**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1**  **5 Post Office Square, Suite 100 B**  **oston , MA**  **02109 -**  **3912 Memorandum**  **Date:** October 24, 2012 **Subj ect**  **:** Technical Support Document for Approval of the Massachusetts Vehicle

Inspection and Maintenance (I/M) Program and for Approval of the New Hampshire Vehicle Inspection and Maintenance (I/M) Program **To :**  Anne Arnold, Manager

Air Quality

Planning Unit, Office of Ecos ys tem Protection **From:** Ariel Garcia, Environmental E ngineer

Air Quality

Planning Unit, Office of Ecos ys tem Protection This Technical Support Document (TSD) was prepared to support a direct final rulemaking action to approve State Implementation Plan (SI P) revision s submitted on June 1, 2009 and November 30, 2009 by the Commonwealth of Massachusetts and on November 17, 2011 by

the State of New Hampshire . Th ese SI P revision s include regulation s to update the enhanced motor vehicle inspection and maintenance (I/M) program s in Massachusetts and New Hampshir e . The Massachusetts I/ M program was previously approved into the SI P on November 15, 2000 ( 65 FR 68898 ) and t he New Hampshire I/M program was previousl y approved into the SI P on January 10, 2001 ( 66 FR 1868 ) . Both state’s programs ha ve since been revise d several times . Most notably the Massachusetts and New Hampshire program s ha ve evolved to consist entirely of o n board diagnostic (ODB2) testing of 1996 and newer vehicles ; and neither program utilizes dy

namometers to phy sicall y test tail - pipe exhaust em issions . This TSD supports approv al of the revised program s because the standards and requirements will strengthen the Massachusetts and New Hampshire SI P s , and are consistent with EPA I/M requirements at 40 CFR Part 51. Background Massachusetts ’ I/M pr ogram has been in place , in some fashion, since 1983 and consisted of centralized testing facilities . In 1999, Massachusetts adopted 310 CMR 60.02, and began testing tailpipe emissions, on model y ear 1984 and newer vehicles, by utilizingdy

namometers via a decentralized , mostly , test and repair network, with some test - only facilities. In 2004, Massachusetts implemented OBD2 testing of model ye ar 1996 and newer vehicles. In 2008, Massachusetts went to an “OBD2 - testing only ” I /M program, and ceased conduct ing tailpipe emissions tests with a dy namometer. Massachusetts has implemented a number of changes to its I/M program to ensure the current program is as effective as the previously implemented program . The June 1, 2009 SI P revision submitted by

Massachu setts demonstrates that the new “OBD2 - testing only ” I /M program is more effective than the pre - existing I/M program . Another major change in 2008, was Massachusetts’ shift to emissions testing on an annual basis, where previously emissions testing had bee n conducted every two years. T he Massachusetts I/M program operates statewide and includes OBD2 testing on the following light - dut y ( less than or equal to 8,500 pounds Gross Vehicle Weight Rating (GVWR) ) and heav y - duty ( a GVWR of 8,501 pounds or more ) ve hicles if they are less than 15 ye ars old :  Non - diesel light dut y vehicles starting with model year 1996 ,  D iesel light dut y vehicles starting with model ye ar 199 7 ,  Non - diesel heavy - dut y vehicles less than or equal to 14,000 pounds GVWR starting with mode l y ear 2008 ,  Diesel heav y - duty

vehicles less than or equal to 14,000 pounds GVWR starting with model ye ar 2007 , and  All heav y - dut y vehicles greater than 14,000 pounds GVWR phased in as OBD2 s ys tems are required to be installed starting with model y ear 2010 . On January

10, 2001, EPA approved a SI P revision submitted by New Hampshire f

or its I/M program , which consisted of: state regulations incorporating an “anti - tampering” program to the existing Safet y Testing Program , state regulations incorporating a sm oke opacity testing program on heavy - dut y trucks, and a commitment for statewide implementation of OBD2 testing on vehicles required to be equipped with OBD2 sy stems. The anti - tampering program, which began in 1999, consist ed of a visual check for proper connection of emissions control components on 1980 and newer vehicles. In late 2006, New Hampshire began a paper - based OBD2 testing program on vehicles of model y ear 2002 and newer. In late 2007, OBD2 testing was expanded to all model y ear 1996 and newe r vehicles. I n 2008, New Hampshire amended its regulation to create an electronic OBD2 testing I/M program which covers light - dut y vehicles that are model ye ar 1996 and newer , and light - duty diesel vehicles that are model y ear 1997 and newer. New Hampshi re continues to operate an anti - tampering program on vehicles up to 20 ye ars old that are not subject to an OBD2 inspection. The Massachusetts and New Hampshire SI P submittal s include each state’s legal authority to perform I/M testing, the state regulati ons to implement the program s , MOBILE6 modeling runs, narrative s describing the program s in detail and appendices which include a variet y of information including the contract s to implement the program, details about the composition of the tested fleet, li sts of inspection stations, among other items.The attached checklist goes through the required elements of EPA’s I/M regulation by

section in 40 CFR Part 51 , and indicates if the State s ha ve met those requirements. If a response to an y of the checklist items varies for one of the states, it will be noted . **Recommended Action:** I recommend that we approve the SI P revision s submitted by the Commonwealth of Massachusetts on June 1, 2009 and November 30, 2009, as well as the SI P revision submitted by the Sta te of New Hampshire o n November 17, 2011 . Th e s e SI P revisions u

pdate : (1) the Massachusetts motor vehicle I/M program which is codified in the Massachusetts Department of Environmental Protection Regulations at 310 CMR 60.02 and the Massachusetts Registry of Motor Vehicle Regulations at 540 CMR 4.00; and (2) the New Hampshire motor vehicle I /M program which is codified in the New Hampshire Department of Safet y Regulations at Saf - C 3200 and Saf

- C 5800 . Th e s e motor vehicle I/M program s are intended to elimi nate excess emissions from motor vehicles in Massachusetts and New Hampshire . I recommend that EPA approve these programs because they will help reduce emissions of volatile organic compounds, nitrogen oxides, and carbon monoxide , a nd will strengthen the Massachusetts and New Hampshire SI P s . As shown in the Attachment, the revised program s are consistent with EPA’s I /M rule. Also, Massachusetts and New Hampshire ha ve demonstrated via MOBILE6 runs that the revised program s meet the federal enhanced performance standard and achieve greater emission reductions than the previousl y approved I /M program s . AttachmentAttachment

**§51.350 Applicability**  __Y___ A. Are all required elements present in this portion of the SI P? __Y____ 1. Does the SI P describe the areas that are required to implement

I/M? Statewide program s __Y_______ 2. Does the SI P include legal authority or rules which establish geographic boundaries for the program ? For Massachusetts at M.G.L. c.111, sec. 142M and for New Hampshire at RSA 266:1 and RSA 266:59 - b . __Y __ B. Is this portion of the SIP approvable? __Y _ 1. Are subject areas required to implement enhanced I /M? Statewide
__ __ a. Is enhanced I/M required in all MSAs with a 1990 population of 100,000 or mor e in an ozone transport region?
__ __ b. Is enhanced I/M required in all serious or worse ozone areas with a 1980 urban population of 200,000 or more?
_ ___ c. Is enhanced I/M required in all carbon monoxide nonattainment areas with a design value 12.7 ppm or greater and a 1980 urban population of 200,000 or more?
__ __ d. Is enhanced I/M required in urban portions of 50,000 or more as defined b y the 1990 Census that are part of a multi - state urbanized area subject to enhanced I/M?
__ NA __ 2. Are subject are as required to implement basic I /M? Not applicable

– Statewide enhanced programs
__ NA __ a. Is basic I/M required in marginal ozone areas and carbon monoxide areas that were either required to be or actuall y were in the SIP on 11/15/90?
__ NA __ b. Is basic I /M is required in all moderate ozone areas that contain one or more urbanized areas?
__ NA __ c. Is basic I/M is required in all serious or worse ozone area with a 1980 urban population of less than 200,000?
__ NA __ d. Is basic I/M required in urban portions of 50,000 or more as defined b y the 1990 Census that are part of a multi - state urbanized area subject to basic I/M?__Y __ 3. Does the program include sufficient geographic coverage? Statewide programs
_ ___ a. Is enhanced I/M required in the entirety of ea ch MSA county with a population density of 200 persons per square mile or more, based on the 1990 Census in areas required as part of an ozone transport region?
__ __ b. If counties within the MSA with population densities of less than 200 persons per squa re mile are excluded, is at least 50% of the MSA included in the program?
__ __ c. Does the I/M program cover at least the number of people in the subject urbanized area(s) based on the 1990 Census, in areas required not as part of an ozone transport reg ion?
_Y ___ 4. Does the SI P include legal authority requiring or allowing operation of the I/M program through the applicable attainment date?
_Y ___ 5. Does the SI P include a list of the ZI P codes of all areas covered by

I/M? **§51.351 Enhanced I/M Perform**  **ance Standard** __Y __ A. Are all elements present in this portion of the SI P?
__Y __ 1. Does the SI P include a modeling demonstration that the I /M

program meets the performance standard for the pollutant(s) which caused it to be subject to the program?
__Y __ 2. Does the SI P include an on - road testing program?
__Y __ B. Is this portion of the SIP approvable?
___Y _ 1. Does the I/M program meet or exceed the enhanced I /M

performance standard for each pollutant which caused the area(s) to be subject to the requirem ent?
__Y __ a. Does the SI P contain model input and output files showing the assumptions and results used in demonstrating the program meets the performance standard?
___Y _ b. Was the modeling performed using the most current version of EPA's mobile source emission model (or approved alternative)?__Y __ c. For each applicable pollutant and milestone, including the attainment deadline, enter below the emission factor for the local performance standard and the program target and indicate, whether the performan ce standard is met for each pollutant in the left column (enter NA for not applicable). If multiple runs are submitted, use tons, or attach a description of y our anal ys is and indicate "okay " below. See section 2 of each state’s SIP narrative. Massachus etts submitted modeling runs for calendar years 2009. 2010, 2011, 2012, and 2018. Massachusetts utilized the MOBILE6.2 model to generate emission factors (see Appendix 4 of the Massachusetts SIP submittal’s narrative). New Hampshire submitted modeling r uns for calendar years 2007, 2009, and 2015. New Hampshire utilized the MOBILE6.2 model to generate emission factors (see Attachment VII to the New Hampshire SIP submittal package). Both Massachusetts and New Hampshire meet the required performance stan dard evaluations for all pollutants and years modeled except for the first modeled year (2009 for Massachusetts and 2007 for New Hampshire); Massachusetts ’ modeling of the new program in 2009 shows a slight increase in VOC and CO emissions. New Hampshire’

s modeling of the new program in 2007 shows a slight increase in CO emissions. Both cases can be attributed to the limitations of the MOBILE6.2 model when modeling the new program in each state ; specifically, not enough program criteria inputs are allowed in MOBILE6.2, when modeling the new programs, to specify that there was an existing program in place prior to the new program start date.
__Y __ d. Are the assumptions used to model the performance standard targets consistent with those listed below?
____ Network: Centralized ____ Start date: 1983 for existing programs; 1995 for areas newly

subject under 1990 CAA ____ Frequency : Annual ____ Model y ears: 1968+ ____ Vehicle t ypes: LDV, LDT1, LDT2 ____ Emission test: IM240 on 1986+ ____ Emission test: Two spe ed on 1981 - 1985 ____ Emission test: Idle on 1968 - 1980____ Emission standards: 0.8/20/2.0 grams per mile (IM240) ____ Emission standards: 1.2% CO, 220 ppm HC (stead y - state) ____ Visual check: Cataly st and Inlet checks on 1984+ ____ Functional test: Pressur e test on 1983+ ____ Functional test: Purge test on 1986+ ____ Pre - 1981 stringency : 20% ____ Pre - 1981 waiver rate: 3% ____ Post - 1980 waiver rate: 3% ____ Compliance rate: 96%
__ NA __ e. Are the correct local characteristics used for the following? EPA prov ides a Low Enhanced Performance Standard input file where the state would just plug in their respective I/M program components, thus an apples - to - apples comparison is conducted against the performance standard. ___ Registration distribution ___ VMT Mix __ _ Min/Max temperature ___ Vehicle speed ___ ASTM class ___ RVP ___ Altitude Note: All applicable mobile source programs for which MOBILE specifies parameters should be included in the modeling for both the performance standard and for evaluating the stat e program, e.g. Stage II.
_ NA ___ 2. If alternative approaches, such as vehicle scrappage, have been used to contribute to meeting the performance standard, are the benefits estimated from alternatives consistent with guidance established for making such calculations?
_ NA ___ 3. If the administrator has found that NOx reductions are not beneficial for this particular ozone area, has the program been designed to offset NOx increases resulting from the repair of HC and CO failures? **§51.352 Basic I/M Perfor**  **mance Standard** _ NA ___ A. Are all elements present in this portion of the SI P?_

NA ___ 1. Does the SI P include a modeling demonstration that the I /M

program meets the performance standard for the pollutant(s) which caused either the program or the area to be subject to the program?
_ NA ___ 2. Does the SI P include a modeling demonstration that, in ozone

nonattainment areas, no increase in NOx will occur as a result of the program?
_ NA ___ B. Is this portion of the SIP approvable?
_ NA ___ 1. Does the I/M program m eet or exceed the basic I/M performance

standard for each pollutant which caused them to be subject to the requirement?
_ NA ___ a. Does the SI P contain model input and output files showing the assumptions and results used in demonstrating the program meets the performance standard?
_ NA ___ b. Was the modeling performed using the most current version of EPA's mobile source emission model (or approved alternative)? _NA __ c. For each applicable pollutant and milestone, including the attainment deadline, enter be low the emission factor for the local performance standard and the program target and indicate, whether the performance standard is met for each pollutant in the left column (enter N/A for not applicable). If multiple runs are submitted, use tons, or atta ch a description of y our anal ys is and indicate "okay " below. January 1: 1997 2000 2003 VOC Performance Standard ______ ______ ______ Program Target ______ ______ ______ NOx No I /M Factor ______ ______ ______ Program Target ______ ______ _____ _ CO 1996 2000 Performance Standard ______ ______ Program Target ______ ________

NA __ d. Are the assumptions used to model the performance standard

targets consistent with those listed below?
____ Network: Centralized ____ Start date: 1983 for existing areas; 1994 for areas newly subject under 1990 CAA ____ Frequency : Annual ____ Model y ears: 1968+ ____ Vehicle t ypes: LDV ____ Emission test: Idle on 1968+ ____ Emission standards: 1.2% CO, 220 ppm HC ____ Pre - 1981 stringency : 20% ____ Pre - 1981 waiver ra te: 0% ____ Post - 1980 waiver rate: 0% ____ Compliance rate: 100% _NA __ e. Are the correct local characteristics used for the following?
___ Registration distribution ___ VMT Mix ___ Min/Max temperature ___ Vehicle speed ___ ASTM class ___ RVP ___ Altitude Note: All applicable mobile source programs for which MOBILE5 specifies parameters should be included in the modeling for both the performance standard and for evaluating the state program, e.g. Stage II. **§51.353 Network Type and Program Evaluation**  _Y ___ A. Are all required elements present in this portion of the SI P? _Y __ 1. Does the SI P describe the network t ype for each I/M area? Test

and repair I/M programs in decentralized testing stations.
_Y ___ 2. Does the SI P include legal authority which a llows for this network ty pe to be implemented in the subject areas?
_Y ___ 3. Does the SI P include a description of the biennial program

evaluation?
_Y __ a. Is a schedule for the program evaluation included?_Y __ b. Is a methodology for the program evalua tion included? _Y __ 4. Does the SI P include legal authority which enables the State to conduct testing (each ye ar) to provide data for the biennial evaluation program? States entered into contracts for emission testing programs which include data reportin g and evaluation.
_Y ___ B. Is this portion of the SIP approvable? (Test and repair)

1. Network T ype _ NA ___ a. If an enhanced program is required for the subject area, do the regulations in the SI P specify that the program be operated in a centralized, tes t - only format?
__ NA __ b. If not (and an enhanced program is required), does the SI P specify a decentralized, test - only program?
_ NA ___ 1. Is the onl y function of the test station in this I /M program to perform official emissions testing (with the possible exceptions of conducting state safet y - related inspections, renewing vehicle registrations/drivers licenses, collecting fees/taxes, or engaging in the sale of refreshments to employ ees/waiting customers)?
__ NA __ 2. Do the I /M regulations in the SI P contain a stipulation that owners and employ ees of an official I/M test station are contractually

or legally

barred from engaging (either directly or indirectl y) in motor vehicle repair or service, motor vehicle parts sales or motor vehicle sale or leasing?
__ NA _ _ 3. Do the I /M program regulations in the SI P bar owners

and/or employ ees of official I /M testing stations from referring vehicle owners to particular repair service providers?
__Y __ c. If not (and an enhanced program is required), does the SI P specify a test - and - repair program, with an accompany ing demonstration which includes a smaller credit reduction than would normally

be assigned to the various test protocols of such a test - and - repair program? S ame credit/equally effective. States have put in place substantial oversight and monitoring efforts to guard against fraud, or incorrect testing. Stations are also audited on a regular basis.
__ NA __ 1. Is the demonstration provided based upon past performance of an existing test - and - repair program thatutiliz ed the specific test - ty pe, inspection standards and waiver criteria to be employ ed?
__ NA __ 2. Does the demonstration include, at a minimum:
__ NA __ i. Repair effectiveness survey s performed on vehicles that failed the tailpipe and evaporative emissions sy s tem tests?
__ NA __ ii. In programs with visual checks, measurement of actual tampering rates, their change over time, and the change attributable to finding/fixing tampering as opposed to the deterrence effect associated with having a visual check?
_ NA ___ iii. Results of covert auditing of inspector effectiveness?
_Y ___ 3. If 1 and 2 above are not satisfied, are there program features which provide complete assurance that the credit loss from the test - and - repair portion of the program will not exceed the ma rgin b y which a test - onl y s ys tem with the otherwise equivalent features would exceed the performance standard?, i.e. can the program still meet the performance standard? (Assertions that this is the case should be discussed with OMS immediately ).
_ NA ___ d. If a basic program is required, does the SIP specify that the program be operated using a test - and - repair or h yb rid network? If so:
_ NA ___ 1. In demonstrating equivalence with the performance standard, is full emission reduction credit claimed only fo r that portion of the fleet passing an initial or subsequent test at a test - only facility , or for that portion of the fleet failing a test - and - repair initial test, but subsequently

passing a test - only

retest?
_ NA ___ 2. Are appropriate credit loss assumpti ons assigned for portions of the fleet initially passing at a test - and - repair facility and to the portion initially failing at a test - only facility , but subsequently passing a retest at a test - and repair facility ? 2. Program Evaluation Included as sectio n 3 (Network Type and Program Evaluation) and section 16 (Data Analysis and Reporting) of each state’s SIP narrative._Y ___ a. Does the SI P provide that the first biennial evaluation be reported to EPA b y J uly

of 1997 in enhanced I/M areas?
_Y __ b. Does th e SI P include a description of: _Y __ 1. The evaluation schedule and protocol?
_Y ___ 2. The sampling methodology ?
_Y __ 3. The data collection and analy sis sy stem?
_Y __ 4. The resources and personnel for the evaluation program, and related details of the eva luation program?
_Y __ c. Do the measures included in the evaluation program (as described in the SIP) include, at a minimum:
_Y __ 1. Survey s assessing the effectiveness of repairs performed on vehicles failing the tailpipe or the evaporative emissions port ions of the test (as applicable)?
__Y __ 2. In programs with visual checks, measurement of actual tampering rates, their change over time, and the change attributable to finding/fixing tampering as opposed to deterrence effects?
__Y __ 3. The results of unde rcover survey s of inspector effectiveness related to identify ing vehicles in need of repair?
__Y __ 4. The results of mass emissions testing and evaporative emissions checks on a sample of subject vehicles, including assurance that:
__Y __ i. The sampling m ethodology results in a representative, random sample (at time of initial inspection - before repair) of at least 0.1% of the vehicles tested in a given y ear?
_Y ___ ii. The test data is submitted to EPA?
__Y __ iii. The test data is used to calculate local fleet emission factors and to assess the actual effectiveness of the I/M program? **§51.354 Adequate Tools and Resources** __Y __ A. Are all required elements present in this portion of the SI P? S ee section 4 of each state’s SIP narrative
_Y ___ 1. Does t he SI P describe the resources to be used for program

operation?
__Y __ 2. Does the SI P describe how the emission reduction targets will be

met?
__Y __ 3. Does the SI P include a detailed budget plan?
__Y __ 4. Does the SI P include a description of personnel re sources?
__Y __ 5. Does the SI P include a description of equipment resources?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Does the SI P demonstrate adequate resources to perform and

maintain all program functions?
__Y __ 2. Does the SI P have a me chanism to insure future funding of

program operations?
__Y __ a. Is a portion of the test fee or a separatel y assessed per vehicle fee collected and placed in a dedicated fund? Or,
_ NA ___ b. Does the SI P demonstrate a suitable alternative funding mechanis m?
_Y ___ 3. Does the program provide for sufficient staff to carry program duties, e.g., inspection and enforcement oversight; program evaluation and oversight; data anal ys is; and public education and training?
_Y __ 4. Does the program have equipment neces sary to achieve the objective of the program and meet program requirements? **§51.355 Test Frequency and Convenience**  _Y ___ A. Are all required elements present in this portion of the SI P?
_Y ___ 1. Does the SI P describe the test frequency in detail?
_ NA __ _ 2. Does the SI P require and include a definition of acceptabl y short

waiting times and driving distances? (Test and repair at many stations)._

NA ___ 3. Does the SI P include the legal authority , rules, or contract

provisions necessary

to implement and en force the test frequency and convenience requirements?
_Y ___ B. Is this portion of the SIP approvable?
_Y ___ 1. Do the test frequency requirements in the program rules insure that vehicles are tested at the assumed frequency ?
_Y ___ a. Does the plan describ e how the test date is assigned for vehicles that change ownership? Are such vehicles kept on the required test schedule?
_Y ___ b. Does the plan describe how the test date for newly registered used vehicles is assigned? Are such vehicles be kept on the r equired test schedule?
__Y __ c. Does the SI P explain how the test frequency will be integrated into the enforcement process?
__Y __ d. Have sufficient safeguards been built into the enforcement sy stem to ensure that vehicles will be tested according to sche dule?
__ NA __ 2. For enhanced I/M areas does the SI P describe mechanisms to

insure short wait times during actual operation? (Test and repair at many stations).
__ NA __ 3. Does the SI P describe the test network and demonstrate that

stations are conveniently located?
__ NA __ 4. For basic and enhanced programs, does the SIP define and require

adherence to regular testing hours b y the test stations?
__ NA __ 5. For basic and enhanced programs, does the SIP require testing

stations to test any

subject vehicle pre sented for a test during a station's operating hours? **§51.356 Vehicle Coverage**  __Y __ A. Are all required elements present in this portion of the SI P?
__Y __ 1. Does the SI P include a description of the number (as of a date

specified in the SI P) and ty pes (broken down b y m odel y ear, fuel ty pe, vehicle class, and weight class) of vehicles in the program, and a plan for how those vehicles will be identified? Described in section 6 of each state’s SIP narrative.__Y __ 2. Does the SI P include a description of special exemptions, i f any , allowed b y the program?
__Y __ 3. Does the SI P include legal authority or rules necessary

to implement and enforce the vehicle coverage requirement?
__Y __ B. Is this portion of the SIP approvable? (Statewide)
_Y ___ 1. Does the n umber of vehicles account for vehicles registered or

required to be registered in the program area (i.e., does the SI P provide an estimate of unregistered vehicles)?
_Y ___ 2. If fleet vehicles are subject to the I /M program, then:
_Y ___ a. Are fleets ins pected b y independent test - onl y facilities subject to the same test requirements as the primary program using the same quality

control standards?
_ NA ___ b. If fleets are not tested b y independent, test - onl y facilities, is one of the following criteria met?
_ NA ___ i. Is there no emission reduction benefit assigned for the all vehicles (including non - fleet vehicles) within the model ye ar class that dealers and fleets are allowed to self - test?
_ NA ___ ii. If credit is assumed for some fraction of the model y e ars that dealers and fleets are self - testing, is the credit assumed only

for vehicles that are not resold through a dealership or fleet in a given test cy cle, is this percentage documented, and are the requirements for receiving an y credit for the affected model y ears including requiring test - only certificates for title transfer and not allowing two self - tests in a row met?
_ NA ___ 4. Are provisions made to allow inspection of vehicles registered in

other program areas and for issuance of certificates of c ompliance or waiver?
_ NA ___ 5. Are subject vehicles registered in the program area but primarily

operated in another I/M area required to be tested in the program or by the program in the area the subject vehicle is primarily operated?
_ NA __ 6. Does the pl an include a description of the Federal fleet inspection

program?_

NA ___ a. Are Federal installation managers required to show proof of inspection for all Federal employ ee - owned vehicles operated on the installation?
_ NA ___ b. Are all Federall y owned vehic les (other than tactical military vehicles) required to be inspected?
_Y ___ 7. Does the description of special exemptions include an estimate of

the number of vehicles exempted and the percentage of the subject fleet, and are the exemptions accounted for i n the emission reduction anal ys is? **§51.357 Test Procedures and Standards**  _Y ___ A. Are all required elements present in this portion of the SI P? _Y __ 1. Does the SI P include detailed procedures for each test and the

pass/fail standards for each applicabl e model y ear for each tes t?
_Y __ 2. Does the SI P include the rule, ordinance or law establishing the

test procedures?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Do the test procedures in the SI P correspond exactly to approved EPA test procedu res or official EPA test procedures pending approval? OBD2 testing in each state.
__Y __ 2. Are initial tests performed without prior repair or adjustment at the

test facility

(except as necessary

to perform functional tests)?
__Y __ 3. Is there a provision for the vehicle operator to have access to the

test area to observe the entire inspection?
__Y __ 4. Is there a provision for rejection of vehicles with missing or

leaking exhausts or other unsafe conditions?
__Y __ 5. Are there pass/fail standards for all t est procedures for all

applicable model ye ars?
__Y __ 6. To the extent that repair of a failure on one part of a test can lead to

failure on another part, does the test procedure provide for a retest on the originall y failed component and the second compone nt?
_Y ___ a. Is an exhaust emission retest required along with a retest of the evaporative s ys tem following an evaporative sy stem failure and repair?__Y __ b. Are all criteria pollutants measured on retest after failure of a given pollutant?
_Y ___ 7. Do the pass/fail standards correspond to those used in modeling

emission reduction benefits of the program?
__Y __ a. Are standards established for both HC and CO in basic I/M areas, and also for NOx in enhanced areas?
__Y __ b. Are evaporative test standards, if an y, equal to or more stringent than EPA established standards?
__ NA __ Note: EPA encourages states to structure their regulations to allow quick response adjustment to cutpoints in case actual failure rates at start - up are not as expected.
__ N __ 8. Does the SI P have a commitment to maintain tailpipe emission test

pass/fail standards for pre - 81 vehicles so as to produce the stringency

rate used in modeling emission reduction benefits? (No tailpipe testing. OBD2 testing of 1996 and newer vehicles)
__Y __ 9. For vehicles with switched engines, are all test procedures and

standards for the chassis model y ear and t yp e applied, or for the engine model year if it is newer?
__Y __ 10. For vehicles that are switched to a fuel ty pe for which there is no certifie d configuration, are vehicles tested according to the most stringent emission standards established for that vehicle t ype and model y ear? **§51.358 Test Equipment**  __Y __ A. Are all required elements present in this portion of the SI P?
__Y __ 1. Does the S IP contain written technical specifications for all test

equipment to be used in the program? __NA _ 2. Does the SI P describe equipment acceptance testing criteria and

procedures?
_Y ___ B. Is this portion of the SIP approvable?
__Y __ 1. Are computerized tes t systems required for all measurements

performed on subject vehicles?
__Y __ 2. Are there provisions for the equipment to be:__Y __ a. Automated to the highest degree commercially available to minimize the potential for intentional fraud and/or human error ?
_Y ___ b. Secure from abuse and/or tampering? _Y __ c. Based upon written specifications? _Y __ d. Capable of simultaneously sampling dual exhaust vehicles?
_Y ___ 3. Does the test s ys tem automatically : _Y __ a. Make a pass/fail decision for all measurements? _Y __ b. Record test data to an electronic medium?
_Y ___ c. Conduct regular self testing of recording accuracy? _Y __ d. Perform electrical calibration and sy stem integrit y tests before each test, as applicable?
_Y ___ e. Initiate s ys tem lockouts for the fol lowing:
_ Y ___ 1. Tampering with security aspects of the test s ys tem?
__Y __ 2. Failing to conduct or pass periodic calibration or leak checks? _NA __ 3. Failing to conduct or pass the constant volume sampler flow rate check, if applicable? _NA __ 4. Failing to conduct or pass any of the dy namometer checks including coast - down, roll speed and roll distance, power absorption capability and inertia weight selection checks?
_ NA ___ 5. Failing to conduct the pressure monitoring device check, if applicable?
_ NA ___ 6 . Failing to conduct or pass the purge flow metering check, if applicable?
_ NA ___ 7. Having a full data recording medium or one that does not pass the cy clical redundancy check?
__Y __ 4. Is the emission test equipment capable of testing all subject

vehicle s?__

NA __ 5. Does the SI P commit to updating emission test equipment to

accommodate new technology vehicles and changes to the program?
__Y __ 6. In enhanced programs, does the SI P require that test sy stems be

connected b y a real - time data link to a hos t computer that prevents unauthorized multiple initial tests on the same vehicle and ensures data accuracy ? **§51.359 Quality Control**  __Y__ A. Are all the required elements present in this portion of the SI P?

Included as section 9 of each state’s SIP narrative.
__Y _ 1. Does the SI P include a description of quality control measures for emission measurement equipment?
__Y __ 2. Does the SI P include a description of record keeping procedures

and other measures taken to ensure document security ? __Y _ 3 . Does the SI P include the procedure manual, rule, ordinance or law

which describes and establishes quality control and record keeping requirements?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Will these measures insure that the equipment is c alibrated and

properl y maintained?
__Y __ 2. Will these measures insure that inspection, calibration records, and

control charts are accurately created, recorded, and maintained?
__ NA __ 3. Does the SI P include alternative quality control measures not includ ed under §51.359 or Appendix A of the I/M rule? _NA _ a If so, have these measures been approved b y the Administrator?
__Y __ 5. Does the SI P include periodic preventive maintenance of all

inspection equipment?
__Y __ 6. Does the SI P include a provision for computerized anal yz ers to

automatically

record quality

control check information, lockouts, attempted tampering, and other recordable circumstances that impact quality

control?
__Y __ 7. For stead y - state testing equipment, does the SI P:__Y __ a. In clude a d escription of the maintenance procedures?

__Y __ b. Do these procedures follow good engineering practices to ensure test accuracy ?
__Y __ c. In clude calibration and adjustment requirements comply ing with those described in Appendix A of the I /M rule? __Y _ _ d . Have equipment specifications including:
__Y __ 1. Minimum housing construction requirements to protect the anal yz er bench and electrical components from ambient temperature and humidity fluctuations exceeding the range of the analy zer's design specificat ions?
_ NA ___ 2. A requirement that anal yzers be designed to automatically

purge the analy

tical sy stem after each test?
_ NA ___ 3. For analy zers that use ambient air as zero air, have provisions been made to draw air from outside the inspection bay

or lane?
_ NA ___ 8. For transient exhaust emission test equipment, does the SI P: _ NA ___ a. In clude a description of the maintenance procedures?
_ NA ___ b. Do these procedures follow good engineering practices to ensure test accuracy ?
_ NA ___ c. Require the use of com puter controlled qualit y assurance checks and quality

control charts whenever possible?
_ NA ___ d. Provide exceptions to the procedures and the frequency of the checks described in Appendix A of the I /M rule?
__ NA __ i. If so, have these exceptions been appr oved by the Administrator?
_ NA ___ 9. For evaporative s ys tem functional test equipment, does the SI P: _ NA ___ a. In clude a description of the maintenance procedures?
_ NA ___ b. Do these procedures follow good engineering practices to ensure test accuracy ?
_ NA ___ c. Require the use of computer - controlled quality assurance checks and quality

control charts whenever possible?_

NA __ d. Provide exceptions to the procedures and the frequency of the checks described in Appendix A of the I /M rule? _NA __ i. If so, have these exceptions been approved by the Administrator?
_Y __ 10. Does the SI P include measures to maintain the security of all documents by

which compliance with the inspection requirement is established?
_Y ___ a. Are such documents required to be counterfei t - resistant?
_Y ___ b. Do such documents include unique serial numbers and an official seal?
__Y __ c. Does the SI P include measures to ensure that compliance documents cannot be stolen or removed without being damaged? **§51.360 Waivers and Compliance Via**  **Diagnostic Inspection** _Y___ A. Are all required elements present in this portion of the SI P? Included as

section 10 in each state’s SIP narrative.
__Y __ 1. Does the SI P include a maximum waiver rate for estimating

emission reduction benefit?
__Y __ 2. Does the SI P include a commitment to:
__Y __ a. Take corrective action to reduce the waiver rate to equal or below the maximum waiver rate used for estimating benefits, or: __Y __ b. revise the SIP and emission reductions claimed based on the actual waiv er rate?
__Y __ 3. Does the SI P include specific criteria and procedures for the

issuance of waivers?
__Y __ 4. Does the SI P include the necessary legal authority , rules, or ordinance to issue waivers, set and adjust cost limits, and administer the waiver sy stem?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Are approvable waiver issuance criteria included?__Y __ a. Are waivers allowed only after failing a retest and after all qualify ing repairs are completed?
__Y __ b. Is available warrant y cover age required to be used before expenditures are counted for waivers?
__Y __ c. Is repair of tampering not applicable towards the waiver limit?
__Y __ d Is performance and appropriateness of repairs confirmed by visual inspection and review of receipts?
_Y __ _ e. Must repairs be performed by recognized repair technicians (except for pre - 1980 models)?
__Y __ f. Are minimum expenditures required before waivers are issued? New Hampshire does not issue conventional repair expenditure waivers.
__ NA __ 1. Is the minim um expenditure at least $75 for pre - 81 vehicles and at least $200 for 1981 and newer vehicles in basic programs?
__Y __ 2. In enhanced I/M areas, is the minimum expenditure based on $450 and adjusted annually using the Consumer Price Index, with a base year of 1990, according to established procedures described in the I /M rule?
_ NA ___ g. If lower minimum waiver limits are established, are vehicles that do not pass the retest and have not received $450 in repair required to be scrapped?
_Y ___ h. If time ext ensions are granted:
_ NA ___ 1. Are criteria (bey ond vehicle model y ear or value) specified that establish that economic hardship exists?
_Y ___ 2. Is the extension granted only once for the life of a vehicle?
_Y ___ 3. Is there a mechanism for tracking that will insure vehicles can be identified as having gotten an extension?
_ NA ___ 2. If compliance via diagnostic inspection is allowed, are approvable

policies and procedures specified? _NA __ a. Is an IM240 test performed on eligible vehicles?_

NA ___ b. Are cu tpoints established in 51.351(a)(7) (or more stringent) in force for eligible vehicles?
_ NA ___ c. Is a complete, documented phy sical and functional diagnosis performed b y the I/M agency or its contractor?
_Y ___ 3. Is the quality control of waiver issuance approvable?
_Y __ a. In enhanced areas, are waivers to be issued onl y by the agency or a single contractor (no inspector issuance)?
__ NA __ b. In basic areas, if inspectors are allowed to issue waivers, are comprehensive reviews of waiver issuance conducted during overt audits?
__ NA __ c. Is a program described to alert vehicle owners to warranty coverage and way s to obtain repairs?
__Y __ d. Are procedures described to authenticate repairs receipts and prevent their reuse?
__Y __ e. Are procedures established t o limit a waiver to one test cy cle?
__Y _ f. Are procedures established to track waivers and time extensions and prevent their improper issuance? **§51.361 Motorist Compliance Enforcement**  __Y __ A. Are all required elements present in this portion of the SI P?
__Y __ 1. Does the SI P provide a detailed description of the motorist

compliance enforcement mechanism to be used in implementing the I /M program? __Y _ 2. Does the SI P identify all agencies responsible for implementing the motorist compliance enforcement program?
__Y __ 3. Does the SI P provide a description of and accounting for all

classes of exempt vehicles?
__Y __ 4. Does the SI P include a description of the plan for testing fleet

vehicles, rental car fleets, leased vehicles, federal fleet vehicles, stat e and local government vehicles, and other subject vehicles which are operated in, but not necessaril y registered in, the I /M area?__Y __ 5. Does the SI P include an estimate of the current compliance rate, including an assessment of the noncompliance due t o loopholes, counterfeiting, and unregistered vehicles?
_ NA __ 6. Does the SI P include estimates of the effect of closing the above

loopholes and otherwise improving the enforcement mechanism, if improved compliance is assumed for modeling purposes?
__ NA __ 7. Are the required estimates of compliance losses and the impact of

fixes based upon a detailed anal ys is of actual data?
__Y __ 8. Does the SI P include the legal authority and/or rules which establish the enforcement program?
__Y __ 9. Does the SI P include a commitment to an enforcement level to be

used in modeling and to be maintained, at a minimum, in practice?
__Y __ B. Is this portion of the SIP approvable?
__ NA __ 1. If the enforcement mechanism is based upon registration denial,

does the program ensure t hat an application for initial registration or reregistration of a subject vehicle is rejected without proof that the vehicle has complied with the testing requirement and been passed or waived? Based on registration suspension.
__ NA __ 2. If the enforcemen t mechanism is based upon registration denial,

does the design of this program include:
__ NA __ a. An external, readil y visible means of determining a vehicle's compliance with the registration requirement?
__ NA __ b. A schedule of testing (annual, biennial, or a mix) that clearl y determines when a vehicle must be tested?
__ NA __ c. A mechanism for certify ing that a vehicle has met the testing requirements and has been either passed or waived (and is therefore eligible for initial registration or reregistratio n), including:
__ NA __ 1. Expiration date of the certification? __ NA _ 2. Unambiguous vehicle identification information? __ NA __ 3. Whether the vehicle was passed or received a waiver?
__ NA __ d. Assurance that this certification is available, checked, and va lidated prior to the registration or reregistration of a subject vehicle?__Y __ e. Routine issuance of citations to motorists who fail to comply with the registration requirement?
__Y __ f. A penalt y schedule including mandatory, minimum, meaningful fines f

or noncompliance with the registration requirement?
__Y __ g. A requirement that noncompliance cases not be closed until compliance is demonstrated?
__Y __ h. A mechanism for preventing owners or lessors of vehicles from avoiding the testing program through manipulation of the registration or titling requirement? Statewide programs.
__Y __ i. The requirement that all applications for exemption triggering changes to a vehicle's registration information be confirmed through a ph ysical examination of the vehicle or the provision of some valid form of documentation (in the case of address changes)?
__Y __ j. A means for tracking and limiting the use of time extensions and out - of

- state exemptions?
__Y __ k. A mechanism for encouraging the enforcement of vehicle trans fer requirements when vehicle owners move into the I /M area?
__Y __ 3. If the program is in an enhanced area and is to be enforced b y

some means other than registration denial: Registration suspsension. __ NA __ a. Was the alternative mechanism part of an app roved I /M SIP prior to enactment of the 1990 Amendments to the Clean Air Act?
_ NA ___ b. Were the I/M program and alternative mechanism in question actuall y in place and operating prior to enactment of the 1990 Amendments to the Clean Air Act?
__Y __ c. Does the SI P include a demonstration that this alternative enforcement mechanism is more effective than registration denial? Registration suspsension. _ NA ___ d. Is this demonstration based upon a determination (and comparison) of the relative compliance number s and percentages for both the registration program and the I /M program?_

NA ___ i. Is this comparison based upon data for at least one full test cy cle?
_ NA ___ ii. Does this comparison show that the fraction of vehicles comply ing with the I/M program is hig her than the fraction of vehicles comply ing with the registration requirement?
_ NA ___ 4. If the program is in a basic area and is to be enforced b y an

alternative mechanism:
_ NA ___ a. Does the SI P include a demonstration that this alternative enforcement m echanism is as effective as registration denial?
_ NA __ b. Is this demonstration based upon a determination (and comparison) of the relative compliance numbers and percentages for both the registration program and the I /M program?
_ NA __ i. Is this compariso n based upon data covering at least 1 full test cy cle?
_ NA ___ ii. Does this comparison show that the fraction of vehicles comply ing with the I/M program is at least equal to the fraction of vehicles comply ing with the registration requirement?
_ Y ___ 5. I f a program is using sticker - based enforcement : Massachusetts

also includes electronic database vehicle registration analysis to identify non - compliance with emissions testing requirements.
_ Y ___ a. Does the SI P include a demonstration that this enforceme nt mechanism (in addition to meeting the general requirements for alternative enforcement mechanisms) will swiftly and effectivel y prevent operation of noncomplying subject vehicles?
_ _Y ___ b. Does the demonstration required of sticker - based programs in it em (B)(4)(a) above include an assessment of the following forms of noncompliance and a means for limiting each:
_Y ___ 1. Use of stolen, counterfeit or fraudulentl y obtained stickers?
_Y ___ 2. In states with safet y inspections, the use of "Safety Inspection Onl y" stickers on vehicles subject to the emission test ?_Y __ 3. Operation of vehicles with expired stickers, including a breakdown b y l ength of noncompliance and model y ear? Ability to electronically audit vehicles with no known final outcome.
_Y ___ c. Does the program require external, easil y visible and unambiguous identification of vehicles as subject to the I /M requirement?
_Y ___ d. Does the program require external, easil y visible and unambiguous identification of a subject vehicle's compliance stat us?
_Y __ e. Does the program include fines which make the cost of noncompliance greater than the upper limit cost of compliance?
_Y ___ f. Are the external identifiers used or planned b y the program:
_Y ___ 1. Counterfeit resistant?
_Y ___ 2. Difficult to rem ove without destroy ing?
_Y ___ 3. Durable enough to last until the next inspection cycle without fading, peeling, or otherwise deteriorating?
_Y ___ g. Does the program require the performance of compliance survey s involving at least 10% or 10,000 (whichever is less) of the subject vehicle population?
__Y __ h. Are all external compliance identifiers tracked and accounted for?
_Y ___ i. Are meaningful fines assessed against test stations for all unaccounted for identifiers?
_Y ___ 6. If a program is using comput er - matching enforcement, either as a

supplement to registration denial or in lieu of registration denial: Used by Massachusetts to enforce registration suspension as a supplement to sticker - based program.
__Y __ a. Does the SI P include a demonstration that this enforcement mechanism (in addition to meeting the general requirements for alternative enforcement mechanisms in the case of areas using computer matching in lieu of registration denial) will swiftly and effectivel y prevent operation of noncomply ing s ubject vehicles?_Y ___ b. Does the demonstration required of computer - matching programs in item (B)(6)(a) above include requirements that ensure that:
__Y __ 1. 90% of subject vehicles are in compliance within 4 months of the compliance deadline?
_Y ___ 2. S ubsequent compliance deadlines are based upon the date of scheduled compliance (not the date of actual compliance)?
_Y ___ 3. Fines for noncompliance are at least as great as the upper limit cost of compliance?
_Y ___ 4. Registration suspension and denial of reregistration for continued noncompliance?
_Y ___ 5. Demonstration of the current computer s ys tem's adequacy to store and manipulate the I /M vehicle database?
_ NA ___ 6. Provisions for periodic sy stem backup and auxiliary storage?
_Y ___ c. Does the compute r - matching program track each vehicle through the steps taken to ensure compliance, including:
_Y ___ 1. The compliance deadline? _Y ___ 2. The date of initial notification? _Y ___ 3. The dates warning letters are sent? _Y ___ 4. The dates notices of violation and other penalty notices are sent? _Y __ 5. The dates and outcomes of other steps in the process? _Y ___ 6. The final compliance date?
_Y ___ d. Does the SI P commit to compiling and reporting monthly summaries including statistics on the percentage of vehic les at each stage in the enforcement process? Real time, snapshot, of program data is available.
_ NA ___ e. Does the SI P commit to tracking the number and percentage of vehicles which are never tested as a result of being junked, sold outside the I /M area, or for other reasons? **§51.362 Motorist Compliance Enforcement Program Oversight**  __Y __ A. Are all required elements present in this portion of the SI P? See sections

11 and 12 of each state’s SIP narrative.__Y __ 1. Does the SI P include a description of how the motorist compliance enforcement program is quality controlled and quality

assured?
__Y __ 2. Does the SI P include a description of the program's information

management activities? __Y _ 3. Does the SI P include the legal authority and/or regulations n ecessary to implement this aspect of the program? )
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Does the oversight program included in the SI P quality assure its information base b y: __Y __ a. Verification of exempt vehicle status through inspec tion?
__Y __ b. Data accuracy assurance through automatic or redundant data entry ?
__Y __ c. Establishment and maintenance of an audit trail for all program documentation so that all such documentation can be controlled and tracked?
__Y __ d. The assessment o f fines against stations for missing or unaccounted for program documents reflecting the "street value" of those documents (i.e., test fee plus minimum waiver expenditure)?
__Y __ e. Analy sis of the registration database to target exemption triggering chang es in registration data?
__Y __ f. Follow - up and confirmation of exemption - triggering registration changes?
__Y _ g. Periodic audits of test records and other program documentation to assess program effectiveness?
__Y _ 2. Are the activities of enforcement pe rsonnel quality controlled through:
__Y _ a. Written procedures to be followed b y personnel directl y involved in the enforcement of the I/M program?
__Y __ b. Written procedures for personnel involved in handling or processing of program documentation, such as registration clerks or other document distributors?__Y __ i. Are these personnel to be audited using written procedures?
__Y __ c. Are all enforcement personnel (direct and indirect) covered by enforcement procedures including disciplining, retraining, o r removing such personnel who deviate from established procedures?
__Y __ 3. Are evaluations of actual or projected program effectiveness based

upon a quality

assured information base that includes:
__Y _ a. An accurate determination of the subject vehicle p opulation?
__Y __ b. Quality assurance of the registration and other program documentation databases?
__Y __ c. Periodic auditing and analy sis of the testing database?
__Y __ d. Comparison of the testing and enforcement databases to determine program effectiv eness and to trigger additional enforcement activities?
__Y __ e. The use of parking lot survey s, road - side pullovers, and other strategies to assess the compliance status of the in - use fleet (and to quality

assure the enforcement database)?
__Y __ f. Does t he SI P permit EPA audits of the enforcement process? **51.363 Quality Assurance**  __Y __ A. Are all required elements present in this portion of the SI P? Included as

section 13 of each state’s SIP narrative.
__Y __ 1. Does the SI P include a description of the qualit y assurance

program?
__Y __ 2. Does the SI P include legal authority or rules necessary

to implement the quality

assurance requirements? __Y _ B. Is this portion of the SIP approvable?
__Y __ 1. Are performance audits (overt and covert) based on wri tten

procedures?
__Y __ a. Are audit results recorded and retained in station and inspector files?__Y __ b. Are records of sufficient detail to support administrative or civil hearings required to be maintained?
__Y __ 2. Are stations and inspectors suspecte d of violating regulations as a

result of data anal ys is or consumer complaints audited at a greater frequency ?
__Y __ 3. Are overt performance audits conducted at least twice a ye ar for

each lane or test bay ?
__Y __ a. Are auditors required to check for docu ment security ?
__Y __ b. Are auditors required to check to see that required records are being kept?
__Y __ c. Are auditors required to check for proper licenses or certificates along with other required display information?
__Y __ d. Do auditors observe and produce written evaluations of each inspector's ability

to properly

perform testing procedures?
___Y _ 4. Are covert audits included in the quality assurance program?
__Y __ a. Are auditors required to remotely observe inspector performance one per ye ar per inspector for high volume stations (i.e., those performing more than 4,000 tests per ye ar)?
__Y __ b. Is the number of covert audits performed annually at least equal to the number of inspectors in the program?
__Y __ c. Are covert vehicles set to fail in s ome fashion? New Hampshire does not currently utilize vehicles set to fail.
__Y __ d. In addition to the above covert audits, are test - and - repair stations covertly

audited at least once per y ear, including the purchase of repairs and retest if the vehicle i s initially failed for tailpipe emissions?
__Y __ e. Is the required audit documentation sufficient for building a legal case and ongoing performance evaluation?
__Y __ f. Does the fleet of covert vehicles used cover the range of vehicle technology

groups an d include a full range of malfunctions?
__Y __ g. Are there a sufficient number of covert vehicles and auditors to allow for rotation to avoid detection?__

NA __ h. Are auditors (or other designated agents) able to access the inspection database to permit th e creation and maintenance of covert vehicle records?
___Y _ 5. Are station and inspector records reviewed at least monthly to assess station performance and identify potential problems?
__Y _ a. Does the review use software - based, computerized anal ys is to i dentify

statistically

inconsistent information?
__ NA __ b. Does the review require visits to stations to review records not covered in an electronic anal ys is?
__ NA __ c. Does the review require comprehensive accountability for all forms that can be used to d emonstrate compliance with the program?
__Y __ 6. Are auditors required to conduct quality control evaluations of testing equipment during overt site visits? Does the equipment audit include:
__ NA __ a. A gas audit using gases of known concentration at leas t as accurate as those used for routine quality control checks?
__ NA __ b. A check for tampering and general serviceability of the equipment?
__ NA __ c. A check for critical flow in the Constant Volume Sampler (CVS)?
__ NA __ d. A check for CVS flow calibratio n?
__ NA __ e. A check for the optimization of FID fuel - air ratio using methane?
__ NA __ f. A leak check?
__ NA __ g. A check to determine that station gas bottles used for calibration are properl y labelled and within relevant tolerances?
__ NA __ h. A functional check of the dy namometer addressing coast down, roll speed and roll distance, inertia weight selection, and power absorption?
__ NA __ i. A check of the s ys tem's ability to detect background pollutant levels?__

NA __ j. A check of the pressure monitoring dev ices used to perform the evaporative canister pressure test?
__ NA __ k. A check of the purge flow metering s ys tem?
__Y __ 7. Is completion of a formal training program required for auditors?

Does this training address
__Y __ a. The use of anal yz ers? __Y __ b. The program rules and regulations? __Y __ c. The basics of air pollution control? __Y __ d. The basics principles of engine repair related to emission performance? __Y __ e. The basics principles of motor vehicle emission control sy stems? __Y __ f. Evidence g athering? __Y __ g. State administrative procedures? __Y __ h. Quality assurance practices? __Y __ i. Covert audit procedures?
___ NA _ 8. Are auditors themselves audited at least once per year? **§51.364 Enforcement Against Contractors, Stations and Inspector**  **s** _Y ___ A. Are all the required elements present in this portion of the SI P? Included

as section 14 of each state’s SIP narrative. _Y __ 1. Does the SI P include a penalty schedule and the legal authorit y to enforce it?
__ NA __ 2. Does the SI P include an offi cial opinion from the state Attorney

General to support all claims of state constitutional impediments to the requirements under this section of the I/M rule?
__Y __ 3. Does the SI P provide descriptions of:
__Y __ a. The administrative and judicial procedure s and responsibilities relevant to the enforcement process?
__Y __ b. A listing by area of responsibility

the agencies, courts, and jurisdictions involved in the above procedures?
__Y __ c. Id entification of the bod y responsible for prosecuting and adjudicat ing cases?
__Y __ d. A description of the resources to be allocated to this function and their source(s)?__

NA __ 4. If state does not have the authority to immediatel y suspend station/inspectors, does the SI P demonstrate that sufficient resources, personnel , and sy stems are in place to process cases directly impacting emission reductions within three day s?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1 Does the penalt y schedule include categories and lists of violations

with minimum penalties to be imposed for the first, second, and subsequent violations and are those penalties adequate?
__Y __ 2. For test - and - repair programs, is there a provision for suspension of

inspector and station licenses for at least 6 months?
__ NA __ 3. For test - onl y programs, is there a provision for removal of an

inspector for at least 6 months, or a retainage penalty equivalent to an inspector's salary

for at least 6 months?
__Y __ 4. Do cases of gross neglect result in a penalt y for the first offense of

no less than $100 or 5 times of inspection fee (whichever is greater) for the contractor or the station and the inspector (if involved)? __Y _ 5. In cases of inspector incompetence, retraining required before

restoration of privileges?
__Y __ 6. Does the license or certification suspension process include

provisions that effectively bar the individual from any involvement, direct or indirect, in the inspection operation during the full term of the suspension?
__Y _ 7. Does the auditor have authority to temporarily

suspend station and inspector licenses or certificates immediatel y upon finding a violation or equipment failure? I f not:
__ NA __ a. Has the state demonstrated that its enforcement sy stem has adequate resources to hold a hearing to suspend or revoke the station or inspect or license within three business day s?
__ NA __ b. Has the state demonstrated that such authorit y is prohibited by the state's constitution?
__Y __ 8. Does the oversight agency have the authorit y to impose penalties

against licensed stations or contractors, a s well as the inspector, even if the licensee or contractor had no direct knowledge of the violation?__Y __ 9. Is the oversight agency specificall y required to maintain records of all enforcement activities, including all warnings, civil fines, suspensions , revocations, and violations?
__Y __ 10. Does the SI P commit to compiling and reporting statistics on the

above enforcement activities on an annual basis? **§51.365 Data Collection**  __Y __ A. Is data collection included as part of the I/ M program? See secti ons 15 and

16 of each state’s SIP narrative.
__Y __ 1. Does the SI P describe the ty pe of data to be collected?
__Y __ 2. Does the SI P describe how the collected data shall be used?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Is the following dat a collected with respect to all vehicles tested?
__Y __ a. Test record number? __Y __ b. Inspection station number? __Y __ c. Inspector number? __Y __ d. Test sy stem number? __Y __ e. Date of the test? __Y __ f. Emission test start time? __Y __ g. The time final emission scores are determined? __Y __ h. Vehicle identification number? __Y __ i. License plate number? __Y __ j. Test certificate number? __Y __ k. Gross vehicle weight rating (GVWR)? __Y __ l. For each vehicle: __Y __ 1. Model y ear? __Y __ 2. Make? __Y __ 3. Ve hicle t ype?
__ NA __ m. Number of cy linders or engine displacement? __ NA__ n. Transmission ty pe? __Y __ o. Odometer reading? __Y __ p. Category of test performed (i.e., initial, first retest, or subsequent retest)? __Y __ q. Fuel t ype of the vehicle (i.e., gas, diesel, or other fuel)? __ NA __ r. Ty pe of vehicle preconditioning performed (if any)? __Y __ s. Emission test sequence(s) used? __ NA __ t. Emission scores for HC, CO, CO 2 , and NOx (in enhanced areas)? OBD2 testing, only indicates proper operation of emissio n control components.__Y __ u. For each test mode, standards for HC, CO, CO+CO 2 , and NOx? OBD2 testing conducted by each state.. __Y __ v. Results (Pass/Fail/Not Applicable) for the following visual inspections : Responses are for the a nti - tampering program in New Hampshire . (NA for the Massachusetts program) __Y __ 1. Cataly tic converter? __Y __ 2. Air sy stem? __ N __ 3. Gas cap? __ N __ 4. Evaporative s ys tem? __Y __ 5. Positive crankcase ventilation (PCV) valve? __Y _ 6. Fuel inlet restrictor? __Y __ 7. Other visual inspection for which emission reduction credit is claimed?
__ NA __ w. Pass/fail results for: __ N __ 1. Evaporative s ys tem pressure test? __ N __ 2. Evaporative s ys tem purge test?
__ N __ x. Total purge flow in liters achieved during the test?
__Y __ 2. Does the SI P include a commitment to gather and report the results

of the quality

control checks described in §51.359?
__Y __ a. Will each check be identified by : __Y _ 1. Station number? __Y __ 2. Sy stem number? __Y __ 3. Date? __Y __ 4. Start time?
__Y __ b. Will the d ata reports contain the concentration values of the calibration gases used to perform the gas characterization portion of the quality

control checks? **§51.366 Data Analysis and Reporting**  __Y __ A. Is data analy sis and reporting included as part of the I /M program? See

sections 15 and 16 of each state’s SIP narrative.
__Y __ 1. Does the SI P include a commitment to submit annual reports? __Y _ 2. Does the SI P include a commitment to submit biennial

evaluations?
__Y __ B. Is this portion of the SIP approvable?
__ NA __ 1. Is the first annual report scheduled to be submitted within 18

months of initial program implementation?__Y __ 2 Does the SI P commit to submit a report each July , for January through December of the previous y ear, which provides statistics on t he testing element of the program? Will this report cover the following program statistics: a. The number of vehicles tested by : __Y __ 1. Model y ear? __Y __ 2. Vehicle t ype?
__Y __ b. By model y ear and vehicle ty pe, the number and percentage of vehicles: Data for OBD2 testing is collected, analyzed, and reported. __Y __ 1. Failing the emissions test initially ? __Y __ 2. Failing each emission control component check initially ? __Y __ 3. Failing the evaporative sy stem functional and integrit y checks initially ? __Y __ 4. Failing the first retest for tailpipe emissions? __Y __ 5. Passing the first retest for tailpipe emissions? __Y __ 6. Initiall y failed vehicles passing the second or subsequent retest for tailpipe emissions? __Y __ 7. Initiall y failed vehicles passi ng each emission control component check on the first or subsequent retest by component? __Y __ 8. Initiall y failed vehicles passing the evaporative s ystem functional and integrit y checks on the first or subsequent retest b y component? __Y __ 9. Initiall y fa iled vehicles receiving a waiver? __Y __ 10. Vehicles with no known final outcome (regardless of reason)?
__Y __ c. The initial test volume by model y ear and test station?
__Y __ d. The initial test failure rate by model y ear and test station?
__ N __ e. The av erage increase or decrease in after repair tailpipe emission levels for HC, CO, and NOx by model y ear and vehicle t ype, for vehicles receiving a mass emissions test or approved alternative?
__Y __ 3. Does the SI P commit to submit a report each July , for Jan uary

through December of the previous y ear, which provides statistics on the quality

assurance program? Will this report cover the following program statistics: a. The number of inspection stations and lanes which are in operation: __Y __ 1. Throughout th e ye ar?__Y __ 2. Only part of the y ear? b. The number of stations and lanes operating throughout the ye ar: __Y __ 1. Receiving overt performance audits in the y ear? __Y __ 2. Not receiving overt performance audits in the y ear? __Y __ 3. Receiving covert perf ormance audits in the y ear? __Y __ 4. Not receiving covert performance audits in the y ear? __Y __ 5. That have been shut down as a result of overt performance audits? c. The number of covert audits: __Y __ 1. Conducted with the vehicle set to fail the emissi on test? __Y __ 2. Conducted with the vehicle set to fail the component check? __Y __ 3. Conducted with the vehicle set to fail the evaporative sy stem checks? __Y __ 4. Conducted with the vehicle set to fail two or more checks? __Y __ 5. Resulting in a false p ass for emissions? __Y __ 6. Resulting in a false pass for component checks? __Y __ 7. Resulting in a false pass for the evaporative s ys tem check? __Y __ 8. Resulting in a false pass for two or more checks?

d. The number of inspectors: __Y __ 1. Suspended, fi red, or prohibited from testing because of covert audits? __Y __ 2. Suspended, fired, or prohibited from testing for other causes? __Y __ 3. Fined for an y reason?

e. The number of stations: __Y __ 1. Suspended, fired, or prohibited from testing because of co vert audits? __Y __ 2. Suspended, fired, or prohibited from testing for other causes? __Y __ 3. Fined for an y reason?
__Y __ f. The number of inspectors licensed or certified to conduct testing? g. The number of hearings: __Y __ 1. Held to consider adverse ac tions against inspectors and stations? __Y __ 2. Resulting in adverse actions against inspectors and stations?__Y __ h. The total amount collected in fines from inspectors and stations by

ty pe of violation?
__Y __ i. The total number of covert vehicles avail able for undercover audits over the ye ar?
_Y __ j. The number of covert auditors available for undercover audits?
_Y ___ 4. Does the SI P commit to submit a report each July , for January

through December of the previous y ear, which provides statistics on the quality

control program? Will this report cover the following program statistics:
_Y ___ a. The number of emission testing sites and lanes in use in the program? _Y ___ b. The number of equipment audits by station and lane? _Y ___ c. The number and percentag e of stations that have failed equipment audits? _Y ___ d. Number and percentage of stations and lanes shut down as a result of equipment audits?
_Y ___ 5. Does the SI P commit to submit a report each July , for January

through December of the previous y ear, w hich provides statistics on the enforcement program? a. For all varieties of enforcement programs, will this report cover the following program statistics?
__Y __ 1. An estimate of the number of vehicles subject to the program, including the results of an anal ys is of the registration data base?
__Y __ 2. The percentage of motorist compliance based upon a comparison of the number of valid final tests with the number of subject vehicles?
__Y __ 3. The total number of compliance documents issued to stations?
__Y __ 4. The number of missing compliance documents?
__Y __ 5. The number of time extensions and exemptions granted to motorists?
__Y __ 6. The number of compliance survey s conducted, number of vehicles survey ed in each, and the compliance rates found?b. For registration denial enforcement programs, will this report cover the following program statistics?
__Y __ 1. An assessment of the program's efforts and actions to prevent motorists from falsely registering vehicles out of the program area or falsely changin g fuel t ype or weight class on the vehicle registration?
__Y __ 2. The results of special studies to investigate these activities?
__Y __ 3. The number of registration file audits, including
__Y __ i. The number of registrations reviewed? __Y __ ii. Compliance rates found?

c. For computer - matching based enforcement programs, will this report cover the following program statistics?
__ NA __ 1. The number and percentage of subject vehicles that were tested by the initial deadline, and by other milestones in the cy cle?
__ NA __ 2. An assessment of the program's efforts to detect and enforce against motorists falsel y changing vehicle classifications to circumvent program requirements, and the frequency

of this t ype of activity ?
__ NA __ 3. The number of enforcement sy ste m audits, and the error rate found during those audits? d. For sticker - based enforcement sy stems, will this report cover the following program statistics?
__Y __ 1. An assessment of efforts to prevent, detect, and enforce against sticker theft and counterf eiting, and the frequency of such activit y?
__Y __ 2. A report on efforts to detect and enforce against motorists falsel y changing vehicle classifications to circumvent program requirements, and the frequency of this ty pe of activity ?
__ NA __ 3. The number o f parking lot sticker audits conducted, the number of vehicles surveyed in each, and the noncompliance rate found during those audits?__Y __ 5. Does the SI P commit to submit the first biennial report by July 1996 (in basic I/M programs) or July 1997 (in en hanced programs)? Will the report include:
__Y __ a. Changes made in program design, funding, personnel levels, procedures, regulations, and legal authorit y, with detailed discussion and evaluation of the impact on the program of all such changes?
__Y __ b. Any weaknesses or problems identified in the program?
__Y __ c. Steps taken to correct those problems, the result, and any future efforts planned? **§51.367 Inspector Training and Licensing or Certification**  __Y __ A. Are all required elements present in th is portion of the SI P? See section 17

of each state’s SIP narrative.
__Y __ 1. Evidence that the state has the authority to require mandatory inspector training? __Y _ 2. Does the SI P contain a description of inspector training program?
__Y __ 3. Does the SI P contain a description of the written and hands - on

tests?
__Y __ 4. Does the SI P contain a description of the licensing or certification

process?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Are inspectors required to receive formal training?
__Y __ a. Does the training program at a minimum cover the following areas: __Y __ 1. Air pollution problems (causes and effects)? __Y __ 2. Purpose, function and goal of state inspection program? __Y __ 3. State inspection regulations? __Y __ 4. Test procedures and rationale for their design? __Y __ 5. Emission control devices, configuration and inspection? __Y __ 6. Test equipment operation, calibration and maintenance? __Y __ 7. Quality control procedures? __Y __ 8. Public relations? __Y __ 9. Safety and health issu es related in the inspection process?__Y __ b. Does the state commit to monitoring and evaluating the training program delivery , if the training is not administered by the program?
__Y __ 2. Are inspectors required to be licensed or certified?
__Y _ a. Mus t inspectors pass a written test covering the elements required in the training program above?
__Y __ c. Is a correct score of at least 80% (or lower if an occupational anal ys is justifies) required to pass the test?
__Y __ d. Does the inspector have to demo nstrate the ability to, without assistance, conduct a proper inspection, properl y use equipment, and follow other procedures in order to pass the training course?
__ NA __ e. In test - onl y programs, is the certification or licensing administered b y a state ag ency or contractor other than the testing department or testing contractor?
__Y __ 3. Are inspectors required to be relicensed or recertified?
__Y __ a. Is there a requirement that the license or certification expires within 2 y ears?
__Y __ b. Is there a requ irement that upon expiration of the license or certification, the inspector undergoes either a refresher training course prior to license or certification renewable or a comprehensive skill examination and determination of inspector competency ? **§51.368 Public Information and Consumer Protection**  __Y __ A. Are all required elements present in this portion of the SI P? ? See section

18 of each state’s SIP narrative.
__Y __ 1. Does the SI P include a plan for informing the public on an ongoing

basis throughout t he life of the I/M program?
__Y __ 2. Does the SI P include a plan to offer motorists that fail the test

repair facility

performance data and diagnostic information in enhanced areas?
__Y __ 4. Does the SI P include provisions to protect the public from fraud

and abuse b y inspectors, mechanics, and others involved in the I /M program?__Y __ B. Is this portion of the SIP approvable? 1. Does the public awareness plan include strategies to educate the public on the:
__Y __ a. The air qualit y problem? __Y __ b. The r equirements of federal and state law? __Y _ c. The role of motor vehicles in the air quality problem? __Y __ d. The need for and benefits of an inspection program? __Y __ e. The way s to maintain a vehicle in a low - emission condition? __Y __ f. How to find a qu alified repair technician? __Y __ g. The requirements of the I/M program?
__Y __ 2. For motorists that fail the test in enhanced areas, will the

information offered to motorists include:
__Y __ a. A list of repair facilities in the area and statistics on:
__Y __ 1. The number of vehicles submitted for a retest after repair? __Y __ 2. The percentage of vehicles passing on first retest? __Y __ 3. The percentage of vehicles requiring more than one trip to comply ? __Y __ 4. The percentage of vehicles receiving a waiv er?
__Y __ b. Software - generated, interpretive diagnostic information based on the particular portions of the test that were failed?
__Y __ 3. Does the consumer protection provisions include:
__Y __ a. A challenge mechanism to contest the result of an inspect ion?
__Y __ b. Protection of whistle blowers and following up on complaints by the public or others involved in the process?
__Y __ c. A program to assist owners in obtaining warrant y covered repairs for eligible vehicles that fail a test? **§51.369 Improvi**  **ng Repair Effectiveness** ___Y _ A. Are all required elements present in this portion of the SI P? Included as

section 19 of each state’s SIP narrative.
___Y _ 1. Does the SI P include legal authority , rules or procedures necessary

to conduct performance monitor ing, provide technical assistance, and insure training is available?
___Y _ B. Is this portion of the SIP approvable?___Y _ 1. Does the SI P provide for technical assistance related to diagnosis and repair of vehicles that fail the I /M test to the repair ind ustry ?
___Y _ a. Is there a mechanism to regularl y inform repair facilities of changes in the inspection program, training program, common problems being found with particular engine families, diagnostic t ype and the like?
___Y _ b. Does the SI P provide for the establishment of an ongoing hot line service to assist technicians with specific repair problems, and answer legal and technical questions?
___Y _ 2. In enhanced areas, is there a s ys tem of repair facility performance monitoring?
___Y _ a. Does this sy st em include gathering statistics, by repair facility , on: ___Y _ 1. The number of vehicles submitted for a retest after repair? ___Y _ 2. The percentage of vehicles passing on first retest? __Y __ 3. The percentage of vehicles requiring more than one trip to comply ? __Y __ 4. The percentage of vehicles receiving a waiver?
__Y __ b. Is a summary of the performance of individual motor vehicle repair facilities, that convey s information on the relative ability of repair facilities in providing effective and conven ient repair, provided to the public at the time of initial failure?
__Y __ c. Does the s ys tem provide feedback to individual repair facilities on a regular basis (at least annuall y)?
__Y __ d. Is a completed repair form indicating which repairs were performe d, any

recommended additional repairs, and identification of the facility that performed the repairs required as a prerequisite for retest?
__Y __ 3. Is repair technician training available which includes the four areas

listed below or are there provisions to make such training available?
__Y __ a. Diagnosis and repair of malfunctions in computer controlled, closed - loop vehicles?__Y __ b. Application of emission control theory and diagnostic data to the diagnosis and repair of failures on the transient emiss ions test and the evaporative sy stem functional test?
__Y __ c. Utilization of diagnostic information on sy stematic or repeated failures observed in the transient test and the evaporative s ys tem function test?
__Y __ d. General training on the various subsy s tems related to engine emissions control? **§51.370 Compliance with Recall Notices**  __Y __ A. Are all required elements present in this portion of the SI P? ? See section

20 of each state’s SIP narrative.
__Y __ 1. Does the SI P include provisions to ensure v ehicles subject to

enhanced I/M receive all required recall repairs? Once EPA makes available.
__Y __ 2. Does the SI P include legal authority to require owners or lessees of vehicles with unresolved recalls to show proof of compliance with recall in order t o complete the inspection or registration cy cle?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Are motorists required by regulations to obtain recall repairs in

order to complete the inspection process or before obtaining a vehicle registratio n?
__Y __ a. Is there a process for notify ing motorists of a specific recall requirement prior to the test deadline? Awaiting EPA action.
__Y __ b. If so, is compliance required on the next registration or inspection date after state notification of recall w as received by the vehicle owner?
__Y __ c. If not, are motorists required to comply when notified at the station of the outstanding recall, prior to completing the inspection or registration requirement?
__Y __ 2. Are qualit y control methods used to insur e recall repairs are

properl y documented and tracked?
__ N __ a. Are vehicles with unresolved recalls automatically identified as noncomply ing when they show up for testing or registration?__

N __ b. Does the SI P commit to updating the list of unresolved reca lls at least quarterly ? Awaiting EPA action.
__Y __ c. Is there a means to document repairs on vehicles that have received repairs but remain on the recall list?
__ N __ d. Does the data s ys tem include the recall campaign numbers for vehicles with unresolved recalls?
__ N _ 3. Does the SI P commit to submitting an annual report providing

information on recall compliance including **§51.371 On**  **- road Testing**  __Y __ A. Are all required elements present in this portion of the SI P? ? Included as

section 21 of each s tate’s SIP narrative.
__Y __ 1. In enhanced areas, does the SI P include an on - road testing

program?
__Y __ 2. In enhanced areas, does the SI P include the legal authority

necessary to implement the on - road testing program?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Does the SI P include a detailed description of the on - road testing

program, including:
__Y __ a. Ty pes of testing to be used? __Y __ b. Test limits and criteria? __Y __ c. The number of vehicles (percentage of the fleet) to be tested? __Y __ d. The budget dedicated to the on - road testing effort? __Y __ e. The methods for collecting and reporting the results of on road testing? __Y __ f. The methods for anal yz ing and utilizing the results of on road testing? __Y __ g. The number of employ ees de dicated to the on - road testing effort?
__Y __ 2. Are motorists that fail the on - road test required to get an off - cy cle inspection and bring the vehicle into compliance? **§51.372 State Implementation Plan Submissions**  __Y __ A. Are all required elements pres ent in this portion of the SI P?__Y __ 1. Does the SI P include a schedule of implementation of the program?
__Y __ B. Is this portion of the SIP approvable?
__Y __ 1. Does the schedule include milestones for the following:
__Y __ a. Obtaining enabling or statu tory authorit y? __Y __ b. Proposal of draft regulations and final promulgation? __Y __ c. Issuance of final specifications and procedures, including RFPs? __Y __ d. Licensing or certification of stations and inspectors? __Y __ e. The start of mandatory testing __Y __ f. The date full - stringency cutpoints take effect?
__Y __ 2. Does the anal ys is of emission level targets use current EPA mobile

source emission model meet the performance standards described in §51.351 or §51.352 of the regulation subpart?
__ NA __ a. If an alternative model approved b y the Administrator is used, does it also meet the same performance standard?
___ NA _ 3. If the program is not county wide, does the SI P include a list of the ZIP codes of areas covered by the program? Statewide programs.
_ __ NA _ 4. Is there a discussion of the required design elements, including

provisions for federal facility compliance?
___Y _ 5. Does the SI P include legal authority requiring or allowing operation of the I/M program through the applicable attainment date?
_ __Y _ 6. Is there evidence of adequate funding, resources, implementing

regulations, interagency

agreements, and memorandum of understanding?
___Y _ 7. Does the SI P include a description of personnel resources? **§51.373 Implementation Deadlines**  ___Y _ A. Ar e all required scheduling elements present in this portion of the SI P?
___Y _ 1. Does the SI P include deadlines for implementing the program?
___Y _ B. Is this portion of the SIP approvable?
___ NA _ 1. If the program is a basic, decentralized sy stem, is it sc heduled to be

fully implemented b y J anuary 1, 1994?___

NA _ 2. If the program is a basic, centralized s ys tem, is it scheduled to be

fully implemented b y J uly

1, 1994?
___Y _ 3. If the program is enhanced, are all enhanced features scheduled to

be implemented by

January 1, 1995 with the following exceptions?
___ NA _ a. In an area switching from an existing test - and - repair network

to a test - only

network, is at least 30% of the subject vehicle population (statewide) scheduled to be tested starting January 1, 1995 ?
___ NA _ c. In areas starting new test - only programs and those with existing test - only

programs, does the SI P include a phase - in of new test procedures between January 1, 1995 and January 1, 1996?
___ NA _ b. Are all subject vehicles scheduled to be tested s tarting

January 1, 1996?
___ NA _ 4. In areas newl y required to implement I /M (not subject as of

November 15, 1992)
___ NA _ a. Does the SI P include implementation:
___ NA _ i. In enhanced areas, within 2 y ears of obtaining legal authority ? ___ NA _ ii. In basic d ecentralized areas, within 1 y ear of obtaining legal authority ? ___ NA _ iii. In basic centralized areas, within 2 y ears of obtaining legal authority ?
___ NA _ b. Has the legal authority for the program been obtained during the first applicable legislative ses sion?