State of California 

AIR RESOURCES BOARD 

STAFF REPORT: 

ENHANCED FLEET MODERNIZATION PROGRAM ASSESSMENT

Date of Release: November 19, 2013

Scheduled for Consideration: November 21, 2013

This report has been reviewed by the staff of the California Air Resources Board and 

approved for publication. Approval does not signify that the contents necessarily reflect 

the views and policies of the Air Resources Board, nor does mention of trade names or 

commercial products constitute endorsement or recommendation for use. 

 
2 

This report was prepared by the Alternative Strategies Section in the OnRoad Controls Branch of the California Air Resources Board. The authors 

would like to acknowledge the assistance and cooperation of the Bureau of 

Automotive Repair and in particular, the roadside inspection teams who 

conducted emissions testing. In addition, other divisions and offices of the 

Air Resources Board contributed to this report. Staff from the Field 

Operations Warranty Section of the In-Use Vehicle Programs Branch 

collected data and conducted testing, and staff from the Mobile Source 

Analysis Branch assisted in data analysis and provided emission inventory 

data. 
3 

Enhanced Fleet Modernization Program Update 

Date of Release: November 19, 2013 

TABLE OF CONTENTS 

Executive Summary ...................................................................................................... 5 

I. Introduction and Background ................................................................................... 8 

A. EFMP Vehicle Retirement and Replacement Program .................................... 9 

B. Other Existing Retirement Programs .............................................................. 10 

II. Program Analysis and Assessment ...................................................................... 11 

A. Retirement-Only Element ............................................................................... 11 

1. Qualitative and Quantitative Assessment ............................................ 12 

2. Testing Conducted at the Dismantler ................................................... 13 

a. Qualitative Results .................................................................... 13 

b. Quantitative Results .................................................................. 15 

3. Phone Survey Results ......................................................................... 16 

4. Areas for Further Study and Potential Program Improvement ............. 16 

a. Limit Acceptance of End-of-Life Vehicles .................................. 17 

b. Appropriate Incentive to Attract Desired Vehicles ..................... 18 

B. Pilot Retirement plus Replacement Voucher Element .................................... 19 

1. Economic Assessment of Program Design .......................................... 19 

a. Incentive Amount Compared to Retired Vehicle Value ............. 19 

b. Low-Income Motorist Participation ............................................ 20 

2. Areas for Further Study and Potential Program Improvement ............. 23 
4 

III. Conclusion .............................................................................................................. 24 

IV. Next Steps .............................................................................................................. 24 

Appendix ...................................................................................................................... 26

Appendix A: Testing Roles and Responsibilities by Agency ............................... 26 

Appendix B: Qualitative Inspection Checklist ..................................................... 29 

Appendix C: Summary Tables for Qualitative Testing ........................................ 30 

Appendix D: Summary Table for Quantitative Testing ....................................... 32 

Appendix E: Summary Tables for Phone Survey................................................ 33 
5 

Executive Summary 

The Enhanced Fleet Modernization Program (EFMP) is a vehicle retirement and 

replacement program authorized by Assembly Bill (AB) 118 (Nunez, Chapter 750, 

Statutes of 2007, California Health and Safety Code Section 44125, amended 2010, 

2013). EFMP is funded by a $1 surcharge on motor vehicle registration, translating into 

about $30 million every fiscal year. 

The purpose of the program is to retire high polluting passenger vehicles and light-duty 

and medium-duty trucks by voluntary means. Statute directs that the program should 

be focused on the areas with the greatest air quality impact, and considers costeffectiveness and impacts on disadvantaged and low-income populations. EFMP is 

designed to help people move into newer, cleaner vehicles through the retirement 

and/or replacement of older, dirtier vehicles. 

The Air Resources Board (ARB or Board), in consultation with the Bureau of Automotive 

Repair (BAR), adopted guidelines to administer two separate elements of the program: 

Retirement-Only and Retirement plus Replacement Voucher. The EFMP retirementonly element is extremely popular with motorists; over 70,000 vehicles have been 

purchased and retired since inception and funds are typically exhausted within the first 8 

months of the year. The program offers $1000 ($1500 for low-income) to retire a 

vehicle. In addition about $3 million (10 percent of total annual funds) was allocated for 

a pilot retirement plus replacement voucher element which has solicited over 11,000 

motorists in the South Coast Air Basin with vehicles either known or suspected to be the 

highest emitters with an offer of $3000 ($4000 for low-income) to retire their vehicle and 

replace it with a newer vehicle less than four years old (less than eight years old, if lowincome). However, the voucher program has had limited success and as of 

November 1, 2013, only 21 people have taken advantage of this offer of additional 

funds towards vehicle replacement. 

During the course of administering the program, ARB staff encountered substantial 

anecdotal evidence suggesting consumers participating in vehicle retirement intended 

to scrap their vehicles even without the EFMP incentive. As the emissions reductions 

achieved by the program are dependent on the useful life remaining on the retired 

vehicle being taken off the road sooner than would otherwise happen, staff decided it 

should conduct an assessment of a sample of the vehicles being retired. Similarly, the 

low participation in the pilot voucher program prompted an examination of that aspect of 

the program. 

In order to evaluate the benefits and performance of the program, ARB and BAR jointly 

conducted an assessment of 164 vehicles retired at two approved dismantlers in 

Southern California. All of the vehicles were assessed qualitatively to determine their 

remaining useful life, and 140 were assessed quantitatively and for operational 

functionality using the standard acceleration simulation mode (ASM) dynamometer 

emissions test for roadside Smog Check inspections.
6 

The key findings from the field assessment confirm that the vehicles entering EFMP 

retirement are generally high emitters, but also generally at the end of their useful life. 

While emission inventory models show vehicles in the age range of EFMP participants 

have on average about three years of remaining useful life, the physical condition of the 

tested vehicles suggests imminent retirement was likely anyway, even without State 

assistance. The majority of vehicles tested exhibited mechanical problems that inhibited 

proper operation and/or would cause them to fail Smog Check, preventing them from 

being registered; in either case, the vehicle’s owners elected to retire the vehicles in lieu 

of repair. The overall conclusion of the assessment of the sample of participating 

vehicles is that while EFMP is meeting program goals by purchasing and retiring high 

emitting vehicles, the cost-effectiveness and emission benefits of the program could be 

substantially improved by ensuring that only vehicles with significant remaining useful 

life are allowed to participate. 

Staff also assessed the retirement plus replacement element under the voucher 

program with respect to participation rates and economics. The key findings suggest 

that the program is overly complicated, highly bureaucratic, and the monetary incentives 

offered are too low. Participation requires interaction of the motorist with two 

government agencies and two private businesses. This leads to multiple points in the 

process where participants drop out from either frustration or confusion, even if the 

program incentives are attractive. Staff investigation of the value of solicited vehicles 

suggests the current incentives for replacement are approximately equal to or slightly 

less than the private market value of the vehicles solicited for participation and, 

therefore, do not provide sufficient financial motivation for a prospective participant to 

engage in a complex, bureaucratic process. 

The conclusions of this study identify key areas for potential program improvement, 

which can inform program changes to the existing EFMP guidelines. In addition, two 

recent acts of legislation adopted this year, Assembly Bill (AB) 8 and Senate Bill (SB) 

459, directly address this program and require ARB adopt new program guidelines by 

June 30, 2015. The first piece of legislation, AB 8, extends funding until 

January 1, 2024. The second piece of legislation, SB 459, specifically targets changes 

to EFMP that: 

• establish compensation for replacement vehicles for low-income vehicle owners 

to no less than $2500, 

• make replacement an option for all motor vehicle owners, 

• make replacement compensation available to an owner in addition to the 

compensation for the retired vehicle, 

• prohibit compensation for all other vehicle owners from exceeding the 

compensation for low-income vehicle owners, and 

• authorize an increase in the compensation for low-income vehicle owners as 

necessary to balance maximizing air quality benefits while ensuring 

participation. 

Staff believes that the key areas identified by this study can be effectively utilized to 

inform changes to the program that are consistent with the legislative direction. 
7 

In response to this legislative direction and to address the findings of this study, ARB 

staff will develop and implement program improvements in coordination with BAR, local 

air districts, and other interested parties. Emphasis will be placed on community 

outreach and in developing partnerships with stakeholders in targeted communities. 

Staff will present the proposal for program improvements through new guidelines to the 

Board in mid-2014. 
8 

I. Introduction and Background 

Although California has been the nation's leader in efforts to reduce air and climate 

pollution, the State -- and in particular the South Coast air basin and the San Joaquin 

Valley air basin, home to nearly 50 percent of the State’s passenger vehicles1

 -- 

continues to struggle with air quality problems. California’s 23 million passenger cars 

and light- and medium-duty trucks, which travel close to 865 million miles per day, 

contribute significantly to the problem2. Older vehicles, which are certified at higher 

emission levels, account for a larger share of these emissions than newer models that 

comply with more stringent emission standards. 

Estimated smog-forming emission rates by model year are shown in Figure 1. Note that 

the emission rate of a 20 year old vehicle, in terms of grams per mile of oxides of 

nitrogen (NOx) plus reactive organic gases (ROG), is about 30 times that of a late 

model vehicle. Vehicles that are 20 years old and older account for only 5 percent of all 

miles traveled, but are responsible for 40 percent of daily smog forming emissions from 

motor vehicles3

. These facts make retirement of older vehicles an attractive strategy to 

combat excess emission of pollutants from on-road motor vehicles. 

Figure 1: Vehicle Emission Rate by Model Year 

 

1

 EMFAC2011 (http://www.arb.ca.gov/emfac/) 

2

 Ibid 

3

 Ibid 
9 

A. EFMP Vehicle Retirement and Replacement Program

EFMP is a vehicle retirement and replacement program authorized by AB 118 

(Nunez, Chapter 750, Statutes of 2007, California Health and Safety Code Section 

44125, amended 2010, 2013). EFMP is funded by a $1 surcharge on motor vehicle 

registration, translating into about $30 million each fiscal year. 

The purpose of the program is to retire high polluting passenger vehicles and lightduty and medium-duty trucks by voluntary means. Statute directs that the program 

should be focused on the areas with the greatest air quality impact and considers 

cost-effectiveness and impacts on disadvantaged and low-income populations. 

Low-income is defined in statute as 225 percent of the federal poverty level. The 

authorizing statute also directs that compensation should take into account the age, 

emission benefits of retirement, and the impact of any replacement vehicle. 

ARB, in consultation with BAR, has adopted guidelines to administer two separate 

elements of the program: 

• The Retirement-only element was implemented starting in August 2010 and is 

administered by BAR. Motorists are offered $1000 ($1500 for low-income) to 

permanently retire their vehicle. The EFMP retirement-only element is extremely 

popular with motorists. BAR has retired over 70,000 vehicles (62 percent lowincome) since inception and funds are typically exhausted within the first eight 

months of the year. 

• The Retirement plus replacement voucher element was first implemented in June 

2012 in the South Coast Air Quality Management District (SCAQMD)4

. About $3 

million (10 percent of total annual funds) was allocated for a pilot voucher 

program which has solicited over 11,000 motorists in the SCAQMD with vehicles 

either known or suspected to be the highest emitters with an offer of $3000 

($4000 for low-income) to retire their vehicle and replace it with a newer vehicle 

less than 4 years old (less than 8 years old, if low-income). The intention at time 

of adoption was that replacement vehicles would be the newest and cleanest 

vehicles meeting ARB’s Low Emission Vehicle II standards; however, given 

financial considerations of low-income participants, an older replacement vehicle 

was allowed. As of November 1, 2013, only 21 people had taken advantage of 

this offer of additional funds towards vehicle replacement. 

 

4

 The San Joaquin Valley Unified Air Pollution Control District has also expressed interest in the Retirement plus 

Replacement Voucher element, but has not yet taken steps to implement the program in their area.
10 

The popularity of the retirement-only element has developed spontaneously without 

any formal advertising or promotion. This grassroots popularity is a stark contrast to 

the very limited participation in the retirement plus replacement voucher element 

which offers a larger incentive, but is only available to high polluters identified by 

ARB and BAR based on existing vehicle Smog Check emissions data. 

B. Other Existing Retirement Programs

There are seven other publicly funded vehicle retirement programs either planned or 

currently operating within the State. Six of the seven are local programs operated by 

air districts using Carl Moyer Program, AB 923, or other local funds. These local 

programs have been in operation three to seven years and are collectively much 

smaller than EFMP in terms of total funding, with approximately $21 million 

expended to date: 

• Antelope Valley Air Quality Management District $ 350,000 

• Bay Area Air Quality Management District $16,000,000 

• Mojave Desert Air Quality Management District $ 475,000 

• San Luis Obispo Air Pollution Control District $ 200,000 

• Santa Barbara Air Pollution Control District $ 1,200,000 

• South Coast Air Quality Management District $ 2,780,0005

These local programs, along with EFMP, are designed to reduce fleet emissions by 

accelerating the turnover of the existing fleet and the consequent replacement with 

newer, cleaner vehicles. Reducing emissions from the existing fleet is a critical part 

of California’s State Implementation Plan, which outlines the State’s overall clean air 

strategy to meet federal ambient air quality standards. 

The other statewide retirement program is the vehicle retirement element of the 

Consumer Assistance Program (CAP), which is also administered by BAR and 

receives roughly the same annual funding as EFMP. CAP is designed to assist 

motorists to comply with the Smog Check vehicle inspection program. Because 

vehicles cannot legally be operated or re-registered in the State without passing the 

Smog Check test, the emission benefits from repair assistance and vehicle 

retirement are attributed to the Smog Check program. 

CAP provides qualified consumers who fail a Smog Check test the option to retire a 

vehicle and receive $1000. As with EFMP, consumers meeting low income eligibility 

requirements (i.e., that are below 225 percent of the federal poverty level) may 

receive $1500. Alternatively, CAP provides qualified consumers who own a vehicle 

that cannot pass its biennial (every other year) Smog Check inspection up to $500 in 

financial assistance toward emissions-related repairs. 

 

 

5

 South Coast Air Quality Management District’s High Emitter Repair or Scrap voluntary pilot program to detect 

“gross-polluting” cars, pickups SUVs and vans using remote sensing, and to provide incentives to repair them or 

scrap and replace them may continue depending on the direction of EFMP. 
11 

Although CAP and EFMP have different mandates and goals, the two programs are 

generally perceived by the public as a single program because EFMP is 

administered by BAR under the CAP label using the existing CAP application. The 

objective of CAP is to provide options for Californians facing difficulties in registering 

their vehicles resulting for failing Smog Check, while EFMP is to improve air quality 

though the voluntary retirement of light- and medium-vehicles. Many consumers are 

familiar with the CAP name, but the name EFMP exists only in statute and 

regulation. 

II. Program Assessment and Analysis 

A. Retirement-Only Element 

The primary goal of voluntary vehicle retirement is to take older, still operational 

vehicles off the road sooner than they would normally be retired. (i.e., while they still 

have “useful life” left in them). A vehicle may have no remaining useful life due to 

mechanical failures, or it may have no remaining useful life due to emission control 

system failures. Mechanical failures may physically prevent operation, while the 

Smog Check program blocks registration of those vehicles that do not have 

functioning emissions controls. 

 

During the course of answering thousands of calls with questions about the EFMP, 

ARB staff has collected substantial anecdotal evidence suggesting there may be 

very little remaining useful life in the vehicles entering the program. The program 

assumes three years of remaining useful life for calculating benefits. Most 

callers/applicants have either just experienced an expensive mechanical failure 

and/or cannot pass the Smog Check test for re-registration without costly repairs. 

Callers typically describe their vehicles as “not worth repairing,” or “the repairs cost 

more than the car is worth.” In either situation, the potential participant has already 

made the decision to dispose of the vehicle and is simply shopping for the best 

option. A vehicle that is not worth repairing has ostensibly little or no resale value, 

and EFMP may be an attractive option because dismantlers typically offer 

substantially less for junk vehicles, typically between $200 and $6006

. Retirement of 

these end-of-life vehicles using EFMP funds does not offer any emission benefit 

when the owner has already made the decision to scrap the vehicle. 

 

Increasing evidence that a substantial number of end-of-life vehicles were entering 

the program prompted ARB and BAR staff to launch an assessment of the condition 

of vehicles participating in the retirement-only element. Appendix A contains the 

testing roles and responsibilities by agency. 

 

6

http://www.pickapartauto.com (participating dismantler) and http://www.junkmycar.com/
12 

1. Quantitative and Qualitative Assessment 

The EFMP Quantitative and Qualitative Assessment was a “proof of concept” 

effort which was designed to capture a sample of 120 to 160 vehicles retired 

through the program and to assess the condition of those vehicles at the time of 

voluntary retirement. The quantitative assessment consisted of subjecting the 

participating vehicles to a standard Smog Check test using an approved 

dynamometer and the ASM driving cycle. The purpose of the qualitative 

assessment of vehicle condition, which included completion of a Checklist 

(Appendix B) and taking digital interior and exterior photos, was to facilitate an 

assessment of the value of the vehicle and the likelihood that it could have 

remained operable if it had not been retired. Assessment was based on a 

number of indicators of vehicle mechanical functionality and general roadworthiness condition as determined by an expert ARB staff. 

Two auto dismantlers – one in Ontario and the other in Rialto – agreed to 

facilitate the assessment of the EFMP vehicle retirement program. Only 

dismantlers in the South Coast air basin were considered for this study due to 

weather and cost considerations. 

BAR was responsible for securing dismantler participation and providing roadside 

team staffing, CAP oversight, and CAP field representative participation. BAR 

provided technical assistance and support for the project and all equipment 

normally supplied for roadside ASM testing. 

ARB provided equipment necessary to start-up EFMP vehicles, including jump 

start equipment, tire inflation, and sufficient fuel to keep it idling and/or driving 12 

to 15 minutes prior to testing (preconditioning), operating through the ASM test 

cycle, and driving back to the place where it is stored. 

BAR’s roadside teams conducted ASM testing and ARB field representatives 

conducted inspections and photographed vehicles at the dismantler sites on 

three consecutive Fridays, beginning Friday, January 18, 2013. Staff conducted 

the first day of testing at the Ontario facility and the remaining two days at the 

Rialto facility. 

Two BAR CAP field representatives were on-site each Friday to interface with the 

dismantler and to assist with pre-conditioning of vehicles and transporting them 

to and from the ASM testing area. The BAR CAP Lead field representative acted 

as on-site project lead and served as the point of contact for the dismantler. 

ARB’s on-site project lead facilitated the qualitative assessment, ensured proper 

vehicle preconditioning, and coordinated driving the vehicles to and from the 

ASM test site. The BAR roadside team performed ASM testing. 
13 

2. Testing Conducted at the Dismantlers 

One hundred and sixty-four vehicles in Southern California were assessed as a 

part of the study. All of the vehicles were assessed qualitatively, and 140 were 

assessed quantitatively using the standard ASM (roadside Smog Check) 

dynamometer test. The key findings from this study confirm that the vehicles 

entering the EFMP are generally high emitters, but are also generally at end-oflife. Sixty percent of the vehicles tested failed the Smog Check test, with 21 

percent failing as gross polluters. The emission level at which a vehicle fails as a 

Gross Polluter varies according the vehicle type and year. Specific test limits for 

gross polluters can be found in 16 CCR § 3340.42. For comparison, on average, 

25 percent of similarly aged vehicles across the entire statewide fleet fail the 

Smog Check test, with only six percent failing as gross polluters7

. The 

prevalence of high emitters in the sample population is encouraging, but a 

majority of vehicles tested exhibited some type of mechanical problem that 

inhibited proper operation and/or prevented them from re-registration due to 

Smog Check. The lack of remaining useful life in retired vehicles seriously limits 

the program’s effectiveness for reducing pollution. 

a. Qualitative Results

The majority of vehicles inspected for this assessment required significant 

effort to be started and prepared for testing on the dynamometer. After sitting 

for less than one week, most required jump starting and/or battery 

replacement. Many required starting fluid or other starting assistance, and 

many required transmission fluid or coolant in order to function for the 

duration of the Smog Check test. Five vehicles simply would not start without 

component replacement which was beyond the scope of this testing. 

Results from the Checklists reveal the majority of vehicles could not be used 

without repairs. Nearly every vehicle required either mechanical and/or 

emission control repairs to pass Smog Check and re-register, or required 

mechanical repairs to be functional. Some required both. Roughly 60 

percent of the vehicles had expired registration and could not legally be used 

without repairs to pass the Smog Check test and re-register, and about 30 

percent of the vehicles could not physically be used without mechanical 

repairs8. None of the vehicles were evaluated for safety. 

Fifty-three of the 164 vehicles tested were 1996 and newer vehicles equipped 

with On-Board Diagnostic II (OBDII) systems. Of all the 1996 and newer 

model year vehicles assessed, 53 percent had their “check engine” light on, 

and an additional 10 percent had a malfunctioning light. These vehicles 

 

7

 BAR Random Roadside data, 2010-2012 

8

 This analysis conducted for vehicles still displaying license plates and vehicle test histories from 

http://www.bar.ca.gov/pubwebquery/vehicle/pubtstqry.aspx 
14 

would have automatically failed a Smog Check inspection and denied 

registration. 

About 60 percent of the vehicles did not display current registration tags, with 

the majority of the registrations having expired within the last 6 months. 

Retirement of these vehicles is presumed to provide minimal emission 

benefits because presumably they would have either been repaired or 

scrapped anyway when they could not pass their Smog Check test. Although 

some of these vehicles could have conceivably remained on the road 

unregistered for some period of time, enforcement of registration and Smog 

Check requirements is highly effective, particularly in urban areas. 

In addition to mechanical and emission control failures that suggest the 

vehicles have reached end-of-life, the model year profile of vehicles entering 

the program also suggests high rates of participation by end-of-life vehicles 

because it is almost exactly the same as vehicles retired naturally during the 

same time period at the dismantlers where the study was conducted. Figure 

2 shows the model year distribution of vehicles retired in December 2012 by 

EFMP statewide and non-EFMP vehicles naturally retired at the Ontario 

dismantler (Pick-A-Part) during approximately the same period (dismantler 

data is based on vehicle inventory on January 18, 2013--vehicles are held for 

6 weeks prior to destruction). Appendix C contains summary tables for the 

qualitative testing. 
15 

Figure 2: Distribution by Model Year of Vehicles Retired by EFMP vs. Natural 

Retirement

Note: the mean age of the EFMP vehicles computed using data from the chart above was 21 years which 

is nearly the same as the 20 year mean age of naturally retired vehicles.9 On average, the program 

purchased slightly older vehicles that were nearly identical to those naturally scrapped during the same 

time period. 

b. Quantitative Results 

 

Twenty-six of the 140 vehicles experienced difficulty driving at 25 miles per 

hour (mph) during the ASM (roadside smog check) dynamometer test, an 

additional 17 vehicles were physically unable to complete the test (could not 

drive 25 mph), and some vehicles even suffered catastrophic engine or 

transmission failure during the test. 

Sixty percent of the vehicles tested failed the Smog Check test, with 21 

percent failing as gross polluters. The emission level at which a vehicle fails 

as a Gross Polluter varies according the vehicle type and year. Specific test 

limits for gross polluters can be found in 16 CCR § 3340.42. For comparison, 

 

9

 Posted vehicle inventory at http://www.pickapartauto.com/inventory/ontinv.html on 1/18/13 compared to EFMP 

participating vehicles during December 2012 

0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

10%

1960 1970 1980 1990 2000 2010

Fraction of Total Retirements

Model Year

Pick a Part

EFMP-statewide
16 

25 percent of similarly aged vehicles in the fleet fail, with only 6 percent failing 

as gross polluters.10 Appendix D shows pass/fail results by model year. 

3. Phone Survey Results 

In addition to the physical inspection and testing, staff conducted a brief phone 

survey, successfully reaching 50 percent of the 164 vehicle owners. The phone 

survey was intended to inform us about the owner’s use of the retired vehicle 

prior to replacement, why the owner decided to retire the vehicle, what mode of 

transportation the owner replaced the vehicle with, and how the owner learned 

about the program. 

The phone survey confirmed that the majority of vehicles had either major 

mechanical problems or could not pass Smog Check without extensive repairs; 

two-thirds of respondents indicated that the vehicle had problems they judged not 

worth repairing. About half of participants reached in the survey purchased a 

replacement vehicle, and the majority of remaining respondents used another 

vehicle they already owned to replace the retired vehicle. Of those that did 

purchase a replacement, about 60 percent purchased a vehicle older than the 

fleet average, almost 20 percent purchased a used vehicle newer than the fleet 

average, and about 15 percent purchased a new vehicle. Participants typically 

learned about the program through friends, relatives, a smog check technician, or 

the Department of Motor Vehicles (DMV). Appendix E contains summary 

tabulated results of the phone survey. 

4. Areas for Further Study and Potential Program Improvement 

Annually, more than 1 million vehicles reach end-of-life and are scrapped in 

California naturally without public assistance.11 The direct emission benefits of 

this program result from driving that figure higher by permanently removing older 

vehicles from service early. Emission benefits from vehicle retirement are limited 

to the relatively short period between when the vehicle is actually retired and 

when it would have been retired anyway without public assistance. While the 

EFMP is meeting program goals by purchasing and retiring high emitting 

vehicles, the emission benefits and cost-effectiveness could be substantially 

improved by purchasing only vehicles with significant remaining useful life. 

Programs designed to generate emission reduction benefits by purchasing older, 

higher emitting vehicles must balance the emission benefits (remaining useful 

life) and incentive amount (value of target vehicles). Previously published costeffectiveness estimates for the EFMP retirement-only element are based on 2 

critical assumptions: fleet average emissions by model year and 3 years average 

 

10 BAR Random Roadside Data 2010-2012 

11 EMFAC2011 (http://www.arb.ca.gov/emfac/) difference between new model year population and total population 

growth 
17 

remaining useful life12. Data from the assessment of 164 vehicles raises 

questions about both of these assumptions. The retired fleet average emissions 

may be higher than previously estimated and the useful remaining life may be 

near zero. Although the higher emissions rates imply that the program achieves

greater reductions and better cost-effectiveness than estimated, the nearly nonexisting remaining life that the car would have been operated implies the 

opposite. Figure 2 shows that because the distribution of EFMP and normal 

vehicle retirement ages is nearly identical, the remaining life of an EFMP vehicle 

approaches zero. This effect overpowers the effect of a higher emissions rate. 

Thus, based on the findings from this study, EFMP is likely less cost-effective 

than previously estimated. 

The overall benefits of the EFMP retirement-only element could be improved 

significantly by shifting the program towards vehicles with demonstrable 

remaining useful life as the program assumes, which may require a higher 

incentive to match the vehicle’s commercial value. However, the program design 

must avoid simply paying more for the same vehicles. 

a. Limit Acceptance of End-of-Life Vehicles 

For any vehicle, at some point the cost of repair will exceed the value of the 

vehicle (for all but a few collector, or special interest vehicles) and it will 

naturally be retired. Necessary repairs may be mechanical, affecting the 

physical ability to use the vehicle or they may be emission related, affecting 

the legal ability to use the vehicle. EFMP purchase of end-of life vehicles 

offers no direct emission benefit because these vehicles would have been 

retired anyway. These benefits are therefore not in excess to a baseline 

without the program. However, there may be some very small ancillary 

emission benefits due to the fact that vehicles retired in the program are 

completely destroyed, thereby removing the ability to recycle any of parts to 

be reused in similar vintage vehicles currently in operation. This could result 

in the accelerated retirement of similar vehicles due to the limited availability 

of used replacement parts. Vehicles at end-of life due to emission control 

system failures should be directed to BAR’s CAP program, which is designed 

to purchase end-of-life vehicles; vehicles at end-of-life due to mechanical 

failure need to be culled from the program. 

 

A more sophisticated acceptance inspection could mitigate the end-of-life 

concern in EFMP. While the current acceptance inspection requires the 

participant to drive the vehicle to the dismantler and demonstrate starting the 

vehicle engine and 30 feet of forward motion upon arrival, there is no 

practicable way for the dismantler to verify the vehicle was actually driven to 

the facility. In addition, and the requirement for 30 feet of forward motion is 

 

12 Initial Statement of Reasons for Proposed Rulemaking (EFMP) May 8, 2009 

[http://www.arb.ca.gov/regact/2009/carscrap09/carscrapisor.pdf] 
18 

simply too lenient. The 164 vehicle study shows vehicles that barely run and 

could not reasonably be driven anywhere are being accepted into the 

program. An improved and objective acceptance test could enhance the 

quality of participating vehicles, and significantly increase the benefits of the 

program. The ASM dynamometer test is a good candidate for a universally 

available, widely accepted, and objective operating test. 

 

Requirement of a Smog Check test would automatically exclude the 

approximately 10-15 percent of today’s participants that cannot at least drive 

25 mph for 90 seconds. It might also deter a larger, but unknown, number of 

owners who know their vehicles do not run properly. Test results would also 

allow the vehicles to be directed to the appropriate funding source for 

retirement: CAP or EFMP funds, depending on whether they pass or fail the 

test. Requirement of any objective drivability test would improve the quality of 

participating vehicles, but it likely could not be comprehensive enough to 

completely block end-of-life vehicles. For this reason, an actual Smog Check 

test is proposed, rather than simply a new drivability requirement. 

b. Appropriate Incentive to Attract Desired Vehicles

In addition to blocking unwanted end-of-life vehicles, the program can be 

improved to better attract high-polluting vehicles that are not end-of-life 

vehicles, but rather vehicles still in use and, hence, offer the potential for 

reduction of truly excess emissions. Staff reviews of vehicle classified ads 

show 99 percent of similar vehicles advertised for sale in running condition 

are listed above the current incentive of $1000/$1500 and have a median 

price over $400013. This evidence suggests the current level of incentive is 

significantly below commercial values and, hence, less likely to attract the 

desired operational vehicles with remaining useful life. An increase in the 

incentive amount may be warranted to better reflect the actual value of 

vehicles intended to be captured by the program. Considering a larger 

incentive that reflects both the recognition of actual used vehicle market value 

of an operating vehicle and the added cost of a Smog Check ASM test would 

improve the current program by providing a better balance between remaining 

useful life, vehicle value, and cost-effectiveness. Both of these measures 

should be taken together; an increase in the incentive amount may attract the 

desired vehicles, but a simple increase in incentive without a mechanism to 

restrict the quality of participating vehicles would simply result in paying more 

with little to no additional benefit. 

 

Increasing the basic incentive for retirement may affect other existing 

retirement programs, in particular, CAP. Thus, BAR and ARB are 

coordinating efforts on EMFP program improvement to ensure the program 

 

13 www.autotrader.com and www.craigslist.com (multiple access dates May to July 2013) for vehicles advertised for 

sale in the SCAQMD 
19 

remain complimentary. It must be recognized that at present, administration 

of CAP and EFMP is generally indistinguishable to the consumer, and an 

increase in the incentive amount for EFMP alone could generate some 

confusion. However, the goals and mandates of CAP and EFMP are 

different: CAP is designed to purchase end-of-life vehicles, while EFMP is 

designed to purchase vehicles before end-of-life. Marketplace data indicate a 

difference in price between these types of vehicles and suggest the incentives 

should differ. Changes in the eligibility requirements for CAP and/or EFMP 

will be considered in coordination by the overseeing agencies. 

B. Pilot Retirement plus Replacement Voucher Element 

The need for cleaner vehicles in the areas of the State hardest hit by air pollution 

prompted staff to design the pilot voucher program to assist motorists operating the 

worst polluting vehicles in replacing that vehicle with a newer, cleaner vehicle. The 

basic concept is to take the existing popular retirement-only element and offer 

additional funding to owners of known or highly probable gross polluters to retire and 

replace sooner than it would otherwise occur. The initial funding allocation for this 

pilot program was roughly $3 million (approximately 10 percent of available EFMP 

funds) for the fiscal year. However, few people have taken advantage of the offer of 

$3000 ($4000 low income) to retire their cars and purchase newer, cleaner ones. 

 

Of the 11,372 vehicle owners contacted by mail for participation specifically in the 

Voucher program, 1,436 responded expressing interest by returning a postage-paid 

card. Each respondent was subsequently contacted via phone by BAR staff, which 

then mailed 211 applications to the most interested responders. Ninety-five of those 

vehicle owners received approval prior to the end of Fiscal Year 2012-2013 and 

BAR staff provided them with direction how to purchase a vehicle and claim the 

additional Voucher incentive. Of those 95 approved to participate, 72 elected for 

retirement only without a replacement voucher, and, as of November 1 2013, only 21 

opted to claim the full retirement and replacement incentive. Several factors are at 

played for resulting in this low participation rate and the staff’s analysis of these 

factors will inform changes for program improvement. 

1. Economic Assessment of Program Design

The low response rate led staff to investigate whether the incentives offered were 

appropriate for the target audiences and vehicles—specifically whether the 

retirement value was sufficient to cover the value of the retired vehicle that could 

be received elsewhere, and whether the replacement amount was sufficient to 

enable low-income participants to purchase a replacement, cleaner vehicle. 

a. Incentive Amount Compared to Retired Vehicle Value 

As mentioned earlier when discussing the retirement-only element incentive 

amount, staff review of classified ads indicate the mean advertised price of 
20 

vehicles offered for sale in running condition and similar to those solicited for 

participation in the EFMP retirement plus replacement voucher element range 

from $4000 listed by a dealer and $5000 listed by a private party.14 That 

value is approximately equal to, and perhaps slightly less than, the $3000 to 

$4000 total retirement plus voucher incentive amount offered by the program. 

This generally means the pilot program has, on average, not offered motorists 

an incentive above the current value of their vehicle to retire it and upgrade in 

the EFMP program. Considering this, likely program participants were those 

people who had coincidently already decided to replace their vehicle and/or 

outliers at the lower end of the value distribution. 

b. Low-Income Motorist Participation 

Staff analysis of DMV data suggest that older vehicles tend to be registered in 

lower income areas. Staff reviewed existing economic data to estimate what 

resources low-income participants would require to purchase a replacement 

vehicle, because the overall participation rate in the retirement plus 

replacement voucher program raises questions of how well the incentives 

offered correspond with the needs of potential participants. 

According to the Bureau of Labor Statistics, the average household 

expenditure on transportation is approximately 15 percent of gross income15. 

This is a fairly constant figure across all income groups, but some individual 

households spend more, and some spend less. Table 7 shows an estimate 

of how transportation expenses for a newer, cleaner car might fit into the 15 

percent budget for various household sizes at the low-income threshold. 

Income is shown at the top of the table, followed by an estimate of expenses 

for a newer, cleaner car in the middle of the table. In the bottom half of the 

table, the ‘fixed’ expenses associated with vehicle ownership are subtracted 

from the 15 percent budget to arrive at a potential amount which could be put 

towards a monthly car payment. The very bottom of the table shows 

estimated borrowing ability based on that potential amount followed by the 

incremental cost beyond that required to purchase newer, cleaner vehicles. 

For low-income households of 1 and 2 people, 15 percent of their income 

does not even cover expenses for gas, insurance, maintenance, etc.; these 

households either do not own a vehicle, are likely not paying for essential 

costs such as insurance, registration, and maintenance, or are doing without 

other household necessities. For a family of 3, low-income is at or below 

$42,953. Fifteen percent of that figure is virtually equivalent to the costs of 

gasoline, insurance, registration, repairs, and maintenance, leaving 

essentially no remaining income left for a loan payment towards a newer, 

 

14 www.autotrader.com and www.craigslist.com (multiple access dates May to July 2013) for vehicles advertised for 

sale in the SCAQMD 

15 www.bls.gov/news.release/cesan.nr0.htm
21 

more expensive vehicle. Larger households have a higher income eligibility 

limit and, on average, may have some resources to purchase a new vehicle 

with a loan. Using the assumptions stated here, a household of 4 could 

theoretically assume a loan for a $7500 vehicle and a household of 5 could 

theoretically assume a loan for a $13,500 vehicle. 

These figures suggest that the current incentive amounts are only appropriate 

for larger households of five or more people. Assistance to smaller 

households would require substantially larger incentives. 

 

A further confounding issue is that many other public assistance programs 

such as the Supplemental Nutrition Assistance Program16 (popularly known 

as the food stamp program) include an asset test, and some households 

could be denied benefits from other programs where they currently receive 

benefits, if they were to participate in the vehicle replacement program that 

placed a high-value asset (a newer car) in the household. 

Obviously, some households may elect to spend more than the average 

household expenditure on transportation and may choose to participate in the 

program as currently constituted. However, calculations suggest that lowincome participants in the replacement purchase program will generally be 

outliers. Experience in other states, such as the current “Drive a Clean 

Machine” program in Texas, also indicates few low income participants have 

taken advantage of replacement programs17

. 

 

16 www.snap-step1.usda.gov/fns/tool/tutorial/vehicle_states_chart/states_chart.html

17 Personal communication on 7/9/13 with Santos Oliveros, Texas Commission on Environmental Quality 
22 

Table 7. Estimate of Additional Funds Required for Low-Income Households by 

Household size and Replacement Vehicle Technology 

Household 

Identification 

Household Size 1 2 3 4 5 

Annual Gross Income1 $ 25,133 $ 34,043 $ 42,953 $ 51,863 $ 60,773 

Monthly 

Income 

Monthly Gross Income $ 2,094 $ 2,837 $ 3,579 $ 4,322 $ 5,064 

15% for Transportation2 $ 314 $ 426 $ 537 $ 648 $ 760 

Monthly 

Transportation

Expenses for 

Newer Vehicle 

Liability Insurance3 $ 45 $ 45 $ 45 $ 45 $ 45 

Collision Insurance3,4 $ 110 $ 110 $ 110 $ 110 $ 110 

Registration5,6 $ 13 $ 13 $ 13 $ 13 $ 13 

Maintenance and Repair7,8 $ 150 $ 150 $ 150 $ 150 $ 150 

Fuel9 $ 200 $ 200 $ 200 $ 200 $ 200 

Potential Monthly Car Payment 

(15% of monthly gross, less all 

other vehicle expenses)

 -- -- $ 19 $ 131 $ 242 

Loan 

Potential Car Loan Amount10

(based on potential payment 

above)

 -- -- $ 1,000 $ 7,500 $ 13,500 

Potential 

Incentive 

Amount 

Required in 

Addition to 

Loan 

ULEV (MY 2006)11 $15,000 Full Cost Full Cost $14,000 $7,500 $1,500 

SULEV (MY 2010)11 $18,000 Full Cost Full Cost $17,000 $10,500 $4,500 

Hybrid (used)11 $19,000 Full Cost Full Cost $18,000 $11,500 $5,500 

AT PZEV (Leaf)12 $21,300 Full Cost Full Cost $20,300 $13,800 $7,800 

 

1

225% of federal poverty level 

 

 

2U.S. Bureau of Labor Statistics: Consumer Expenditures Report 9/25/12 

3

June 2013 Quote from State Farm Automobile Insurance Company for good driver with 15 years’ experience

4Additional $60 per month for new vehicle 

5CA Department of Motor Vehicles Vehicle Registration Fee Calculator website model year 2005 representative vehicle 

6Additional $10 per year for each model year newer than 2005, e.g. additional $80 per year ($6.67/month) for 2013 vehicle 

7Edmunds.com True Cost to Own for 8 year old representative vehicle 

8Costs may be lower for newer vehicles 

9Assumes 12,000 miles annually at 20 mpg and $4.00/gal 

10Prime Borrower (credit score >800) at 3% (Bankrate 2.67% average on 6/28/13) for 60 months 

11CARMAX mean web advertised price in LA area on 6/28/13 

12Base model MSRP on Nissan.com on 6/28/13 (after maximum federal incentives) 

 
23 

2. Areas for Further Study and Potential Program Improvement 

Staff’s initial evaluation has concluded that factors such as low incentive 

amounts, program complexity throughout the transaction process, and limited 

outreach may be important contributors to the lack of success of the voucher 

program. 

To address the barriers to low-income participation identified above, staff 

suggests incentive amounts should be revised upwards. As noted previously, 

surveys have consistently shown that the total retirement plus voucher incentive 

amount is approximately equal to the mean and median advertised price of 

vehicles similar to those being solicited. This generally means the pilot program 

has on average offered motorists the value of their vehicle to retire it and 

upgrade, which may not be much of an incentive for most motorists. Likely the 

only participants were people who had coincidently already decided to replace 

their vehicle and/or outliers at the lower end of the value distribution, and thus 

their participation provided little or no emission benefit. The program must not 

only offer sufficient financial incentive to overcome the inertia or hassle of making 

a change and mitigate the added financial burden of an upgrade; it must also 

overcome hurdles that are not always strictly financial, such as participant 

distress over the thought of crushing what may be a beloved car. 

The current model of direct solicitation in the pilot voucher retirement plus 

replacement program has proven to be inefficient both in terms of administrative 

costs and participation rates. The program is effectively making cold calls to 

offer motorists approximately the value of their vehicles in exchange for 

scrapping their car and buying a more expensive upgrade. 

Instead of simply increasing the replacement incentive, and thus decreasing the 

cost-effectiveness, and adding additional resources to expand existing outreach 

efforts, staff is evaluating a structural change where the outreach and function of 

the program is moved to an arena where people are already motivated to make a 

change: the vehicle dealership. The current model is limited to inviting an owner 

of a likely high polluter vehicle (who may not be interested in replacing a vehicle 

at all) to retire the vehicle and then go to a dealership to replace it; the proposed 

model would incentivize everyone at the dealership with an older vehicle to make 

a cleaner replacement choice. All older vehicles could be eligible for retirement 

with an additional tiered incentive for purchase of more environmentally friendly 

replacement vehicles. This approach could be coordinated with other programs 

such as the Clean Vehicle Rebate Project (CVRP) to maximize opportunity for 

low-income participants. 

Many vehicles sold to dealerships as trade-ins are excellent candidates for 

EFMP retirement. Many trade-ins are relatively high emitters due to age and 

also have significant useful life remaining. The dealership typically purchases 
24 

these vehicles for less than retail resale value and the vehicle is subsequently 

sold into another household. Those vehicles could potentially be intercepted at a 

price that is advantageous to both the dealer and the consumer and retired 

instead of eventually returning to the road under new ownership. 

If the program was to be transitioned to one that is implemented at the dealer to 

leverage car dealers’ resources and existing motivation, the program would no 

longer be necessarily restricted to the highest polluters. Instead, this approach 

would rely on the proven fact that older vehicles generally pollute more and the 

replacement program focus would shift from the difficult task of convincing 

owners of gross polluters to crush their cars to focusing on influencing people 

who have already decided to make a change towards making a cleaner choice. 

A significant increase in efficiency could be gained by purchasing vehicles whose 

owners have already decided to sell, rather than increase the incentive amount 

sufficiently to convince other owners to sell. 

Besides simply leveraging dealer outreach resources, additional benefits from a 

dealer/EFMP relationship may be possible. BAR could mine the very large data 

from statewide Smog Check test results, the Vehicle Information Database, to 

create a ‘want list’ of specific vehicles, or vehicle types wanted for purchase. The 

list could be distributed among the participating dealerships for additional 

targeting of higher emitting vehicles. Every time a vehicle matching the 

characteristics of vehicles on the list arrived as a trade-in, it could be diverted 

from the usual auction route or other resale path towards EFMP retirement 

instead. A sophisticated targeted list could even include mileage, in addition to 

age, make and model. Additional outreach beyond the dealer could be added to 

increase the likelihood of reach the owners of those vehicles. 

III. Conclusion 

EFMP has been successful in retiring high polluting vehicles, but less so in providing 

incentives for replacement vehicles. Staff has identified aspects of both elements of the 

program that warrant additional study and can improve the program’s ability to reduce 

emissions and serve low-income consumers. 

However, it must be recognized that the issue of incentivizing vehicle retirement and 

replacement is complex, with many confounding factors. To determine a sensible 

retirement and replacement vehicle solution, it is recommended that different 

approaches be evaluated and tested. Course corrections may be necessary, if the 

initial approach does not prove fruitful. 

IV. Next Steps 

The conclusions of this study identify key areas for potential program improvement, 

which can inform program changes to the existing EFMP guidelines. This assessment 

yielded useful information that played a role in recent legislation which paves the way 
25 

for improving the program. Two recent acts of legislation adopted this year, Assembly 

Bill (AB) 8 and Senate Bill (SB) 459, directly address this program and require ARB 

adopt new program guidelines by June 30, 2015. The first piece of legislation, AB 8, 

extends funding until January 1, 2024. The second piece of legislation, SB 459, 

specifies, among other items, that vehicles should not be eligible for retirement unless 

they have sufficient remaining useful life. And in addition to a directive that outreach 

should be increased, the bill provides options to ensure the program adequately serves 

persons of low- and moderate-income, such as by granting the ability to limit eligibility 

on the basis of income. 

Moving forward, ARB staff will work closely with BAR staff to develop strategies to 

improve the program and to ensure that all changes are complementary to the 

Consumer Assistance Program. Development and implementation of the program 

modifications will require coordination with local air districts, engagement with 

stakeholders and outreach to interested parties. Consistent with SB 459, staff will 

emphasize community outreach and developing partnerships with stakeholders in 

targeted communities. ARB staff will work with stakeholders to develop a draft proposal 

that will be the subject of public workshops scheduled for early spring 2014 and return 

to the Board with a proposal for program changes and improvements in mid-2014. 

 

 
26 

Appendix A: Testing Roles and Responsibilities by Agency 

On-site leads were as follows: 

On-site Leads Name

BAR CAP Lead Howard Pittman 

BAR Roadside Lead Paul Thomas 

ARB On-Site Lead John Ellis 

ARB Point of Contact Gene Seto 

The participating dismantlers’ names, addresses, and phone numbers are as follows: 

Dismantler Address Phone Number(s)

Pick-A-Part 2025A South Milliken Avenue 

Ontario, California 91761 

(800) 600-5865 

(909) 390-5270 

Ecology Auto Parts 221 East Santa Ana Avenue 

Rialto, California 92316 (909) 877-8707 

Agency Roles and Responsibilities: 

I. BAR roadside team (the quantitative assessment team) responsible for: 

1. Setting up the mobile ASM unit, calibrating the equipment. 

2. Establishing a queuing area for vehicles waiting in line to be tested. 

3. Ensuring vehicles have been appropriately pre-conditioned prior to testing. 

4. Performing an ASM test on all testable EFMP vehicles stored at the 

dismantler site and entering test information using the vehicle license plate or 

vehicle identification number (VIN). 

5. Performing equipment calibration in the morning and at lunch. 

6. Printing two Vehicle Inspection Reports and providing one to ARB at the end 

of the test. 

7. Notifying ARB’s Representative and informing him of the reason if a vehicle 

arrives in the staging area that the BAR roadside team determines is unsafe 

to test: 

a. Unsafe vehicles or vehicles that cannot be tested due to the vehicle’s 

condition marked on the Checklist as “vehicle could NOT be tested due to 

________________________.” 

8. Taking down the equipment following testing and ensuring the testing and 

queuing areas are left in the same condition as they were found. 

9. Informing the CAP Field Representative if an issue requires dismantler 

clarification or resolution. 

10. Ensuring that all areas impacted by the roadside team are left in the same 

condition as they were found. 

 
27 

II. CAP field representative responsible for: 

1. Establishing and maintaining rapport with the dismantler, including all 

interface activity on the day of testing. 

2. Securing adequate space for queuing and testing vehicles, and establishing 

the procedure for moving EFMP vehicles from the yard to the staging area 

(queue) and returning the vehicles to the yard. 

3. Securing the keys for all EFMP vehicles. 

4. Assisting in the process of starting and warming up EFMP vehicles for testing 

and driving them to and from the staging area. 

5. Ensuring all areas impacted by the project (BAR roadside testing and ARB 

qualitative assessment) left in the same condition as they were found. 

III. ARB Representatives (the qualitative assessment team) responsible for: 

1. Identifying each EFMP vehicle and accurately recording its VIN, CAP ID, 

make, model, and model year (Checklist). 

2. Checking the vehicle tires (for safety) and windows (Checklist). 

3. Starting the vehicle to begin the warm-up (pre-conditioning) process, 

recording the odometer reading, and checking the fuel gauge (Checklist): 

a. If needed, re-charge the battery. 

b. If needed, add gas to enable vehicle to be tested. 

4. Determining if the vehicle is untestable, i.e., unsafe to test or unable to be 

started and driven to the staging area (record on checklist if not testable). 

NOTE: ARB staff check with BAR roadside before deciding if a vehicle is not 

testable: 

a. Check for obvious leaks that could render the vehicle untestable 

b. Mark vehicle as “vehicle could NOT be tested due to 

________________________” (Checklist). 

5. (While the vehicle is warming up) recording on the checklist the nonmechanical interior and exterior condition of the vehicle (Checklist). 

6. Taking interior and exterior digital photos to visually display – in the best 

possible manner -- the condition of the vehicle (Checklist): 

a. Take at least two photos of the interior, including one of the dash and a 

second that shows the general condition of the seats and flooring 

i. If severe damage is present, take a photo of the damaged area. 

b. Take at least four photos of the exterior, including a frontal photo, a 

photo from the rear end of the vehicle, and a photo of each sides 

i. If severe damage is present, take a photo of the damaged area(s). 

7. Checking that the vehicle’s emissions control systems is not missing, 

modified, or tampered (Checklist). An ASM test performed regardless of 

findings if vehicle is determined to be testable. 

8. Working in tandem with the CAP Field Representative be sure all vehicles are 

properly pre-conditioned prior to driving the vehicle to the staging area: 

a. Idled the vehicle for a minimum of 10 minutes at normal idling speed 

b. At “fast idle,” idle the vehicle for one minute.

9. Driving all testable vehicles to and from the staging area: 

a. Check that the MIL (Engine Check Light) is not on (Checklist) 
28 

b. Check that there is no obvious problem with the engine while driving 

(Checklist) 

c. Check vehicle transmission while driving (Checklist) 

d. Check that there is no obvious frontend problem while driving 

(Checklist) 

e. Check that the brakes are working while driving (Checklist) 

f. Check the coolant system (Checklist). 

10. Checking if vehicle is smoking when it arrives at staging area (Checklist). 

11. Marking the overall condition of the vehicle (Checklist). 

12. If the roadside test team determines the vehicle is untestable, marking vehicle 

as “vehicle could NOT be tested due to ___________________-” (Checklist). 

13. Informing the CAP Field Representative if an issue requires dismantler 

clarification or resolution. 

14. Ensuring that all areas impacted by ARB are left in the same condition as 

they were found. 

15. Following the assessment at the dismantlers, combining the Checklist with 

the printed photos for each vehicle. 

 
29 

Appendix B: Qualitative Inspection Checklist 
30 

Appendix C: Summary Tables for Qualitative Testing 

Vehicle’s Overall Mechanical Condition (as rated by ARB field technician) 

Overall Vehicle Condition

 Good Fair Poor 

All Vehicles 12% 63% 25% 

 

By location 

 Ontario 16% 71% 13% 

 Rialto 10% 60% 30% 

Status of the On-Board Diagnostic Malfunction Indicator Light (MIL) for 1994 

and Newer Model Year Vehicles 

Status of Malfunction Indicator Light (MIL) 

 ON” “OFF” Malfunctioning 

1994 and newer model-year vehicles 55% 37% 8% 

 

1996 and newer model-year vehicles 53% 37% 10% 

The Top 12 Mechanical Problems 

Top 12 Mechanical Problems

1 Catalytic Convertor (aftermarket part, not certified for vehicle) 26 

2 Transmission Problem 14 

3 Engine Misfire 11 

4 Power Steering 7 

5 Vacuum Hose 6 

6 Smoking 6 

7 Overheating 5 

8 Rough Idle 3 

9 Engine Noise 3 

10 Engine Knocking 3 

11 Other disconnect or modified 6 

12 Leaking oil or fluids 5 

Note: Some vehicles had more than one mechanical problem identified at the time of 

visual inspection. 
31 

Non-Mechanical Condition (as rated by ARB field technician) 

Non-Mechanical Condition of the Vehicle

Good Fair Poor 

Interior Condition 16% 37% 47% 

 

Exterior Condition 22% 52% 26% 

 

 
32 

Appendix D: Summary Table for Quantitative Testing 

ROADSIDE EFMP TESTS 

1/18/2013 AND 1/25/2013 AND 02/01/2013 

Vehicle Odometer Reading Gross Polluter 

MODEL 

YEAR 

AVERAGE HIGH LOW TESTED FAILED 

NON-GP 

FAILED GP FAILED 

TOTAL 

PASS FAIL 

RATE 

1973 66,914 88,784 28,704 3 0 1 1 2 33%

1975 27,237 27,237 27,237 1 0 0 0 1 0%

1978 46,213 46,213 46,213 1 0 1 1 0 100%

1979 74,635 74,635 74,635 1 0 1 1 0 100%

1981 994 994 994 1 0 1 1 0 100%

1983 2,262 2,262 2,262 1 0 1 1 0 100%

1986 92,864 133,304 52,424 2 1 1 2 0 100%

1987 193,928 310,695 93,710 5 2 0 2 3 40%

1988 203,371 393,443 80,981 4 1 0 1 3 25%

1989 190,512 303,849 3,502 10 8 1 9 1 90%

1990 253,734 253,734 253,734 1 1 0 1 0 100%

1991 186,396 241,034 92,195 11 5 3 8 3 73%

1992 172,470 263,903 15,688 8 4 1 5 3 63%

1993 224,891 322,347 142,883 10 5 3 8 2 80%

1994 189,107 331,410 79,743 9 3 2 5 4 56%

1995 210,168 325,054 114,878 11 4 2 6 5 55%

1996 202,565 285,535 0 10 6 2 8 2 80%

1997 200,153 326,133 89,520 13 2 3 5 8 38%

1998 213,651 294,593 176,743 4 2 0 2 2 50%

1999 167,063 216,093 93,728 4 1 1 2 2 50%

2000 154,842 217,080 0 6 2 0 2 4 33%

2001 112,798 123,195 102,400 2 0 1 1 1 50%

2002 113,040 113,040 113,040 1 0 0 0 1 0%

2003 252,078 252,078 252,078 1 0 0 0 1 0%

TOTAL 182,024 120 47 25 72 48 60%

An odometer reading was collected for each vehicle tested and data is shown in the 

table above for all vehicles by age group. Data from 1992 and older model year 

vehicles that have 5-digit odometers may not reflect total mileage, and without the 

vehicle history might not show the real picture. In the same manner, at least 2 of the 

newer vehicles (one in model year 1996 and the other in model year 2000) had 

inoperable odometers. Therefore, in only a few years do the odometer readings reflect 

the actual mileage driven. 

 
33 

Appendix E: Summary Tables for Phone Survey 

At the time you retired your vehicle was it registered with DMV? (The responses to this 

question do not agree with staff observations; about 60 percent of the vehicles 

displayed expired tags during testing and inspection.) 

# % “Yes” or “No” 

80 98% Yes (the vehicle was registered) 

2 2% No (the vehicle was not registered) 

What would you have done with your vehicle if you did not retire it through the State 

program? 

# % Response 

38 46% Keep it, drive it, and/or fix it to drive 

30 37% Sell it 

6 7% Scrap it 

4 5% Donate it 

3 4% Don’t know 

1 1% Register it as “Non-Op”

At the time you retired your vehicle, what did you think it was worth? While 13 percent 

did not know or did not want to guess, 71 participants stated what they thought their 

vehicle was worth. (87 percent of these vehicles were purchased by EFMP for $1500 

and 13 percent for $1000). The following table summarizes the results: 

# % The owner thought the vehicle was worth: 

1 1% Less than $200 

2 2% Between $200 to $399 

3 4% Between $400 to $599 

2 2% Between $600 to $799 

4 5% Between $800 to $999 

23 28% $1,000 

4 5% $1,001 to $1,299 

3 4% $1,300 to $1,499 

10 12% $1,500 

2 2% $1,501 to $1,799 

1 1% $1,800 to $1,999 

9 11% $2,000 

3 4% $2,001 to $2,499 

1 1% $2,500 

 Between $2,501 to $2,999 

1 1% $3,000 to $3,999 

 $4,000 to $4,999 

2 2% $5,000 or over 

11 13% Did not know 
34 

Was the retired vehicle used to commute to work or school? 

# % Response 

39 48% Vehicle used to commute to work 

21 26% Vehicle was not used to commute 

16 20% Vehicle used for both work and school

6 7% Vehicle used to commute to school 

How many miles did you commute each way? 

Answers to this question suggested that many respondents may not have known 

or been able to realistically estimate how many miles they drove their [retired] 

vehicle each way to work. 

Was the retired vehicle driven during the morning commute time (7:00 to 9:00 a.m.) or 

the evening commute time (5:00 to 7:00 p.m.)? 

# % Response 

38 46% Used during both commute times 

31 38% Not used during either commute time 

9 11% Used during morning commute, only

4 5% Used during afternoon commute, only 

Over the last year before the vehicle was retired, about how many miles per week was 

the vehicle driven? 

Answers to this question suggested that many respondents may not have known 

the mileage, may have combined the round trip mileage, or guessed in a manner 

that could not be substantiated by their response to the question, “about how 

many miles did they commute each way?” 

Why did you decide to retire the vehicle? 

# % Primary Reason 

34 41% The vehicle had major mechanical problems that 

would be too expensive to repair 

19 23% Owner thought it couldn’t pass the Smog Check 

12 15% The vehicle was no longer needed 

9 11% The vehicle was no longer as reliable and you 

wanted a newer vehicle 

4 4% Other 

2 2% Owner recognized it was time to retire the vehicle 

1 1% Unavailability of replacement parts 

Did you purchase a replacement vehicle? 

# % “Yes” or “No” 

43 52% No (a replacement vehicle was NOT purchased) 

39 48% Yes (a replacement vehicle was purchased) 
35 

If you purchase a replacement vehicle, how old was the vehicle you purchased? 

# % Age in model years 

23 59% Purchased a vehicle 9 model years or older 

7 18% Purchased a vehicle 8 model years old or newer 

6 16% Purchased a new vehicle 

3 8% Did not answer

If you purchased a replacement vehicle, about what was the odometer reading of the 

replacement vehicle? 

What is the estimated average odometer reading 

for the (non-new) replacement vehicles? 

Average Odometer 

reading 

For vehicles that are 8 model years old or newer 

(if entered)

128,000 

For vehicles that are 9 model years old or older 

(if entered) 

120,667 

For new vehicles 0 

What method of travel do you currently use? 

# % Primary Reason 

39 48% Used replacement vehicle you purchased 

32 39% Use another car you already owned 

5 6% Carpool or get a ride with someone else 

3 4% Other 

1 1% Use public transit 

-- -- Walk or ride a bike

How did the participant learn about the State vehicle retirement program? 

# % Primary Reason 

24 29% Friends or family 

15 18% Smog Station 

13 16% Internet or Website 

12 15% DMV 

4 5% Repair shop or parts store 

4 5% Dismantler 

4 5% Other

3 4% You or others you know participated before