Quality. Does Your Car Have
to be Inspection? Information Bulletin No. 76050.

Oregon Department of Environmental Quality. Summary of
Definition and Standards. March 28, 1975.

Oregon House of Representatives. Report of the House Task Force
on Auto Emissions Control. April 1976.

Oregon Environmental Quality Commission. Motor Vehicle Emission
Control Inspection Test Criteria, Methods, and Standards.
March 1975.

U.S. Environmental Protection Agency, Region X. Oregon Trans—
portation Control Plan Technical Support Documents. October
1973.

88


Mechanic Training: No formal Program as such but for mechanics to be

licensed as "Approved Inspector", they must provide
documentation of automotive schooling and experience,
must be qualified to operate emissions analyzing
equipment, and pass written examination.

Station Licensing: To become an "Authorized Station" to perform emission
test, a station must employ an "Approved Inspector,"

own proper tools and equipment for performing test
and present a $1000 surety bond.

Waiting and Test Time: No problems. During change of ownership phase
most vehicles are conveyed by dealers who perform
inspection and required adjustments as routine
task of vehicle preparation. Nevada inspection
requires about 15 to 20 minutes.

Problems: Minimal.

Achievements: Consumer complaints have been minimal. Unique combination
of inspection testing and check and adjustment of primary
manufacturer's specification settings. Most vehicles attain
at least some improvement in terms of performance, emission
reductions, and fuel savings.

D.M.V. control of licensings of stations and inspectors
including regular visits to check station performance,
tools and emission analyzing equipment.

56


Data Collection:

Records kept on volumes passing and failing only.
Percent of vehicles not meeting standards are as follows:

1975 | 1976 1977"
% ’ %

Cincinnati | 21.5) 16.9
Norwood 31.8) 19.7 }17.6

*
First quarter.

Mechanic Training: No formal program, but Colorado State University

conducted a course for Cincinnati metropolitan
area vocational education instruction in June 1976,

Waiting Time: No major problems,

Problems:

Woefully low throughput caused by no enforcement and lack of
“tradition of inspection," caused Hamilton County to cease
operations February 1, 1976,

Lack of phase~in period and adequate PR caught public by
surprise, Complaints that Kentucky commuters should be
tested, (Kentucky established a voluntary program in the
three northern Kentucky counties of Boone, Campbell, and
Kenton on December 1, 1977. One state owned van visits
shopping centers in order to stimulate car owners'
participation.)

Achievements: Demonstrated short lead time adding I1/M to existing safety

program,

With improved enforcement, approximately 90 percent of
registered LDV's in Cincinnati compiled with I/M require-
ments during 1976,

52


91

4 emissions

RAPID LINEAR SLOW
DETERIORATION DETERIORATION DETERIORATION

—» TIME

Figure 1. Possible post maintenance deterioration functions.


SECTION 7

FACT SHEETS ON EXISTING INSPECTION/MAINTENANCE PROGRAMS

The following pages present information on existing I/M programs. Both
technical and nontechnical topics are included. Thé information is current
as of September 1977,

43


Enforcement ;

Phase I - not applicable.

Phase II - changes in registration (buying, moving into
state, etc.) cannot be made without passing
inspection.

Phase III - annual renewal of registration and changes in
registration cannot be made without passing
inspection.

Instrumentation: For Phase I, most analysis equipment, including dyna-

mometers, was manufactured by Autoscan. System uses
computer data processing.

Data Collection: Odometer readings and vehicle age along with tailpipe

concentrations fo CO, HC, and NOx. Computer hookup

(to tailpipe and engine) permits instant diagnosis,
with three-mode analysis of emission readings. Vehicle
owner is provided with printout, indicating probable
cause of malfunction and recommended service action.
About 30 percent of the vehicles tested during Phase I
did not meet standards. Data collection during Phase II
will utilize highly automated techniques.

Accompanying Phase I was a surveillance program involving
650 vehicles. Results of this effort include program
effectiveness, and "technical effectiveness" (vehicle
thruput, waiting times, etc.). These results were used
to help identify required elements for the proposed
Phase II program.

Mechanic Training: California has a program of mechanic licensing.

Waiting Time:

Under Phase I, a “certificate of qualification" was
required of mechanics to perform repairs resulting
from the I/M program. These mechanics had to attend
an orientation seminar and either:

(a) possess a California "Class A" mechanic's
license, or

(b) pass a written examination.
Currently developing master plan to qualify mechanics
in the S.C.A.B. prior to Phase II.

No problems during Phase I where demand was kept uniform by
mailing out notices to 450 to 500 vehicle owners daily
(chosen at random by computer). The owner then had 2 weeks
from date of postmark to bring in his vehicle.

Total inspection time is about 7 minutes.

Waiting time objective for Phase II is less than 10 minutes
for most vehicles and an absolute maximum of 20 minutes
during peak periods.

47


APPENDIX B

BIBLIOGRAPHY

The bibliography is broken down by major topics. An asterisk (*) denotes
a recommended source. It is recommended that these reports be read first
when seeking information on inspection/maintenance.

76


TABLE 1. STATUS OF STATE MOTOR VEHICLE ANTITAMPERING LAWS*

Antitampering law Antitampering law

State Yes No State Yes No
Alabama x Nebraska x
Alaska x Nevada x
Arizona x New Hampshire x
Arkansas x New Jersey xk
California x New Mexico x
Colorado x New York x
Connecticut x North Carolina x
Delaware x North Dakota x
Florida x Ohio x
Georgia x Oklahoma x
Hawaii x Oregon x
Idaho x Pennsylvania x
Illinois x Rhode Island x
Indiana x South Carolina x
Towa x South Dakota x
Kansas x Tennessee x
Kentucky x Texas x
Louisiana x Utah x
Maine x Vermont x
Maryland x Virginia x
Massachusetts x Washington x
Michigan x West Virginia x
Minnesota x Wisconsin x
Mississippi x Wyoming x
Missouri x District of
Montana x Columbia x

——
This information is current as of September 1977.


Location: Cincinnati and Hamilton County, Ohio

Type of Program: Municipally-operated permanent facilities, idle mode,
mandatory inspection and maintenance.

Sites: Cincinnati - One site, four lanes, includes safety inspection.
Norwood - One site, one lane, includes safety inspection.

Hamilton County - Two sites (Newtown and Glenway), three lanes
total, no safety inspection.

Chronology: Fully mandatory I/M began in Cincinnati and Norwood on
January 1, 1975, with no voluntary phase-in periods. Newtown
began operation 8-75 and Glenway 9-75. Operations ceased at
Newtown and Glenway, February 1, 1976.

Geographic Coverage: Eventually the whole of Hamilton County, about
500,000 LDV's.

Administering Agency: Individual local governments.

Area Contact: Marion Smith, (513) 352-4880 (Cincinnati APCD)
None (513) 632-8222 (Hamilton County Commissioners)
Rick Hogan, (502) 564-6798 (Kentucky DAP)

Capital Cost: (Cincinnati) $12,600 for 9 analyzers - inspection facilities
already in operation for safety.

Operating Cost: (Cincinnati) $130,000 for 11 additional positions.
Cost to Motorist: $3.75, including safety,

Standards: Same as Chicago, four-stage standards dependent on model year
stringency factor 25 percent in 1975 and 18 percent in 1976
and first quarter of 1977.

Enforcement: (Cincinnati) Vehicle cannot be registered by city (sticker
issued) unless inspection is passed. City Division of Air
Pollution Control has four vehicles issuing tickets on a
limited basis, Enforcement was initially inadequate due to
lack of Police Department backing and difficult due to the
inability to distinguish between Cincinnati vehicles and
Hamilton County commuter vehicles. However, during 1976 en-
forcement was stepped up with nearly 80,000 citations issued
by Cincinnati and Norwood police.

(Hamilton County) No enforcement program, Recently cited by
Federal Government with court action pending.

Instrumentation: Sun #910 I analyzers modified with color-coded scales
and pass/fail lights, Cincinnati has 9 of these,
Norwood 2, and Hamilton County 4,

51


Preface ..
Abstract .
Figures ..
Tables ..

CONTENTS

1. Introduction «6 6 6 ee ee ee eee wee ee eee

Research Methodology . .. + + se eee eee eee
Report Organization . . od

2. Purpose of Inspect ion/Maintenance Programs. .. +. e+ ees

References . ss ee ee ee ee ee ee ee ee

3. Benefits of Inspection/Maintenance Programs .... .

Program Determinants of Emission Reduction Potential
Emission Deterioration. .......-. see
Cost Effectiveness of Inspection/Maintenance we ee
Warranty Provisions. . . 1. 6 6 ee we ee we we ewe
References... 6 1 eee ee ee ee ee ee es

4. Alternate Approaches to Inspection/Maintenance. .... .~

Types of Inspection Approaches ...... e+e eee
Emission Testing Instrumentation. ......+4-e-.
Emission Maintenance Requirements. ... eee
Inspection/Maintenance of Heavy-Duty Vehicles. wee
Inspection/Maintenance and the Repair Industry .. .
References . 1. 1 6 1 ee eee ee eee ee ee

5. Implementation of Inspection/Maintenance Programs ... .

Legal Authority. 2. 6 6 1 ee eee ee ee ee we
Administrative Factors . 1.6 ss ee ee ee eee

6. Inspection/Maintenance Problem Areas .......e ees

Quality Control of Private Garages ..... se
Adequacy of the Repair Industry to Perform Emissions
Related Work... 1 ee ee ee ee ee ee ew
Combined Safety and Emissions Testing. .......
Impact of Waiving Repair Requirements for Certain
Vehicles .. 2... 56s re ry

7. Fact Sheets on Existing Inspect ion/Maintenance Programs .

Appendices

A. Compilation of Emission Standards for I/M Programs. . . .
B. Bibliography... 1. ee eee eee ee ee ee ee
Cc. Glossary . 6 6 ee ee ee ee ee ee we ee

62
76
93


MG
1976 MG
1975 MG, MG Midget and 1976
MG Midget
1973 through 1974 MGB, MGBGT, MGC
1971 through 1974 Midget
1972 MGB, MGC
1968 through 1971, except 1971 Midget
pre-1968

Rover
1971 through 1974
1968 through 1970
pre-1968

Triumph
1975 and 1976
1971 through 1974
1968 through 1970
pre-1968
BUICK - see GENERAL MOTORS
CADILLAC - see GENERAL MOTORS
CAPRI - see FORD MOTOR COMPANY, 4 cyl.
CHECKER
1975 and 1976 catalyst equipped
1973 through 1974
1970 through 1972
1968 through 1969
pre-1968
CHEVROLET - see GENERAL MOTORS
CHEVROLET L.U.V. - see L.U.V., Chevrolet

CHRYSLER - see CHRYSLER CORPORATION

Base standard
%

DuUPww NO
ou

MWoooo

aus
ooo

DAEwN
UouNnd

DAwWNbO

ouuouw

CHRYSLER CORPORATION (Plymouth, Dodge, Chrysler)

1975 and 1976 noncatalyst

1975 and 1976 catalyst equipped
1972 through 1974

1969 through 1971

1968

68

NEROR
OuUouUcd

Enforcement
tolerance, %
through June, 1977

OrRRHSO
uUucooun

FPRHROO
USOUN


<4

TABLE 6.

CHARACTERISTICS OF IDLE MODE AND LOADED MODE TESTING

Idle mode testing

Loaded mode:
steady state test

Loaded mode:
transient test

Simple test procedure
which requires minimum
training for inspectors

Carburetor adjustments
can be made during test

Diagnosis of some engine
maladjustments and
malfunctions

Can be duplicated by either
public or private test systems

Requires minimal test time
and equipment

Malfunctions that occur
under loaded conditions
may not be detected

Engine operated under simu-
lated road cruise conditions

Includes idle test

Additional diagnostic infor-
mation to repair facility

Requires dynanometers ~
and other additional
equipment

Test cannot be duplicated
in most repair facilities
due to lack of dynamometer

Requires more test time

Engine operated under simulated

urban driving cycle

Expected to provide closest
correlation with FIP CVS

emissions

Variable inertial and power
absorption dynamometer
required

Driving cycle difficult to
repeat accurately: cycles
cannot be averaged

Test cannot be duplicated in
most repair facilities

’ Computer needed for rapid

on-line data analysis; i.e.,
high initial costs



8. Oregon Light Duty Motor Vehicle Emission Control Idle Emission Standards.

This section is in three parts. The first section specifies idle carbon
monoxide limits, the second specifies idle hydrocarbon limits, and the third
specifies maximum smoke levels.

(1) Carbon Monoxide idle emission values not to be exceeded:

Enforcement
Base standard tolerance %
a through June, 1977

ALFA ROMEO

1975 and 1976 1.
1971 through 1974 3.
1968 through 1970 4
pre-1968 6

COrPRR
Uuced

AMERICAN MOTORS CORPORATION

1975 and 1976 noncatalyst 1
1975 and 1976 catalyst equipped 0
1972 through 1974 2
1970 through 1971 3
1968 through 1969 5
pre-1968 6
Above 6000 GVW, 1974 through 1976 2

HOORFOO
OuNUcoun

ARROW, Plymouth - see COLT, Dodge

AUDI

1975 and 1976
1971 through 1974
1968 through 1970
pre-1968

DENE
ooun
OrFO
Moon

66


the remainder of Oregon. Some evidence of vehicles being re-
adjusted following the passing of inspection due to drive-
ability problems.

Achievements:

Estimated reduction in CO and HC emissions of 14 percent
and 7 percent, respectively, have been achieved during

first inspection cycle.

Many garages are buying analyzers, indicating increased
acceptance. Of all I/M programs, has the most extensive,
and therefore the most equitable standards. Difficulties
in identifying vehicles and their standards have been
minimal.

59


ot

TABLE. 4, FUEL SAVINGS FROM INSPECTION/MAINENTANCE PROGRAMS*

: Annual fuel Dollar savings Annual fuel Dollar savings
Failure * . . . :
rate Savings-serviced per serviced savings—all per vehicle-
vehicles only* vehicle vehicles all vehicles
(x) (y)
(2) (gallons) (%) (gallons)
50% 4.2 36 21.40 2.1 18 10.70
40% 4.73 40 24.00 1.89 16 9.60
30% 5.5 47 28.00 1.65 14 8.40
20% 6.76 57 34.40 1.35 1 6.85
10% 9.66 82 49.30 0.97 8 4.90

¥
All savings based on national averages of 11,500 vehicle-miles per year and
13.58 mpg. Cost of fuel assumed at $0.60 per gallon.

Source: U.S, Environmental Protection Agency. Inspection/Maintenance Binder
of Background Materials. April 1976.


SECTION 5

IMPLEMENTATION OF INSPECTION/MAINTENANCE PROGRAMS

LEGAL AUTHORITY

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 (centrally-located or service station)
should be decided upon. Program objectives, operating rules, program dimen-
sions, and major agency responsibilities should be specified. The conduct
of the initial planning and tradeoff studies should result in the identification
of the technical, social, and economic characteristics of the desired I/M pro-
gram. This aids in the structuring of the legislation.

A considerable period of time can be involved in assuring that such legis-
lation adequately treats all aspects of the desired I/M program. To help ex-
pedite matters, EPA has prepared model I/M legislation formats that can greatly
assist the states in the development of their own legislation. In addition,
other states that currently have legal authority can be used as models. Some
of the provisions that should be considered for incorporation in enabling le-
gislation are:

e Adequate authority to adopt rules and regulations concerning:
— Requirements for periodic inspection

— Establishment of fees for providing the inspection
service

— Withholding vehicle registration for those vehicles
that do not satisfactorily complete the inspection or
that do not comply with an applicable variance

— Prohibition of tampering

e Provisions for providing adequate funds for implementing,
monitoring, and enforcing the I/M program

e Adequate authority to obtain pertinent data and information,
and require periodic reporting of emission information

33


Location: New Jersey

Type of Program: State-operated permanent facilities, idle mode,
mandatory inspection and maintenance. Includes
safety inspection. Failed vehicles may be retested
at certified private garages, for $1.00 certificate
fee plus labor charges.

Sites: 38 sites, 68 lanes, one mobile van (rotates among sites).

Chronology: Inspections began July 1972, with voluntary maintenance
phase. Fully mandatory program commenced February 1, 1974
with Phase I standards. On November 1, 1975, Phase II
standards became effective, and private garage reinspection
began a 2-year trial period. Also beginning on this date
new cars were withheld from inspection for their first 2
yearly re-registrations. Phase III standards, originally
scheduled to become effective on February 1, 1976, were post-
poned until at least January 1978. Phase III now subject
to public hearings and final review.

Geographic Coverage: Entire State of New Jersey (3.9 million LDV's).

Administering Agency: New Jersey Department of Environmental Protection
(establishes standards and technical procedures),
Department of Motor Vehicles (administers testing
and enforces standards).

Staff Contact: John Elston, NJDEP, (609) 292-6714.

Capital Cost: $250,000 for analyzers and related equipment-inspection
facilities already in operation for safety.

Operating Cost: DEP, $330,000/yr
DMV, $1,000,000/yr .
Total $1,330,000/yr

Cost to Motorist: $2.50, taken out of yearly registration fee, includes
safety.
$1, additional fee at reinspection garages for
certificate, garage labor charges extra.

Standards: Phase I - ‘approx. 12 percent stringency factor.
Phase II - approx. 16 percent stringency factor.
Proposed Phase III - approx. 23 percent stringency factor.
All phases are four-stage, dependent on model year.

Enforcement: Vehicle cannot be registered unless inspection is passed.
Enforced by sticker system. Proposed HDV standards to be
enforced on the road (pullover spot check) and at operators
facilities.

53


SECTION 4

ALTERNATE APPROACHES TO INSPECTION/MAINTENANCE

TYPES OF INSPECTION APPROACHES

The following are the five recognized inspection alternatives for an
inspection/maintenance program.

e Idle mode test conducted at state inspection stations.

e Idle mode test conducted at inspection stations operated
by a contractor to the state.

e Idle mode test conducted at privately owned service
stations and garages.

e. Loaded mode test conducted at state inspection stations.

e Loaded mode test conducted at inspection stations operated by a
contractor to the state.

As displayed by the above listing, there are two major features to the
inspection phase of an I/M system. There are the nature of the test and the
way in which the test is administered.

Nature of the Emissions Test

The minimum requirements of an in-use vehicle emissions test are that it
be short, applicable to warmed-up vehicles, and able to identify high emitting
vehicles. Two distinct emission testing procedures which satisfy these criteria
have been developed for measuring exhaust emissions. These are the idle mode
and the loaded mode tests. Table 5 provides a comparison of the short test
procedures. They have been the only short tests used in programs directly
affecting the inspection of vehicles owned and operated by the general public.

*,
Mandatory maintenance, to the extent that it does not require periodic in-
spection of motor vehicles, has been omitted from this list. A mandatory

maintenance program requires that all vehicles undergo specific maintenance
procedures designed to ensure compliance with emissions standards. The main-
tenance is performed by authorized garages.

19


9.

Vehicle Inspection Program Branch, Bureau of Automotive Repair.
California Vehicle Inspection Program, Riverside Trial Program
Report (Operations From 9/2/75 to 2/13/76)— Volumes 1 and 2,
Summary Report. May 1976.

VIP Information Packet, Information Used at the Riverside In-
spection Facility or Issues to the Public. 1976.

C. Chicago, Illinois

1.

Poston, H. W. The Chicago Vehicle Exhaust Emission Control
Program. (Presented at Second North American Conference on
Motor Vehicle Emission Control. Denver. August 1973.)

Poston, H. W. and J. Seliber. Chicago's Experience in Vehicle
Emission Testing. Department of Environmental Control. City
of Chicago. Paper No. 760368. (Presented at SAE Automotive
Engineering Congress. Detroit. February 1976.)

Poston, H. W. The Chicago Experience— Two Years Later. D. E. C.
City of Chicago. (Presented at MVECC-IV. Anaheim. November
1975.)

Poston, H. W. and Joseph Seliber. Chicago's Emission Testing
Program- 1976. City of Chicago, Department of Environmental
Control. (Presented at MVECC-V. Hyannis. October 26, 1976.)

D. Colorado

*1,

Automotive Testing Laboratories, Inc. An Analysis of the
Practical Application of an I/M Program in the Public and
Private Sectors (Draft). Prepared for the Colorado Department
of Health.

Colorado Air Pollution Control Commission. Report to the
Governor— 1975.

Colorado Air Pollution Control Commission Regular Meeting
Minutes. Colorado Department of Health. February 26, 1976.

Colorado Air Pollution Control Commission Regular Meeting
Minutes. Colorado Department of Health. March 29, 1976.

Colorado Air Pollution Control Commission Briefing— Testing
Program Results on Catalytic Equipped 1975 Model Year Vehicles.
Appendix to Commission Meeting Minutes. February 26, 1976.

Colorado Air Pollution Control Commission. Motor Vehicle Emis-
sion Control Program. 1973.

Colorado Air Pollution Control Commission. Motor Vehicle Emis-
sion Control Program. 1974.

86


the price of repair work is not insignificant to 4 given household in many, in-
stances, In addition, automobiles in the past have been tuned more for pér-
formance than for meeting emissions standards, Having the latter as the goal
may necessitate some adjustments on the part of mechanics. In short, an I/M

program requires that some effort be made to change the climate in which these
perceptions evolved.

There exist several options to ensure that the repair industry is versed.
in emission related work, The first of these options is the offering of
courses in automobile emissions in vocational training schools. Colorado State
University, under contract to EPA, has developed the materials for such a ©
course. Consisting of colored slides with accompanying script, the material
covers the causes of excessive emissions and presents solutions to the exist-
ing problems, Such a course is of value to both would be mechanics as part
of their overall training and to experienced mechanics as a refresher course
in emission related work, The information, in addition to being offered
solely in vocational schools, could also be presented in the form of workshops
or seminars, California, for example, has offered workshops utilizing mate~
rial that have developed. Of relatively short duration, (e.g., 8-32 hours)
workshops can both acquaint the repair industry with the I/M program and
present basic emissions related information.

A second way of ensuring the adequacy of the repair industry is to certify
repair shops performing emission related work, New Jersey has established ~
such a system, In New Jersey, a motorist whose vehicle fails to pass the
emissions test has the option of returning, after repairs, for a retest at a
central inspection facility. There is no additional charge for the retest,

As an option, the motorist may take his vehicle to a repair facility certified
by the state to perform the retest, While there is a charge with this second
option, the motorist reduces the risk of receiving inadequate repair work

on his vehicle. While an individual can have his emission repair work per-
formed anywhere he prefers, the certification of some repair facilities serves
as a guide to those vehicle owners unsure of where to have the work done.

Lastly, the adequacy of emissions related repair work can be guaranteed,
This simply means that inadequate repair work be rectified without any additional
charge to the consumer, While this option is understandably the least popular
of the three alternatives mentioned, at least one state, California, has
experimented with this approach,

COMBINED SAFETY AND EMISSIONS TESTING

A total of 31 states and the District of Columbia require periodic safety
inspections of registered vehicles, An additional 12 states have spot or
title transfer safety inspection programs. These systems vary in terms of
what is inspected, who performs the inspection, and the frequency of the
inspection, The systems usually inspected include wheel assemblies. tires.
suspension system, steering and braking systems, Of the states having a
periodic inspection, 25.do so annually and 7 inspect vehicles on a semi-annual
basis. Thirty-three states use service stations or garages, licensed by the
state for inspection while five states have state operated programs. There

40


5.  Paulsell, C. D. and Ronald E. Kruse. Test Variability of
Emissions and Fuel Economy Measurements Using the 1975 Federal
Test Procedure. U.S. Environmental Protection Agency. SAE
Transactions, Volume 83, Section 4, Paper No. 741035. 1974.

6. U.S. Environmental Protection Agency. Effectiveness of Short
Emission Inspection Tests in Reducing Emissions Through
Maintenance. EPA-460/3-73-009. 1973.

7. Williams, Marcia E. Computer Simulation of Emission Inspec-
tion Procedures— Assessment of Effectiveness. U.S. Environ-
mental Protection Agency. Paper No. 760555. (Paper Presented
at SAE Fuels and Lubricants Meeting. St. Louis. June 1976.)

III. ENGINE DETERIORATION

1.

2,

Automotive Testing Labs, Inc. Report on a Study of Emission
Deterioration and Engine Degradation. Prepared for State of
Colorado. 1974.

Olson Laboratories, Inc. Degradation Effects on Motor Vehicle
Exhaust Emissions. Prepared for California Air Resources Board.
1976.

Iv. BENEFITS ASSOCIATED WITH INSPECTION/MAINTENANCE

A.

Emissions Reduction

1. Calspan Corp. Automobile Exhaust Emission Surveillance: A
Summary. Prepared for U.S. Environmental Protection Agency.
May 1973.

2. Maugh, Roger E. Comments on the Changing Relationship Between
Automotive Maintenance and Air Quality. Assistant Director
Automotive Emissions Office, Ford Motor Company. (Presented at
MVECC-IV. Anaheim. November 1975.)

*3. Panzer, J. Effectiveness of Maintenance in Reducing Emissions.

Exxon Research and Engineering Company. (Presented at MVECC-
III. San Antonio, September 25, 1974.)

4. Stanford Research Institute. CO Emission Reduction Potential
of Proposed Washington State Certified Maintenance Program.
Prepared for U.S. Environmental Protection Agency, Region X.
January 1976.

5. U.S. Environmental Protection Agency. Air Quality Impact of
Alternative Emission Standards for Light Duty Vehicles.
March 1975.

6. U.S. Environmental Protection Agency. Tradeoff Associated With
Possible Automobile Emissions Standards. February 1975.

81


Instrumentation:

Data Collection:

29 Sun "OEA 75" analyzers with digital readout of HC, CO,
and C02, and with remote viewing gauges. Systems are
fully computer compatible, but are not computer controlled
at this time. For supplementary data generation, two
Clayton and two Autoscan dynomometers are used. Oregon
State University has CVS testing capabilities.

Actual stringency factor, July 1975 to March 1977, was
36 percent. Survey of 3570 vehicles during February to
March 1977 found refailure rate of 22 percent, up from
16 percent reported earlier.

Record kept of all emission readings. Readings are taken
at idle speed, 2500 rpm (intended mainly as precondition-
ing), and then again at idle, with the lower of the idle
readings governing.

Mechanic Training: Emission-related tune-up course at Clackamas Community

College, in response to Oregon I/M. EPA Region X
assisted with funding through DEQ. Several hundred
enrollees in the past 2 years.

An increase in training by major service station parent
organization has been noted. Other community colleges
and vocational school have established self-initiated
training programs. DEQ is proposing to conduct mechanic
training seminars.

Waiting Time: Systemwide average waiting time approximately 15 minutes

during 1976 ("on" year). Total inspection time averages
3 minutes.

Other Aspects:

Inspections tied into biennial motor vehicle registration
system. Even numbered years are "on" years with approxi-
mately 80 percent of LDV registrations due for renewal,
and odd numbered years are "off" years with remaining 20
percent due for renewal. Inspection stations were opened
7 days/week during 1976 with 75 emission inspectors on
payroll. During 1977, stations opened 5 days/week,
Tuesday through Saturday. Only 23 emission inspectors
required to inspect "off" year (1977) demand, Licensed
private fleets (more than 100 vehicles) may inspect them-
selves. Inspection of HDV's proposed for 1978.

Problems: The 2-year inspection interval hurts program effectiveness.

cash

flow, and creates personnel problems. It will be at

least July 1977 before interval can be shortened legislatively.
(No action expected at this time). Public criticism of "lack
of uniformity" - Portland area residents feel that commuters

from

Washington State should be tested, as well as vehicles in

58


7. U.S. Environmental Protection Agency. Automobile Exhaust
Emission Surveillance: Analysis of the FY 1973 Program. 1975.

B. Fuel Economy

1.  Clewell, D. H. and W. J. Kuckl. Impact of Automotive Emissions
Regulations on Gasoline Demand. Mobile Oil Corporation and
Mobile Research and Development Corporation. Paper No. 73015.
(Paper Presented at SAE Energy and the Automobile Conference.
Detroit. May 15, 1973.)

2. Elston, J. C. Criteria for Evaluating Vehicle In-Use Inspection/
Maintenance Impact on Emissions and Energy Conservation. New
Jersey Department of Environmental Protection. Paper No. 730522.
(Paper Presented at SAE Energy and the Automobile Conference.
Detroit. May 15, 1973.)

*3, Oberdorfer, Dr. P. E. Reducing Fuel Consumption and Emissions
by an Optimizing Tune-Up. Sun Oil Company. (Presented at
MVECC-IV. Anaheim. November 1975.)

*4. Panzer, J. Fuel Economy Improvements Through Emissions I/M.
Exxon Research and Engineering Company. Paper No. 760003.
(Paper Presented at SAE Automotive Engineering Congress.
Detroit. February 1976.)

Vv. ADMINISTRATIVE PROGRAM FACTORS

A. Mechanic Training

l. Gillespy, Dr. Roy E. Motor Vehicle Emission Control Instruc-
tional Material. Colorado State University. Department of

Industrial Sciences. (Presented at MVECC-IV. Anaheim.
November 1975.)

*2. Hayes, B. D. and Roy E. Gillespy. Motor Vehicle Emissions
Control Instructional Materials Packet. Colorado State
University, Department of Industrial Sciences, Fort Collins,
Colorado for U.S. Environmental Protection Agency, Research
Triangle Park, N.C. 1975.

3. Plotkin, A. S. Mechanics Warned on Pollution. Boston Evening
Globe. July 29, 1976.

4, U.S. Environmental Protection Agency. Anticipated Results of

State Participation in the Auto Emission Training Program.
Internal Memo.

B. Economic Considerations

1. Downing, Paul B. An Economic Analysis of Periodic Vehicle In-
spection Programs. Atmos Environ. 7:1237-1246. 1973.

82


TABLE 8. MAJOR CAUSES OF EXHAUST EMISSIONS

Major causes of high carbon monoxide emissions are:

e@ Carburetor out of adjustment
e Air-fuel mixture imbalances

e Malfunction of emission control devices
Major causes of high hydrocarbon emissions are:

e Improper timing
e Ignition system malfunctions

e Malfunction of emission control devices

*
TABLE 9. TYPES OF REPAIRS REQUIRED

Repair type Percent undergoing repair
Carburetor adjustment 78
Tune-up 14

Engine overhaul
Valves
Other

< s -
Reported by Portland, Oregon I/M program.

27


SECTION 2

PURPOSE OF INSPECTION/MAINTENANCE PROGRAMS

Inspection/maintenance (1/M) is a program designed to check pollutant
emission levels of motor vehicles with respect to certain emission standards
and to adjust to those standards or below the vehicles which fail. The result-
ing emission reductions can be an important contribution towards the meeting of
National Ambient Air Quality Standards (NAAQS) for transportation-related
pollutants, Thirty-three Air Quality Control Regions (AQCR's) have been found
by EPA.to need automotive inspection/maintenance (I/M) programs in order to
meet air quality requirements under Section 110 of the Clean Air Act. Recently
acquired data suggests that many more AQCRs may eventually need such programs
to meet the clean air requirements.

Inspection/maintenance is, of course, only one of several options avail-
able for the control of automobile-related pollutants. Given the extent of
air pollution in many areas of the United States, no one measure can be ex-
pected to completely solve a given air pollution problem. Therefore, the key
question to be asked about any given control is not whether it alone can solve
the problem, but rather can the strategy act to reduce pollution in a rela-
tively nondisruptive manner. As discussed below, I/M programs represent a
reliable and common sense approach to cleaner air.

One of the first things to bear in mind concerning inspection/maintenance
is that it supplements the existing Federal Motor Vehicle Emission Control
Program (FMVCP). The FMVCP is composed of the following three primary elements:

e Certification Program - Certification of new vehicles prototypes
to show that they are designed to meet Federal emissions standards.

e Selective Enforcement Auditing - Assembly-line testing to assure
that production copies of vehicles meet standards when new.

e Recall - Requirement that manufacturers recall vehicle types
found through in-use surveillance to fail standards because of
defects in design.

The objective of these programs is to provide consumers with motor vehicles
which can meet emission standards when the motor vehicles are properly main-
tained and operated.

While it is the manufacturers' responsibility to produce motor vehicles
engines with emission control devices and systems with no defects, the warranty


emission testing (in areas having safety inspection done at private establish-
ments) must be included in the list of proposed options,

IMPACT OF WAIVING REPAIR REQUIREMENTS FOR CERTAIN VEHICLES

One of the most commonly voiced fears of I/M programs is that the cost
of repairs necessary to reduce emissions may in some instances be prohibitive.
As a means of alleviating this problem, some have suggested the establishment
of a price ceiling on repair costs. The ceiling, expressed as an absolute
amount and/or a percentage of the book value of the vehicle would exempt
vehicles from having repair work done which exceeded the ceiling.

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 is 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 waving
of repair requirements for certain vehicles.

42


Section 7 provides fact sheets on existing 1/M Programs. A bibliography and
glossary are included as appendices to the report.


mandatory testing, As a consequence of this,

. > the Ari ram
experienced considerable public opposition in & Arizona T/M prog

its early stages.

Careful planning of a voluntary maintenance phase before the full manda-
tory maintenance phase can be very effective in terms of

public with goals and procedures of the program, Public
unintentionally stimulated by having a very high failure rate in the voluntary
phase or by having no voluntary phase at all, Voluntary phases have been used
in a number of programs, including New Jersey, Portland, and Arizona.

familiarizing the
opposition can be

Consumer Protection

Provisions must be made to insure that vehicle owners are protected from
abuses which could appear in the system (e,g., overcharging by repair shops
and unnecessary repairs) just as care must be taken to avoid hardships in
terms of extremely costly repairs or the denial of vehicle registration with-
out due cause. One facet of the consumer protection program is the exemption
of certain classes of vehicles, for example, new cars and antique vehicles,

In addition, some areas have considered a ceiling on the cost of repairs re~
quired for compliance, The ceiling could be either a flat rate or a percentage
of the market value of the vehicle, This would eliminate the potential for
certain vehicle owners experiencing undue hardships.

Finally, some kind of mechanism should be established to handle consumer
complaints concerning overcharging and unnecessary repairs by garages as well
as complaints about the program in general. This consumer affairs office could
also be responsible for the licensing of repair facilities. If too many com-
plaints about any one repair facility are received the consumer affairs office

could investigate and revoke the license of the garage if the claims were
justified.

Consumer Convenience

An I/M program will be more readily accepted by vehicle owners if their in-
convenience in terms of travel and waiting times is minimized. Ideally, the
average distance travelled by a vehicle owner to an inspection station is 5
miles while a 10-mile travel distance is a reasonable objective as an upper

limit. Proximity to local community activity centers is desirable in locating
stations.

For a central test lane configuration, providing the option to retest at
a private garage can reduce consumer travel and waiting time. A vehicle owner

can have his car reinspected at the same facility that performs the repairs
and eliminate a second trip to the test station.

The time period between notification of required inspection and the com-
pliance date should be designed to allow ample time for inspection, mainte-
nance and reinspection. It was Arizona's experience that 30 days was not
enough time; the legislation has subsequently been revised to permit vehicle
inspection during the 90 days prior to registration renewal.

36


gradually improve. It is also believed that secondary deterioration (i.e.,
malfunctions that occur due to the existence of other defects) will decrease
in relative proportion to the extent that defective vehicle components exist
and are identified and repaired properly. Affecting these benefits, is the
possibility of increased tampering in response to driveability problems occur-
ing when the vehicles are adjusted to low emission levels.

To be on the conservative side while not refuting available information,
deterioration over time is assumed to be a linear function. In other words,
the rate of deterioration (grams/kilometer/year) for a given pollutant and
vehicle is constant over time, However, a further study is currently proceed-
ing to collect additional data to confirm or reject present beliefs.

COST EFFECTIVENESS OF INSPECTION/MAINTENANCE
Cost

The costs of inspection facilities vary according to the elaborateness of
the program and the existing nature of any safety program in the area. In
terms of capacity, for a state or contractor-operated program, one idle
mode inspection lane is required for every 30,000 vehicles coming under the
program.” Given the longer time required for a loaded test, one loaded mode
facility is needed for every 25,000 vehicles.? In Arizona, which has a very
elaborate program with loaded mode capabilities, the average capital cost per
inspection lane was approximately $250,000. The program operating cost in
Arizona is $500,000 per year. The Portland, Oregon idle mode program is an
example of a less costly approach. Only one station was actually built for the
program, with construction costing $77,000. Located on a State right-of-way
this station has loaded-mode and safety testing capabilities. The other four
permanent facilities are leased. Four mobile vans are used in addition to the
permanent sites, each van, complete with equipment, costing $40,000. The total
cost of the 29 analyzers purchased for these permanent and mobile facilities
was approximately $200,000. Operating costs in Portland vary from $1.45 mil-
lion in an "on" year, to $0.8 million in an "off" year. Inspection in Portland
is biennial at this time, Other costs mentioned in the fact sheets on exist-
ing I/M programs in Section 7 of this report point up the fact that a wide
range of program costs exist. Whatever they are, however, these costs are
borne by the state or, if a contractor approach is selected, by the private
firm, In either case, however, the operating costs and repayment of the ini-
tial investment would be covered by revenues derived from a fee charged the
motorist having his vehicle inspected. Experience has shown that most inspec-
tions cost between $4 and $10, with the higher figure including both emissions
and safety inspection."

This same range of fees would also apply to a privately-run system where
service stations and garages are performing the emissions test. Here the fee
would be used to offset the cost of an emission analyzer and the labor required
to do the testing.

In addition to the inspection fee, those individuals whose vehicles do

not meet the emission standards will incur repair costs. The available data
show that costs of the repair have been reasonable in those areas where I/M

15


in emissions from the time of repair or tune-up is known as deterioration '
Obviously, once pretune-up levels are reached, further maintenance is required
to offset continued deterioration. Several studies have been conducted in the
area of deterioration, and a fairly broad range of estimates on the length of
time emission related repairs last has resulted.

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, A biannual 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.

Emission Standards--

Most importantly, the I/M emission standards, or "cut points," determine
the overall emission reduction potential of the program. The cut point is the
level of emissions which distinguishes between those vehicles requiring emis-
sions-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 carbon monoxide and
hydrocarbons.

There are two basic concerns that constrain the selection of I/M emission
standards. As mentioned previously. the I/M emission standards determine the
emission reduction potential. As such, I/M standards 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 re-
duction benefits are maximized while impacts to the public are minimized.

Appendix A provides a compliation of emission standards for the existing
I/M programs. Details on specific state I/M programs can be found in the Fact
Sheets of Section 7, Each state currently conducting an I/M program has spent
considerable time and effort, either by conduct of demonstration programs or by
evaluation of standards developed by others, analyzing data to develop an op-
timal set of emission standards. When developing standards, these states were
concerned with achieving certain emission reductions while still gaining full
public acceptance. These standards are continuously being reviewed for appro-
priate revisions.

As stated above, emission reductions achieved with any particular L/M pro-

gram are a result of a combination of the emission reductions obtained through
the optimal selection of various options. Tables 2 and 3 list, for HC and co

10


Number

Number

10

iL

FIGURES

Possible post maintenance deterioration functions . ......

TABLES

Status of State Motor Vehicle Antitampering Laws .,....-s

First Year Percent Emission Reduction of Hydrocarbons Through
Inspection/Maintenance Programs ... ++ ee eevee

First Year Percent Emission Reduction of Carbon Monoxide
Through Inspection/Maintenance Programs . . 1. eee eee

Fuel Savings from Inspection/Maintenance Programs . .. «+ «
Comparison of Short Test Procedures for Emissions Inspection
Characteristics of Idle Mode and Loaded Mode Testing ....
Effect of Engine Component Operation on Emissions .....s
Major Causes of Exhaust Emissions ...
Types of Repairs Required .....
Repair Costs Summary for Existing I/M Programs .......

Extent of States' Consideration of Inspection/Maintenance

vi

12

13
16
20
23
26
27
27
28
35


So

7. Riverside--Loaded

Hi-cruise Lo-cruise Idle

Model No. of

year cylinders HC co HC co NO, HC co
55-65 4 or less 1200 ppm 6.5% 1200 ppm 7.0% 2500 ppm 1900 ppm 8.0%
55-65 5 or more 1000 5.5 1000 6.0 2500 1200 8.0
66-67 4 or less 1200 6.5 1200 7.0 2500 1900 8.0
66-67 5 or more 500 4.0 ‘500 4.5 2500 500 7.0
66-67 5 or more w/AI 500 4.0 500 4.5 2500 400 5.5
68-70 4 or less 600 4.5 600 5.0 2500 650 7.0
68-70 4 or less w/AI 600 4.5 600 5.0 2500 500 5.5
68-70 5 or more 500 4.0 500 4.5 2500 500 7.0
68-70 5 or more w/AI 500 4.0 500 4.5. 2500 400 5.5
71+ 4 or less 500 3.5 500 4.0 2500 600 5.0
71+ 4 or less w/AI 500 3.5 500 4.0 2500 450 3.5
Ti+ 5 or more 400 2.5 400 3.0 2500 350 4.0
71+ 5 or more w/AI 400 2.5 400 3.0 2500 250 3.0

AI = Air Injection


Oz

TABLE 5. COMPARISON OF SHORT TEST PROCEDURES FOR EMISSION INSPECTION
Special test
iota Cycle test : Instrumentation ccati
Short test Cycle description time equipment required Applications to date
required
Idle mode Idle in drive and/or < 30 sec None HC and CO exhaust N.J. Test lane; Nevada,
freewheeling at gas analyzers Portland, Ore.,
2500 rpm Chicago, Cincinnati,
Calif .-roadside:
Calif.-end of
assembly line
Loaded mode: steady Steady-state at high 60 sec Chassis dynamometer HC, CO, and NOx, Arizona, Riverside,
state cruise, low cruise, (single power ab- exhaust gas Calif., Washington,

(Clayton Key mode,
Federal Three mode)

Loaded mode: transient
(NJ/NY composite
cycle, Federal short
cycle)

idle in drive

Consist of acceler-
ations, cruise, de-~
celerations, and
idle in drive

75 to 125 sec

sorption curve)

Chassis dynamometer
(variable inertia
and power absorp-
tion with automa-
tic test settings)

analyzers

CVS sampling sys-
tem — HC, CO,
and NOx gas
analyzers with
computerized
data reduction

D.C, test Lanes



REFERENCES

Kincannon, B. F., A. H. Castaline, K. U. Hill, and D. A. Lynn. Viable
Alternative Types of Inspection/Maintenance Program for St. Louis.
Prepared by GCA/Technology Division for U.S, EPA under Contract No.
68-02-1376, Task Order No. 28. June 1977.


Instrumentation Availability and Cost

The necessary technology for conducting vehicle inspections and required
maintenance has reach a point where a full range of alternate systems are avail-
able. These instruments have been developed by the industry in response to the
recent demand for low cost exhaust analyzers. At the present time, nearly 100
exhaust analyzer models are marketed by more than 25 different manufacturers
and distributors. There are a large number of good instruments available to
the repair industry within a cost range of $2,200 to $2,800 each. States no
longer need to sponsor an extensive instrument development and evaluation effort.

Chassis dynamometers were developed before vehicle emissions testing be-
came necessary and are used for a number of purposes. For example, they are
used to evaluate new and reconditioned engines, braking systems, transmissions
and drive chains, and to measure engine efficiency. Dynamometers are avail-
able from a number of manufacturers at a cost of approximately $10,000 per
unit.

EMISSION MAINTENANCE REQUIREMENTS

The other major aspect of an I/M program is, of course, the maintenance
phase. This involves the repair of those vehicles which were identified during
inspection as high emitters. The quantity of repair work is dependent upon,
in addition to the I/M emission standards, the level of preventive maintenance
provided by vehicle owners. The quality of repair is the responsibility of the
automobile service industry.

Preventive maintenance is required on a regular basis if a motor vehicle
is to remain in top operating condition. The recommended maintenance materials
provided by automobile manufacturers include timetables for the inspection,
maintenance, and adjustment of critical components. The malfunctioning or mal-
adjustment of certain of these components can cause the vehicle to be a high
emitter. Unfortunately, because of oversight or cost considerations, many ve-
hicle owners do not have this preventive maintenance done as scheduled.
Instead, some wait until degradation in vehicle reliability, driveability, or
performance is noticeable. One result of this is that vehicle emissions may
increase. To the extent that many owners do not have preventive maintenance
work performed on their vehicles, more may have to have repair work done until
an I/M program. Thus, an I/M program provides the mechanism for identifying
substandard vehicle operations and provides the impetus for vehicle owners to
maintain the operating efficiency of their vehicles.

It is the responsibility of the automobile service industry to locate and
repair any malfunction or maladjustments in the engine or emission control
system which cause a vehicle to have excessive emissions. Automobile mechanics
must be knowledgeable of and proficient in the use of diagnostic tests in order
to identify any improperly operating engine component or system. Further,
mechanics must also be capable of providing the repair needed to bring a vehicle
into compliance with the I/M emission standards. Obviously, mechanics play a
central role in the maintenance aspect of an I/M program. The possible con-
sequences of having unknowledgeable mechanics include higher than necessary re-
pair bills, lower than anticipated emissions reduction, or a combination of both.

25


GLOSSARY

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 gaso-
line created by the carburetor. Usually expressed as a numerical rela-
tionship 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.

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 load-
ing 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
decelleration.

94


E

Fy,

8,

%

Sorrels, Don. Testing Program Results—1975 Model Vehicles.
Inter-Office Communication, Colorado. Department of Health,
Division of Air Pollution Control. February 6, 1976.

TRW, Inc. Inspection/Maintenance of Light Duty Vehicles in the
Denver Air Quality Control Region. November 1974.

Connecticut

1

2

Connecticut Department of Environmental Protection. Study
Report on Proposed Inspection-Maintenance System. January 1975.

Connecticut Department of Environmental Protection. Connecticut

Revised Transportation Control Plan, Inspection/Maintenance.
1976,

Nevada

1.

*2,

3.

Castaline, Alan H. Inspection and Maintenance in the Nevada
Context. GCA Corporation, GCA/Technology Division, Bedford,
Massachusetts. (Presented at MVECC-V. Hyannis. October 26,
1976.)

Kincannon, Benjamin F. and Alan H. Castaline. Evaluation of the
Nevada I/M Programs. GCA Corporation, GCA/Technology Division,
Bedford, Massachusetts. Prepared for U.S. Environmental Pro-
tection Agency, Washington, D.C. Under Contract No. 68-01-3155,
Task Order No. 6. August 1976.

Nevada Hearings on I/M (Portions). 1975.

New Jersey

1.

Andreatch, A., J. C. Elston, and R. Lahey. New Jersey REPAIR
Project: Tune-Up at Idle. New Jersey Bureau of Air Pollution
Control. J Air Pollut Contr Assoc. 21(12), December 1971.

Andreatch, A. and J. C. Elston. Evaluation of Idle I/M Equip-
ment Network. New Jersey Bureau of Air Pollution Control. SAE
Paper No. 740134. (Presented at Automotive Engineering Congress.
Detroit. February 1974.)

Elston, John C., Anthony J. Andreatch, and Laurence J. Milask.
Reduction of Exhaust Pollutants Through Automotive Inspection
Requirements— The New Jersey REPAIR Project. New Jersey Depart-
ment of Environmental Protection. Bureau of Air Pollution Con-
trol. Second International Clean Air Congress, Washington, D.c
December 6-11, 1970. » D.C.

Elston, J. C. and D. Cowperthwait. New Jersey's Auto Emi
Inspection Program: An Assessment of 1 Year's Mandatory Opece-
tion. Paper 75.42.3. (Presented at APCA, Boston. June 1975 )

87


SECTION 3

BENEFITS OF INSPECTION/MAINTENANCE PROGRAMS

The extent to which an inspection/maintenance program reduces the emissions
from motor vehicles depends uvon the specific features incorporated into the
program. Moreover. the rate at which emissions-related repair work deterio-
rates also how a major bearing upon the magnitude of emission reductions. This
section discusses these two major determinants of the benefits of an I/M pro-
gram. In addition, the costs associated with I/M are presented and a further
benefit is discussed - namely the warranty provisions under the Clean Air Act.

PROGRAM DETERMINANTS OF EMISSION REDUCTION POTENTIAL

Minimal Program Requirements

In order to obtain full emission reduction benefits from an I/M program,
certain minimum requirements must be met:

e All vehicles for which emission reductions are claimed must
receive regular, periodic inspections

e To ensure that failed vehicles receive the maintenance
necessary to achieve compliance with the inspection standards,
they should be required to pass a retest following maintenance

e Quality control measures, such as routine maintenance, calibra-
tion and inspection of all I/M equipment, and routine auditing
of inspection results, must be followed to ensure the reliability
of the inspection system and accuracy of the equipment.

Program Options

Beyond the minimum requirements, various other facets of a program can
influence the emissions reductions to be achieved.

Type of Inspection--

While currently available data indicate no overall difference in the CO or
HC emission reductions obtained through the use of loaded or idle mode testing,
loaded mode testing is considered to be a better indicator of the actual emis-
sions of the vehicle in-use and it provides better diagnostic information. In
addition, a loaded mode emission test has the potential to measure oxides of


APPENDIX C

GLOSSARY

93


TECHNICAL REPORT DATA

(Please read Instructions on the reverse before completing)

1. REPORT NO.

EPA-400/9-78-001

2.

3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE
Information Document on Automobile Emissions
Inspection and Maintenance Programs

5. REPORT DATE

January, 1$78

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S)
Benjamin Kincannon and Alan H. Castaline

8. PERFORMING ORGANIZATION REPORT NO.

GCA-TR-77-14-6(2)

lo. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA Corporation/Technology Division

Burlington Road
Bedford, Massachusetts 01730

10. PROGRAM ELEMENT NO,

2AA635

11, CONTRACT/GRANT NO.

68-01-4458

12, SPONSORING AGENCY NAME AND ADORESS
U.S. Environmental Protection Agency
Office of Air and Waste Management (AW-445)
401 M Street, S.W.

Washington, D.C. 20460

13, TYPE OF REPORT AND PERIOD COVERED
Final Report

74, SPONSORING AGENCY CODE

15, SUPPLEMENTARY NOTES.

Reviewed by the U.S. Department of Transportation

76, ABSTRACT

procedures,
inspection and maintenance programs.

who wish to go into specific topics in greater detail.

benefits and costs;
alternative methods for implementing programs;

inspection/maintenance problem areas; and
summaries of existing programs.

wance

This document is prepared pursuant to Section 108(f)(1)(A)(i) of the Clean
Air Act which requires that information be published on the processes,

and methods to reduce or control motor vehicle emissions through
Included are basic information for
those who are unfamiliar with inspection/maintenance and references for those

Subjects treated include:

legal and administrative considerations of inspection/maintenance;

KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS,

b.IDENTIFIERS/OPEN ENDED TERMS |c.

cosati Field/Group

Automobile engines
Exhaust detection
Exhaust emissions

Automobile emissions

Inspection/maintenance
Mobile source control

Unclassified

18, DISTRIBUTION STATEMENT . ECURITY ,¢ ‘This Ri t) 21. NO, OF P,
Unlimited distribution nclassitied om Report) 104 ‘AGES
20. SECURITY CLASS (This page) 22. PRICE

EPA Form 2220-1 (9-73)

98

+ U.S. GOVERNABAT PRINTING OFFICE, 1979-620-007/3736


Problems: Originally intended to use centralized test lane approach
operated by a private contractor,

Achievements: Program initiated and supported by Governor and RIDOT with
backing from Executive and Legislature Branches,

61


Enforcement
Base standard tolerance, %
% through June, 1977

AUSTIN - see BRITISH LEYLAND
BMW

1975 and 1976 1.5
1974, 6 cyl. 2.5
1974, 4 cyl. 2.0
1971 through 1973 3.0
1968 through 1970 4.0
pre-1968 6.0

BRITISH LEYLAND

Austin, Austin Healey, Morris, America, and Marina
1975 2.0
1973 through 1974 2
1971 through 1972 4
1968 through 1970 5.
pre-1968 6

Jaguar
1975 and 1976 0.5
1972 through 1974 3.0
1968 through 1971 4.0
pre-1968 6.0

67


TABLE 2, FIRST YEAR PERCENT EMISSION REDUCTION OF HYDRO-
CARBONS THROUGH INSPECTION/MAINTENANCE PROGRAMS

Pirst year

Stringency Motorcycles

Vehicle type Additional benefits

Heavy- Mechanics training Semiannual

factor Technology Technology and uty ‘Technology Technology inspection
I Ir light-duty OUty : II
trucks rus
0,10 1 1 1 1 3 0.2
0,20 5 3 5 14 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 rey 24 ll 17.2 7 1 0.2

Subsequent years program credits

Additional benefits

Additive credit HC (percent)

Additive credit Mechanics training

Mimber of inspections “yg (percent) ead Technology I Technology II

Inspections Inspections
2 3 or more 2 or more

2 7 0.10 30015 10

3 1 0.20 4 0 8

4 20 0.30 6 9 2

5 25 0.40 5 1

6 30 0.50 3 1

7 33

8 or more 36

Source:

U.S. Environmental Protection Agency; Appendix N Emission Reduction Achievable
Through eee en and Maintenance of Light-Duty Vehicles, Motorcycles, and Light
and Heavy-Duty Trucks. Proposed Rule, Federal Register, 24(84):  22177-
Monday, May 2, 1977, * oe 177-2283.

12


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 emis-
sions under specified conditions. The emission levels are compared with
a standard established for the vehicle class. If the emissions are higher
than the standard, the vehicle is failed and must be adjusted or repaired
to bring its emissions into compliance with the standards,

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.

hang-up: HC which clings to the surface of the sampling and analyzer system
in contact with the gas sample stream which causes an erroneous indica-
tion 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.

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.

95


programs have been established. In New Jersey, the average cost of repairs

has been under $35 while in Arizona and Portland, Oregon the average costs have
been less than $25 and $15, respectively.5 The actual number of vehicles re-
quiring maintenance as well as the cost is determined by the stringency of the
emissions standards established by the state.

The improved fuel economy resulting from a well-maintained vehicle will
offset, in many cases, the costs incurred by motorists under an I/M program.
Information on this is contained in Table 4. This shows dollar savings for
several vehicles and for the entire vehicle population under an I/M program.

Effectiveness

Approximately one-half of the hydrocarbon and virtually all of the carbon
monoxide emissions come from mobile sources. An I/M program can reduce these
emissions substantially. The extent to which these are reduced is presented
in Tables 2 and 3 which appear in the preceding pages.

WARRANTY PROVISIONS

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 regula-
tion by EPA, will require the automobile manufacturer to bear the cost of re-
pair 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 com-
ponents installed on or in a vehicle for the sole or primary purpose of reduc—
ing vehicle emissions. These warranty provisions are thus an additional be-
nefit to individuals residing in areas with an I/M program.

17


Location: California

Type of Program: State-operated permanent facilities in Riverside.
‘Phase I - Mandatory inspection with voluntary maintenance,
loaded mode testing. (Phase I completed).
Phase Il - Incorporation of idle mode test only.
Phase III - Test mode undecided.

Sites: Two sites, six lanes.

Chronology: Phase I (pilot program) - began inspections September 2, 1975;
second station opened, February 19, 1976. Phase II scheduled
to begin January 1979, Phase III needs further legislative
approval, Under Phase II, program expands to 18 to 19 sites
with a total of 43 to 45 lanes, I/M to be mandatory for those
vehicles requiring registration changes and for those vehicles
that fail California Highway Patrol random roadside checks,
Inspection stations to be operated by a private contractor.
Phase III requires fully mandatory I/M for all registered
vehicles on a yearly basis.

Geographic Coverage: Phase I - City of Riverside only (120,000 LDV's).
Phases II and III will expand program to the remainder
of the South Coast Air Basin (approximately 6.6 million
vehicles), including the whole or parts of Riverside,
San Bernardino, Los Angeles, Orange, Ventura, and
Santa Barbara Counties.

Administering Agency: California Bureau of Automotive Repair - administra-
tion. California Air Resources Board - operations.

Staff Contacts: Jack Dolan and Joe Todd (916) 322-3823.

Capital Cost: $250,000 for six lanes of equipment (analyzers, dynos,
computer control). Land and building of currently oper-
ating station are leased on a monthly basis.

Operating Cost: Not available.

Cost to Motorist: Free at present. Phases II and III, $7 to $8 (estim-
ated). Waiver System - Maximum mandatory repair cost
is $50 with provisions to raise it to $75 in later
years if required.

Standards: Matrix of standards for three model year groups, two engine
size groups, and the presence or absence of air injection.
Projected stringency factor under these standards is 35 per-
cent. Standards will be updated as required.
Vehicles 1955 and older and vehicles of gross weight greater
than 6000 lbs are exempt from program.

46


Connecticut

1. An Act Concerning thé Control of Motor Vehicle Emissions. Raised
Committee Bill No. 50. Referred to Committee on Environment.
February Session, 1975.

2. An Act Concerning the Control of Motor Vehicle Emissions. Draft
Version of Proposed Legislation to be Introduced to Committee on
Environment. 1976-1977 Session.

Nevada
1. Nevada Air Quality Regulations. 1975.

2. Regulations and Procedures for Licensure and Enforcement of I/M.
Department of Motor Vehicles. 1976.

3. Assembly Bill No. 464. An Act Relating to Registration of
Motor Vehicles; Requiring Evidence of Emission Control Com—
pliance; Requiring Certain Motor Vehicles to Be Inspected, etc.
Passed and Signed by Governor, May 1977.

New Jersey

1. Control and Prohibition of Air Pollution From Light-Duty
Gasoline-fueled Motor Vehicles. New Jersey State Department of
Environmental Protection. Air Pollution Control Code.

Chapter 15. January 6, 1972.

2. New Jersey Air Pollution Control Laws. Motor Vehicle Law.
Chapters 15 and. 16 Amended.

3. Proposed Revision of New Jersey Administrative Code 7227-15.1
et seq. Control and Prohibition of Air Pollution From Gasoline
Fueled Motor Vehicles. Proposed Regulation: Notice of Public
Hearing and Adoption of Emergency Rule Docket No. DEP 032-76-12.
State of New Jersey. Department of Environmental Protection.
December 30, 1976.

Portland, Oregon
1. Proposed Amendments to OAR. Chapter 340. 1976,

2. House Bill No. 3239 and Amendments. Oregon Legislative
1975 Regular Session. 8 Assembly.

Others

1. An Act Regulating the Inspection of Motor Vehicles
of the Public Laws of 1976. State of Rhode °
Plantations. Passed by General Assembly,
and Approved by Governor May 26, 1976.

Chapter 139
Island and Providence
January Session, 1976,

91


Other data which have been collected indicate that the service mechanics
have gradually improved their skills in emission related repairs. The fact
that failure rate upon reinspection in New Jersey and elsewhere has declined
supports this idea.

INSPECTION/MAINTENANCE OF HEAVY DUTY VEHICLES

Because of the overwhelming number of automobiles in urban areas, I/M
programs have generally been considered primarily for light-duty vehicles. In
addition, since many trucks are part of fleets and their proper running is im-
portant for business reasons, trucks are often better maintained. However, in
some areas it may be desirable to include heavy-duty vehicles (gross weight
greater than 8500 pounds) in the I/M program to obtain additional emissions
reduction. Although the importance of truck emissions to overall vehicle
emissions is dependent upon a number of factors (such as vehicle mix and miles
traveled by each vehicle class), projections show that in the next 20 years
truck emissions will become more important as the standards for light-duty
vehicles become more stringent.

In assessing the applicability of various I/M approaches to heavy-duty
vehicles, the following factors and special circumstances pertinent to the
use and maintenance of such vehicles are important and should be considered:

e The number and density of heavy-duty vehicles in the region
being considered, including the number registered outside
the state(s) involved.

e The range of sizes, shapes, and weights included in the
vehicle population.

e The Federal emission standards and test procedures appli-
cable to the in-use vehicles at the time they were produced.

e A large part of the heavy-duty population is operated for
commercial purposes. Lost time and the cost of unscheduled
maintenance are more significant to the owners of heavy-
duty vehicles than for most owners of light-duty vehicles.

e Fleet operation and maintenance are more common with
heavy-duty than with light-duty vehicles.

e Heavy-duty chassis dynamometers are expensive and their

. availability is limited; therefore, experience with
dynamometer testing of heavy-duty vehicles is quite
limited.

New York City Department of Air Resources has been testing heavy-duty
vehicles for several years to determine the effectiveness of I/M and retrofits
for reducing heavy-duty emissions. The primary short test being used is the
idle. Results should be available in 1978, Other approaches for controlling
heavy duty emissions include spot checks on highways and mandatory maintenance
of fleets.

29


TABLE 3, FIRST YEAR PERCENT EMISSION REDUCTION OF CARBON
MONOXIDE THROUGH INSPECTION/MAINTENANCE PROGRAMS

First year
Vehicle type Additional benefits
Stringency Motoreycles yo.

wy- Mechanics training  Semiannual

factor Technology Technology and duty Technology Technology inspection
z I light-duty trucks 1 II
trucks

0.10 3 8 3 5 7 0.2
0.20 8 20 8 8.3 7 10 0.2
0.30 B 28 13 9.2 9 10 0.2
0.40 19 33 19 10.5 8 7 0.2
0.50 22 37 22 12.0 7 0.2

Subsequent years program credits

Additional benefits

Additive credit CO (percent)
Mechanics training
Additive credit
CO (percent) Seringency Technology I Technology II
Inspections Inspections
2 30r more 2 or mre

Number of inspections

2 8 0,10 3 B 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 mre 35

Source: 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.

43


Location: Portland, Oregon

Type of Program: Combination of permanent and mobile facilities, idle
mode, mandatory inspection and maintenance. Inspection
is biennial at present.

Sites: Five permanent sites, 10 lanes; four mobile vans, five lanes
Nine sites, 15 lanes total. Plans call for expansion to 17 lanes.

Chronology: Voluntary inspection and maintenance commenced January 1974.
In 18 months, 105,000 vehicles were tested. No transitional
mandatory/voluntary phase. Fully mandatory I/M began
July 1, 1975.

Geographic Coverage: Portland Metropolitan Service District - urbanized
portions of Washington, Multnomah, and Clackamas
Counties (580,000 LDV's < 8400 lbs).

Administering Agency: Oregon Department of Environmental Quality (DEQ).
Staff Contact: Ron Householder, (503) 229-6200.

Capital Costs: Total cost of analyzers (29) was about $200,000. Only
one station was actually built for the program, construc-
tion costing $77,000. Located on State right-of-way,
land costs are not included. This station has loaded-mode
and safety testing capabilities. The four remaining
permanent facilities are leased. A complete mobile van
setup, including new vehicle, three analyzers, and sec-
ondary equipment, cost $40,000 in 1975.

Operating Costs: Approx. $1.45 million for "on" year, $0.8 million for
“off" year.

Cost to Motorist: $5 for issuance of Certificate of Compliance. Un-
limited retests.

Standards: Multiple standards, based on manufacturer's specifications,
involving model year groups, manufacturer groups, and engine
modifications. Testing involves preconditioning to offset
hot idle effect. Vehicles can also be rejected for exhaust
dilution, visible smoke, and excessive idle speed. Stringency
factor is about 35 percent.

Enforcement: Vehicles cannot be registered without Certificate of
Compliance.

57


p. 26 - Table 7

ERRATA

Advanced spark timing increases hydrocarbons.

P. 35 - Table 11

The following metropolitan areas do not currently have SIP

requirements for I/M.
Missouri -

Nevada

New Jersey

Rhode Island

Texas -

St. Louis

Las Vegas (rulemaking is proceeding)
Reno (rulemaking is proceeding)

Remainder of state outside New York City,
Philadelphia, and Trenton metropolitan areas

All

Dallas

The following metropolitan area has had both a SIP requirement and
preliminary review or research.

Texas - San Antonio

The following metropolitan area has had preliminary review or

research.

Georgia - Atlanta

vil


*10.

Young, William H. Review of Report to the 59th Legislative
Assembly by the Environmental Quality Commission on Its In-
vestigation of the Effectiveness of the Motor Vehicle Emission
Program. Director, Environmental Quality Commission. Portland,
Oregon. January 1977.

I. Other States

1.

2.

Automotive Parts and Accessories Association Status of Safety
and Emissions Inspection in the Fifty States. February 1976.

Caprarotta, Gary L. and Douglas J. Orf. An Investigation of
Motor Vehicle Emissions Deterioration Through Idle Emissions
Testing. Regional Air Pollution Control Agency, Dayton, Ohio.
(Paper Presented at APCA Annual Meeting. Boston. June 1975.)

Motor Vehicle Emission Inspection Establishment of Criteria.
Federal Register. Volume 40, Number 113, p. 24904. June 11,
1975.

Pienta, Walter J. Steady State Emissions Characteristics of
1975 and 1976 Model Year Vehicles Tested in New York State.
Prepared by Mobile Source Staff, Bureau of Source Control,
Division of Air Resources, New York State Department of Environ-
mental Conservation. August 9, 1976.

Radian Corporation. A Program Plan for Implementation of Vehicle
Inspection/Maintenance in Four Regions of Texas. June 1975.

Smith, M. F. Transportation Control Plan Requirements of
Cincinnati and Hamilton County. City of Cincinnati. (Presented
at the 5th Annual North American Motor Vehicle Emission Control
Conference. Hyannis. October 26. 1976.)

Williams, Harry. Pilot Study of Proposed Vehicle Inspection
Program in Marion County, Indiana. Director, APCD, Indiana,
APCA Paper 75-42.1. (Presented at APCA Annual Meeting. Boston.
June 1975.)

Kincannon, Benjamin F., Alan H. Castaline, Karen U. Hill and
David A. Lynn. Viable Alternative Types of Inspection/
Maintenance Programs for St. Louis. Prepared for U.S. Environ-
mental Protection Agency. Research Triangle Park, North
Carolina. EPA 907/9-77-005. June 1977.

VIII. INSPECTION/MAINTENANCE LEGISLATION

A. Arizona

1.

Mandatory Annual Emissions Inspection of Motor Vehicles.
Chapter 158, House Bill 2319. State of Arizona, 31st

Legislature, 2nd Regular Session. Signed by Governor on
May 1974,

89


e Authority to make emission reports and i;
available for public inspection © information

e. Authority to compel compliance with rules and regulations,
supported by civil or criminal penalties

e Provisions for injunctive relief where deemed necessary.

The legislation should also designate the lead agency for the program,
most probably the state air pollution control agency, and work out cooperative
arrangements with other groups such as the motor vehicle bureau, the depart-
ment of revenues, the district attorney's office, and other enforcement agen-
cies. State or local consumer protection offices may be included in the pro-
gram design for surveillance of the service industry. Where the intent is to

combine the I/M program with an existing safety inspection program, amendments
to existing statutes may be needed.

The product of these efforts is the initial legislation to authorize pro-
gram development and operation. As the program development advances it is
likely that other issues will surface which require legislative action. The
result will be the revision or modification of the initial legislation. Both
Arizona and New Jersey, two states with established inspection programs, have
required changes to their original legislation.

The current status of legal authority in areas where I/M is required as
part of the transportation control plan is summarized in Table 11.

ADMINISTRATIVE FACTORS

In addition to the usual functions of program evaluation and supervision,
there are three further areas requiring administrative efforts. There are
public relations, consumer protection, and consumer convenience.

Public Relations

The function of a public relation program is to familiarize the public
and the repair establishments with an I/M program. This includes the ex-
planation of the purpose and objectives of the program, the program benefits,
and the practical workings of the program. Under this latter category, the
actual testing procedure should be explained. In addition, information re-

garding station locations, inspection times, and consumer protection measures
should be made available.

A public relations program may take a variety of forms. Advertisements,

public service announcements on radio and television, and brochures have all
proven to be useful.

Directors of current I/M programs recomend that a public relations pro-
gram be started 6 months to a year before any mandatory testing is begun in
order to allow vehicle owners to become accustomed to the concept of I/M.

In Arizona such a program was not fully established until after the start of

34


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: A motor vehicle designed for highway use of less than
8,501 pounds gross vehicle weight. Further distinctions are sometimes mad
made between light-duty automobiles and light-duty trucks such as pickup
trucks.

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.

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 ig-
nition 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.

96


Finally, one:of the major concerns of a vehicle owner will be what he will
have to pay to have his car inspected. For this reason, and to avoid burden-
ing any population group, the inspection fee should be kept as low as possible,

37