UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

5 Post Office Square, Suite 100

Boston, MA 02109-3912

Memorandum

Date: October 24, 2012

Subject: 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 Ecosystem Protection

From: Ariel Garcia, Environmental Engineer

Air Quality Planning Unit, Office of Ecosystem Protection

This Technical Support Document (TSD) was prepared to support a direct final 

rulemaking action to approve State Implementation Plan (SIP) revisions 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. These SIP revisions include

regulations to update the enhanced motor vehicle inspection and maintenance (I/M) 

programs in Massachusetts and New Hampshire. The Massachusetts I/M program was 

previously approved into the SIP on November 15, 2000 (65 FR 68898) and the New 

Hampshire I/M program was previously approved into the SIP on January 10, 2001 (66

FR 1868). Both state’s programs have since been revised several times. Most notably

the Massachusetts and New Hampshire programs have evolved to consist entirely of onboard diagnostic (ODB2) testing of 1996 and newer vehicles; and neither program 

utilizes dynamometers to physically test tail-pipe exhaust emissions. This TSD supports

approval of the revised programs because the standards and requirements will strengthen 

the Massachusetts and New Hampshire SIPs, and are consistent with EPA I/M 

requirements at 40 CFR Part 51.

Background

Massachusetts’ I/M program 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 year 1984 and newer vehicles, by utilizing 
dynamometers via a decentralized, mostly, test and repair network, with some test-only

facilities. In 2004, Massachusetts implemented OBD2 testing of model year 1996 and 

newer vehicles. In 2008, Massachusetts went to an “OBD2-testing only” I/M program, 

and ceased conducting tailpipe emissions tests with a dynamometer. 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 SIP revision 

submitted by Massachusetts 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 been conducted every two years. The Massachusetts I/M program 

operates statewide and includes OBD2 testing on the following light-duty (less than or 

equal to 8,500 pounds Gross Vehicle Weight Rating (GVWR)) and heavy-duty (a 

GVWR of 8,501 pounds or more) vehicles if they are less than 15 years old:

 Non-diesel light duty vehicles starting with model year 1996,

 Diesel light duty vehicles starting with model year 1997,

 Non-diesel heavy-duty vehicles less than or equal to 14,000 pounds 

GVWR starting with model year 2008,

 Diesel heavy-duty vehicles less than or equal to 14,000 pounds GVWR 

starting with model year 2007, and

 All heavy-duty vehicles greater than 14,000 pounds GVWR phased in as 

OBD2 systems are required to be installed starting with model year 2010.

On January 10, 2001, EPA approved a SIP revision submitted by New Hampshire for its 

I/M program, which consisted of: state regulations incorporating an “anti-tampering” 

program to the existing Safety Testing Program, state regulations incorporating a smoke 

opacity testing program on heavy-duty trucks, and a commitment for statewide 

implementation of OBD2 testing on vehicles required to be equipped with OBD2 

systems. The anti-tampering program, which began in 1999, consisted 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 year 2002 and newer. In late 2007, OBD2 testing was expanded to all model year 

1996 and newer vehicles. In 2008, New Hampshire amended its regulation to create an 

electronic OBD2 testing I/M program which covers light-duty vehicles that are model 

year 1996 and newer, and light-duty diesel vehicles that are model year 1997 and newer. 

New Hampshire continues to operate an anti-tampering program on vehicles up to 20 

years old that are not subject to an OBD2 inspection.

The Massachusetts and New Hampshire SIP submittals include each state’s legal 

authority to perform I/M testing, the state regulations to implement the programs, 

MOBILE6 modeling runs, narratives describing the programs in detail and appendices 

which include a variety of information including the contracts to implement the program, 

details about the composition of the tested fleet, lists 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 States have met those requirements. If a 

response to any of the checklist items varies for one of the states, it will be noted.

Recommended Action: I recommend that we approve the SIP revisions submitted by

the Commonwealth of Massachusetts on June 1, 2009 and November 30, 2009, as well as 

the SIP revision submitted by the State of New Hampshire on November 17, 2011. 

These SIP revisions update: (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 Safety Regulations at Saf-C 3200 and Saf-C 5800. 

These motor vehicle I/M programs are intended to eliminate 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, and will strengthen the Massachusetts and New 

Hampshire SIPs. As shown in the Attachment, the revised programs are consistent with 

EPA’s I/M rule. Also, Massachusetts and New Hampshire have demonstrated via 

MOBILE6 runs that the revised programs meet the federal enhanced performance 

standard and achieve greater emission reductions than the previously approved I/M 

programs. 

Attachment
Attachment 

§51.350 Applicability

__Y___ A. Are all required elements present in this portion of the SIP? 

__Y____ 1. Does the SIP describe the areas that are required to implement 

I/M? Statewide programs

__Y_______ 2. Does the SIP 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 more 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 by the 1990 Census that are part of a multi-state 

urbanized area subject to enhanced I/M?

__NA__ 2. Are subject areas 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 actually 

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 by 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 each 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 square 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 region?

_Y___ 4. Does the SIP include legal authority requiring or allowing 

operation of the I/M program through the applicable attainment 

date?

_Y___ 5. Does the SIP include a list of the ZIP codes of all areas covered by

I/M?

§51.351 Enhanced I/M Performance Standard

__Y__ A. Are all elements present in this portion of the SIP?

__Y__ 1. Does the SIP 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 SIP 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 requirement?

__Y__ a. Does the SIP 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 performance 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 your analysis and indicate "okay" below. See section 2 of 

each state’s SIP narrative.

Massachusetts 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 runs 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 standard 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 years: 1968+

____ Vehicle types: LDV, LDT1, LDT2

____ Emission test: IM240 on 1986+

____ Emission test: Two speed 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 

(steady-state)

____ Visual check: Catalyst and Inlet checks 

on 1984+

____ Functional test: Pressure 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 provides 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 state 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 Performance Standard

_NA___ A. Are all elements present in this portion of the SIP?
_NA___ 1. Does the SIP 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 SIP 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 meet or exceed the basic I/M performance 

standard for each pollutant which caused them to be subject to the 

requirement?

_NA___ a. Does the SIP 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 below 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 attach a description 

of your analysis 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 years: 1968+

____ Vehicle types: LDV

____ Emission test: Idle on 1968+

____ Emission standards: 1.2% CO, 220 ppm HC

____ Pre-1981 stringency: 20%

____ Pre-1981 waiver rate: 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 SIP?

_Y__ 1. Does the SIP describe the network type for each I/M area? Test 

and repair I/M programs in decentralized testing stations.

_Y___ 2. Does the SIP include legal authority which allows for this network 

type to be implemented in the subject areas?

_Y___ 3. Does the SIP 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 evaluation included?

_Y__ 4. Does the SIP include legal authority which enables the State to 

conduct testing (each year) to provide data for the biennial 

evaluation program? States entered into contracts for emission 

testing programs which include data reporting and evaluation.

_Y___ B. Is this portion of the SIP approvable? (Test and repair)

1. Network Type

_NA___ a. If an enhanced program is required for the subject area, do 

the regulations in the SIP specify that the program be 

operated in a centralized, test-only format?

__NA__ b. If not (and an enhanced program is required), does the SIP 

specify a decentralized, test-only program?

_NA___ 1. Is the only function of the test station in this I/M program 

to perform official emissions testing (with the possible

exceptions of conducting state safety-related inspections, 

renewing vehicle registrations/drivers licenses, collecting 

fees/taxes, or engaging in the sale of refreshments to 

employees/waiting customers)?

__NA__ 2. Do the I/M regulations in the SIP contain a stipulation 

that owners and employees of an official I/M test station 

are contractually or legally barred from engaging (either 

directly or indirectly) 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 SIP bar owners 

and/or employees 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 SIP 

specify a test-and-repair program, with an accompanying 

demonstration which includes a smaller credit reduction than 

would normally be assigned to the various test protocols of 

such a test-and-repair program? Same 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 that 
utilized the specific test-type, inspection standards and 

waiver criteria to be employed?

__NA__ 2. Does the demonstration include, at a minimum:

__NA__ i. Repair effectiveness surveys performed on vehicles 

that failed the tailpipe and evaporative emissions 

system 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 margin by which a test-only system 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 hybrid 

network? If so:

_NA___ 1. In demonstrating equivalence with the performance 

standard, is full emission reduction credit claimed only

for 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 assumptions 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-andrepair facility? 

2. Program Evaluation Included as section 3 (Network Type and 

Program Evaluation) and section 16 (Data Analysis and 

Reporting) of each state’s SIP narrative.
_Y___ a. Does the SIP provide that the first biennial evaluation be 

reported to EPA by July of 1997 in enhanced I/M areas?

_Y__ b. Does the SIP include a description of:

_Y__ 1. The evaluation schedule and protocol?

_Y___ 2. The sampling methodology?

_Y__ 3. The data collection and analysis system?

_Y__ 4. The resources and personnel for the evaluation program, 

and related details of the evaluation program?

_Y__ c. Do the measures included in the evaluation program (as 

described in the SIP) include, at a minimum:

_Y__ 1. Surveys assessing the effectiveness of repairs performed 

on vehicles failing the tailpipe or the evaporative 

emissions portions 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 undercover surveys of inspector 

effectiveness related to identifying 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 methodology 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 year?

_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 SIP? See section 4 

of each state’s SIP narrative

 _Y___ 1. Does the SIP describe the resources to be used for program 

operation?

__Y__ 2. Does the SIP describe how the emission reduction targets will be 

met?

__Y__ 3. Does the SIP include a detailed budget plan?

__Y__ 4. Does the SIP include a description of personnel resources?

__Y__ 5. Does the SIP include a description of equipment resources?

__Y__ B. Is this portion of the SIP approvable?

__Y__ 1. Does the SIP demonstrate adequate resources to perform and 

maintain all program functions?

__Y__ 2. Does the SIP have a mechanism to insure future funding of 

program operations?

__Y__ a. Is a portion of the test fee or a separately assessed per vehicle 

fee collected and placed in a dedicated fund? Or,

_NA___ b. Does the SIP demonstrate a suitable alternative funding 

mechanism?

_Y___ 3. Does the program provide for sufficient staff to carry program 

duties, e.g., inspection and enforcement oversight; program 

evaluation and oversight; data analysis; and public education and 

training?

_Y__ 4. Does the program have equipment necessary 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 SIP?

_Y___ 1. Does the SIP describe the test frequency in detail?

_NA___ 2. Does the SIP require and include a definition of acceptably short 

waiting times and driving distances? (Test and repair at many 

stations).
_NA___ 3. Does the SIP include the legal authority, rules, or contract 

provisions necessary to implement and enforce 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 describe 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 

required test schedule?

__Y__ c. Does the SIP explain how the test frequency will be 

integrated into the enforcement process?

__Y__ d. Have sufficient safeguards been built into the enforcement 

system to ensure that vehicles will be tested according to 

schedule?

__NA__ 2. For enhanced I/M areas does the SIP describe mechanisms to 

insure short wait times during actual operation? (Test and repair 

at many stations).

__NA__ 3. Does the SIP 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 by the test stations?

__NA__ 5. For basic and enhanced programs, does the SIP require testing 

stations to test any subject vehicle presented 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 SIP?

__Y__ 1. Does the SIP include a description of the number (as of a date 

specified in the SIP) and types (broken down by model year, fuel 

type, 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 SIP include a description of special exemptions, if any, 

allowed by the program?

__Y__ 3. Does the SIP 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 number of vehicles account for vehicles registered or 

required to be registered in the program area (i.e., does the SIP 

provide an estimate of unregistered vehicles)?

_Y___ 2. If fleet vehicles are subject to the I/M program, then: 

_Y___ a. Are fleets inspected by independent test-only facilities 

subject to the same test requirements as the primary program 

using the same quality control standards?

_NA___ b. If fleets are not tested by independent, test-only 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 

year class that dealers and fleets are allowed to self-test?

_NA___ ii. If credit is assumed for some fraction of the model years 

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 cycle, is this percentage 

documented, and are the requirements for receiving any 

credit for the affected model years 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 compliance 

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 plan include a description of the Federal fleet inspection 

program?
_NA___ a. Are Federal installation managers required to show proof of 

inspection for all Federal employee-owned vehicles operated 

on the installation?

_NA___ b. Are all Federally owned vehicles (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 in the emission 

reduction analysis?

§51.357 Test Procedures and Standards

_Y___ A. Are all required elements present in this portion of the SIP?

_Y__ 1. Does the SIP include detailed procedures for each test and the 

pass/fail standards for each applicable model year for each test?

_Y__ 2. Does the SIP 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 SIP correspond exactly to approved 

EPA test procedures 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 test procedures for all 

applicable model years?

__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 originally failed component and the second component? 

_Y___ a. Is an exhaust emission retest required along with a retest of 

the evaporative system following an evaporative system 

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 any, 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 SIP 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 year and type applied, or for the 

engine model year if it is newer?

__Y__ 10. For vehicles that are switched to a fuel type for which there is no 

certified configuration, are vehicles tested according to the most 

stringent emission standards established for that vehicle type and 

model year? 

§51.358 Test Equipment

__Y__ A. Are all required elements present in this portion of the SIP?

__Y__ 1. Does the SIP contain written technical specifications for all test 

equipment to be used in the program?

__NA_ 2. Does the SIP describe equipment acceptance testing criteria and 

procedures?

_Y___ B. Is this portion of the SIP approvable?

__Y__ 1. Are computerized test 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 system 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 system integrity tests 

before each test, as applicable?

_Y___ e. Initiate system lockouts for the following:

_ Y___ 1. Tampering with security aspects of the test system?

__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 dynamometer 

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 cyclical redundancy check?

__Y__ 4. Is the emission test equipment capable of testing all subject 

vehicles? 
__NA__ 5. Does the SIP commit to updating emission test equipment to 

accommodate new technology vehicles and changes to the 

program? 

__Y__ 6. In enhanced programs, does the SIP require that test systems be 

connected by a real-time data link to a host 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 SIP? 

Included as section 9 of each state’s SIP narrative.

__Y_ 1. Does the SIP include a description of quality control measures for 

emission measurement equipment?

__Y__ 2. Does the SIP include a description of record keeping procedures 

and other measures taken to ensure document security?

__Y_ 3. Does the SIP 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 calibrated and 

properly maintained?

__Y__ 2. Will these measures insure that inspection, calibration records, and 

control charts are accurately created, recorded, and maintained?

__NA__ 3. Does the SIP include alternative quality control measures not 

included under §51.359 or Appendix A of the I/M rule?

_NA_ a If so, have these measures been approved by the 

Administrator?

__Y__ 5. Does the SIP include periodic preventive maintenance of all 

inspection equipment?

__Y__ 6. Does the SIP include a provision for computerized analyzers to 

automatically record quality control check information, lockouts, 

attempted tampering, and other recordable circumstances that 

impact quality control?

__Y__ 7. For steady-state testing equipment, does the SIP:
__Y__ a. Include a description of the maintenance procedures?

__Y__ b. Do these procedures follow good engineering practices to 

ensure test accuracy?

__Y__ c. Include calibration and adjustment requirements complying 

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 analyzer bench and electrical components from 

ambient temperature and humidity fluctuations exceeding 

the range of the analyzer's design specifications?

_NA___ 2. A requirement that analyzers be designed to 

automatically purge the analytical system after each test?

_NA___ 3. For analyzers 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 SIP:

_NA___ a. Include 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?

_NA___ 9. For evaporative system functional test equipment, does the SIP:

_NA___ a. Include 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 SIP 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 counterfeit-resistant?

_Y___ b. Do such documents include unique serial numbers and an 

official seal?

__Y__ c. Does the SIP 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 SIP? Included as 

section 10 in each state’s SIP narrative.

__Y__ 1. Does the SIP include a maximum waiver rate for estimating 

emission reduction benefit?

__Y__ 2. Does the SIP 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 waiver rate? 

__Y__ 3. Does the SIP include specific criteria and procedures for the 

issuance of waivers?

__Y__ 4. Does the SIP include the necessary legal authority, rules, or 

ordinance to issue waivers, set and adjust cost limits, and 

administer the waiver system?

__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 

qualifying repairs are completed?

__Y__ b. Is available warranty coverage 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 minimum 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 extensions are granted:

_NA___ 1. Are criteria (beyond vehicle model year 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 cutpoints established in 51.351(a)(7) (or more stringent) 

in force for eligible vehicles?

_NA___ c. Is a complete, documented physical and functional diagnosis 

performed by 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 only 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 ways to obtain repairs?

__Y__ d. Are procedures described to authenticate repairs receipts and 

prevent their reuse?

__Y__ e. Are procedures established to limit a waiver to one test 

cycle?

__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 SIP?

__Y__ 1. Does the SIP provide a detailed description of the motorist 

compliance enforcement mechanism to be used in implementing 

the I/M program?

__Y_ 2. Does the SIP identify all agencies responsible for implementing 

the motorist compliance enforcement program?

__Y__ 3. Does the SIP provide a description of and accounting for all 

classes of exempt vehicles?

__Y__ 4. Does the SIP include a description of the plan for testing fleet 

vehicles, rental car fleets, leased vehicles, federal fleet vehicles, 

state and local government vehicles, and other subject vehicles 

which are operated in, but not necessarily registered in, the I/M 

area?
__Y__ 5. Does the SIP include an estimate of the current compliance rate, 

including an assessment of the noncompliance due to loopholes, 

counterfeiting, and unregistered vehicles?

_NA__ 6. Does the SIP 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 analysis of actual data?

__Y__ 8. Does the SIP include the legal authority and/or rules which 

establish the enforcement program?

__Y__ 9. Does the SIP 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 that 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 enforcement mechanism is based upon registration denial, 

does the design of this program include:

__NA__ a. An external, readily visible means of determining a vehicle's 

compliance with the registration requirement?

__NA__ b. A schedule of testing (annual, biennial, or a mix) that clearly 

determines when a vehicle must be tested?

__NA__ c. A mechanism for certifying that a vehicle has met the testing 

requirements and has been either passed or waived (and is 

therefore eligible for initial registration or reregistration), 

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 

validated 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 penalty schedule including mandatory, minimum, 

meaningful fines for 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 exemptiontriggering changes to a vehicle's registration information be 

confirmed through a physical 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 

transfer 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 by 

some means other than registration denial: Registration 

suspsension.

__NA__ a. Was the alternative mechanism part of an approved 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 

actually in place and operating prior to enactment of the 1990 

Amendments to the Clean Air Act?

__Y__ c. Does the SIP 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 numbers 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 cycle?

_NA___ ii. Does this comparison show that the fraction of vehicles 

complying with the I/M program is higher than the 

fraction of vehicles complying with the registration 

requirement?

_NA___ 4. If the program is in a basic area and is to be enforced by an 

alternative mechanism:

_NA___ a. Does the SIP include a demonstration that this alternative 

enforcement mechanism 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 comparison based upon data covering at least 1 full 

test cycle?

_ NA___ ii. Does this comparison show that the fraction of vehicles 

complying with the I/M program is at least equal to the 

fraction of vehicles complying with the registration 

requirement?

_ Y___ 5. If 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 SIP include a demonstration that this enforcement 

mechanism (in addition to meeting the general requirements 

for alternative enforcement mechanisms) will swiftly and 

effectively prevent operation of noncomplying subject 

vehicles?

__Y___ b. Does the demonstration required of sticker-based programs in 

item (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 fraudulently obtained 

stickers?

_Y___ 2. In states with safety inspections, the use of "Safety 

Inspection Only" stickers on vehicles subject to the 

emission test ?
_Y__ 3. Operation of vehicles with expired stickers, including a 

breakdown by length of noncompliance and model year?

Ability to electronically audit vehicles with no known 

final outcome.

_Y___ c. Does the program require external, easily visible and 

unambiguous identification of vehicles as subject to the I/M 

requirement?

_Y___ d. Does the program require external, easily visible and 

unambiguous identification of a subject vehicle's compliance 

status?

_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 by the program:

_Y___ 1. Counterfeit resistant?

_Y___ 2. Difficult to remove without destroying?

_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 

surveys 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 computer-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 SIP 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 effectively prevent operation of noncomplying 

subject 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. Subsequent 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 system's adequacy

to store and manipulate the I/M vehicle database?

_NA___ 6. Provisions for periodic system backup and auxiliary

storage?

_Y___ c. Does the computer-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 SIP commit to compiling and reporting monthly

summaries including statistics on the percentage of vehicles 

at each stage in the enforcement process? Real time, 

snapshot, of program data is available.

_NA___ e. Does the SIP 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 SIP? See sections 

11 and 12 of each state’s SIP narrative.
__Y__ 1. Does the SIP include a description of how the motorist compliance 

enforcement program is quality controlled and quality assured?

__Y__ 2. Does the SIP include a description of the program's information 

management activities?

__Y_ 3. Does the SIP include the legal authority and/or regulations 

necessary 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 SIP quality assure its 

information base by:

__Y__ a. Verification of exempt vehicle status through inspection?

__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 of 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. Analysis of the registration database to target exemptiontriggering changes 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 personnel quality controlled 

through:

__Y_ a. Written procedures to be followed by personnel directly 

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, 

or 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 population?

__Y__ b. Quality assurance of the registration and other program 

documentation databases?

__Y__ c. Periodic auditing and analysis of the testing database?

__Y__ d. Comparison of the testing and enforcement databases to 

determine program effectiveness and to trigger additional 

enforcement activities?

__Y__ e. The use of parking lot surveys, 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 the SIP permit EPA audits of the enforcement process? 

51.363 Quality Assurance

__Y__ A. Are all required elements present in this portion of the SIP? Included as 

section 13 of each state’s SIP narrative.

__Y__ 1. Does the SIP include a description of the quality assurance 

program?

__Y__ 2. Does the SIP 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 written 

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 suspected of violating regulations as a 

result of data analysis or consumer complaints audited at a greater 

frequency?

__Y__ 3. Are overt performance audits conducted at least twice a year for 

each lane or test bay?

__Y__ a. Are auditors required to check for document 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 year per inspector for high volume 

stations (i.e., those performing more than 4,000 tests per 

year)?

__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 some 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 year, including the 

purchase of repairs and retest if the vehicle is 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 and 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 the 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 analysis 

to identify statistically inconsistent information?

__NA__ b. Does the review require visits to stations to review records 

not covered in an electronic analysis?

__NA__ c. Does the review require comprehensive accountability for all 

forms that can be used to demonstrate 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 least 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 calibration?

__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 properly labelled and within relevant 

tolerances?

__NA__ h. A functional check of the dynamometer addressing coastdown, roll speed and roll distance, inertia weight selection, 

and power absorption?

__NA__ i. A check of the system's ability to detect background pollutant 

levels?
__NA__ j. A check of the pressure monitoring devices used to perform 

the evaporative canister pressure test?

__NA__ k. A check of the purge flow metering system?

__Y__ 7. Is completion of a formal training program required for auditors? 

Does this training address

__Y__ a. The use of analyzers?

__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 

systems?

__Y__ f. Evidence gathering?

__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 Inspectors

_Y___ A. Are all the required elements present in this portion of the SIP? Included 

as section 14 of each state’s SIP narrative.

_Y__ 1. Does the SIP include a penalty schedule and the legal authority to 

enforce it?

__NA__ 2. Does the SIP include an official 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 SIP provide descriptions of:

__Y__ a. The administrative and judicial procedures 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. Identification of the body responsible for prosecuting and 

adjudicating 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 immediately suspend 

station/inspectors, does the SIP demonstrate that sufficient 

resources, personnel, and systems are in place to process cases 

directly impacting emission reductions within three days?

__Y__ B. Is this portion of the SIP approvable?

__Y__ 1 Does the penalty 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-only 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 penalty 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 immediately upon finding a 

violation or equipment failure? If not:

__NA__ a. Has the state demonstrated that its enforcement system has 

adequate resources to hold a hearing to suspend or revoke the 

station or inspector license within three business days?

__NA__ b. Has the state demonstrated that such authority is prohibited 

by the state's constitution?

__Y__ 8. Does the oversight agency have the authority to impose penalties 

against licensed stations or contractors, as well as the inspector, 

even if the licensee or contractor had no direct knowledge of the 

violation?
__Y__ 9. Is the oversight agency specifically required to maintain records of 

all enforcement activities, including all warnings, civil fines, 

suspensions, revocations, and violations?

__Y__ 10. Does the SIP 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 sections 15 and 

16 of each state’s SIP narrative.

__Y__ 1. Does the SIP describe the type of data to be collected?

__Y__ 2. Does the SIP describe how the collected data shall be used?

__Y__ B. Is this portion of the SIP approvable?

__Y__ 1. Is the following data collected with respect to all vehicles tested?

__Y__ a. Test record number?

__Y__ b. Inspection station number?

__Y__ c. Inspector number?

__Y__ d. Test system 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 year?

__Y__ 2. Make?

__Y__ 3. Vehicle type?

__NA__ m. Number of cylinders or engine displacement?

__NA__ n. Transmission type?

__Y__ o. Odometer reading?

__Y__ p. Category of test performed (i.e., initial, first retest, or 

subsequent retest)?

__Y__ q. Fuel type of the vehicle (i.e., gas, diesel, or other fuel)?

__NA__ r. Type of vehicle preconditioning performed (if any)?

__Y__ s. Emission test sequence(s) used?

__NA__ t. Emission scores for HC, CO, CO2, and NOx (in enhanced 

areas)? OBD2 testing, only indicates proper operation of 

emission control components.
__Y__ u. For each test mode, standards for HC, CO, CO+CO2, and 

NOx? OBD2 testing conducted by each state..

__Y__ v. Results (Pass/Fail/Not Applicable) for the following visual 

inspections: Responses are for the anti-tampering program in 

New Hampshire. (NA for the Massachusetts program)

__Y__ 1. Catalytic converter?

__Y__ 2. Air system?

__N__ 3. Gas cap?

__N__ 4. Evaporative system?

__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 system pressure test?

__N__ 2. Evaporative system purge test?

__N__ x. Total purge flow in liters achieved during the test?

__Y__ 2. Does the SIP 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. System number?

__Y__ 3. Date?

__Y__ 4. Start time?

__Y__ b. Will the data 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 analysis 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 SIP include a commitment to submit annual reports?

__Y_ 2. Does the SIP 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 SIP commit to submit a report each July, for January

through December of the previous year, which provides statistics 

on the testing element of the program? Will this report cover the 

following program statistics: 

a. The number of vehicles tested by:

__Y__ 1. Model year?

__Y__ 2. Vehicle type?

__Y__ b. By model year and vehicle type, 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 system functional and integrity 

checks initially?

__Y__ 4. Failing the first retest for tailpipe emissions?

__Y__ 5. Passing the first retest for tailpipe emissions?

__Y__ 6. Initially failed vehicles passing the second or subsequent 

retest for tailpipe emissions?

__Y__ 7. Initially failed vehicles passing each emission control 

component check on the first or subsequent retest by

component?

__Y__ 8. Initially failed vehicles passing the evaporative system 

functional and integrity checks on the first or subsequent 

retest by component?

__Y__ 9. Initially failed vehicles receiving a waiver?

__Y__ 10. Vehicles with no known final outcome (regardless of 

reason)?

__Y__ c. The initial test volume by model year and test station?

__Y__ d. The initial test failure rate by model year and test station?

__N__ e. The average increase or decrease in after repair tailpipe 

emission levels for HC, CO, and NOx by model year and 

vehicle type, for vehicles receiving a mass emissions test or 

approved alternative?

__Y__ 3. Does the SIP commit to submit a report each July, for January

through December of the previous year, 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 the year?
__Y__ 2. Only part of the year?

b. The number of stations and lanes operating throughout the 

year:

__Y__ 1. Receiving overt performance audits in the year?

__Y__ 2. Not receiving overt performance audits in the year?

__Y__ 3. Receiving covert performance audits in the year?

__Y__ 4. Not receiving covert performance audits in the year?

__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 emission test?

__Y__ 2. Conducted with the vehicle set to fail the component 

check?

__Y__ 3. Conducted with the vehicle set to fail the evaporative 

system checks?

__Y__ 4. Conducted with the vehicle set to fail two or more 

checks?

__Y__ 5. Resulting in a false pass for emissions?

__Y__ 6. Resulting in a false pass for component checks?

__Y__ 7. Resulting in a false pass for the evaporative system 

check?

__Y__ 8. Resulting in a false pass for two or more checks?

d. The number of inspectors:

__Y__ 1. Suspended, fired, or prohibited from testing because of 

covert audits?

__Y__ 2. Suspended, fired, or prohibited from testing for other 

causes?

__Y__ 3. Fined for any reason?

e. The number of stations:

__Y__ 1. Suspended, fired, or prohibited from testing because of 

covert audits?

__Y__ 2. Suspended, fired, or prohibited from testing for other 

causes?

__Y__ 3. Fined for any reason?

__Y__ f. The number of inspectors licensed or certified to conduct 

testing?

g. The number of hearings:

__Y__ 1. Held to consider adverse actions 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 type of violation?

__Y__ i. The total number of covert vehicles available for undercover 

audits over the year?

_Y__ j. The number of covert auditors available for undercover 

audits?

_Y___ 4. Does the SIP commit to submit a report each July, for January

through December of the previous year, 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 percentage 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 SIP commit to submit a report each July, for January

through December of the previous year, which 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 analysis 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 surveys conducted, number of 

vehicles surveyed 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 changing fuel type 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 cycle?

__NA__ 2. An assessment of the program's efforts to detect and 

enforce against motorists falsely changing vehicle 

classifications to circumvent program requirements, and 

the frequency of this type of activity?

__NA__ 3. The number of enforcement system audits, and the error 

rate found during those audits?

d. For sticker-based enforcement systems, will this report cover 

the following program statistics?

__Y__ 1. An assessment of efforts to prevent, detect, and enforce 

against sticker theft and counterfeiting, and the frequency

of such activity?

__Y__ 2. A report on efforts to detect and enforce against motorists 

falsely changing vehicle classifications to circumvent 

program requirements, and the frequency of this type of 

activity?

__NA__ 3. The number of parking lot sticker audits conducted, the 

number of vehicles surveyed in each, and the 

noncompliance rate found during those audits?
__Y__ 5. Does the SIP commit to submit the first biennial report by July

1996 (in basic I/M programs) or July 1997 (in enhanced 

programs)? Will the report include:

__Y__ a. Changes made in program design, funding, personnel levels, 

procedures, regulations, and legal authority, 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 this portion of the SIP? 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 SIP contain a description of inspector training program?

__Y__ 3. Does the SIP contain a description of the written and hands-on 

tests?

__Y__ 4. Does the SIP 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 issues 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. Must 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 

analysis justifies) required to pass the test?

__Y__ d. Does the inspector have to demonstrate the ability to, without 

assistance, conduct a proper inspection, properly use 

equipment, and follow other procedures in order to pass the 

training course?

__NA__ e. In test-only programs, is the certification or licensing 

administered by a state agency 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 years?

__Y__ b. Is there a requirement 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 SIP? ? See section 

18 of each state’s SIP narrative.

__Y__ 1. Does the SIP include a plan for informing the public on an ongoing 

basis throughout the life of the I/M program?

__Y__ 2. Does the SIP include a plan to offer motorists that fail the test 

repair facility performance data and diagnostic information in 

enhanced areas?

__Y__ 4. Does the SIP include provisions to protect the public from fraud 

and abuse by 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 quality problem?

__Y__ b. The requirements 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 ways to maintain a vehicle in a low-emission condition?

__Y__ f. How to find a qualified 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 waiver?

__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 inspection?

__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 warranty covered 

repairs for eligible vehicles that fail a test?

§51.369 Improving Repair Effectiveness

___Y_ A. Are all required elements present in this portion of the SIP? Included as 

section 19 of each state’s SIP narrative.

___Y_ 1. Does the SIP include legal authority, rules or procedures necessary

to conduct performance monitoring, provide technical assistance, 

and insure training is available?

___Y_ B. Is this portion of the SIP approvable?
___Y_ 1. Does the SIP provide for technical assistance related to diagnosis 

and repair of vehicles that fail the I/M test to the repair industry?

___Y_ a. Is there a mechanism to regularly inform repair facilities of 

changes in the inspection program, training program, 

common problems being found with particular engine 

families, diagnostic type and the like?

___Y_ b. Does the SIP 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 system of repair facility performance 

monitoring?

___Y_ a. Does this system 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 conveys information on the relative 

ability of repair facilities in providing effective and 

convenient repair, provided to the public at the time of initial 

failure?

__Y__ c. Does the system provide feedback to individual repair 

facilities on a regular basis (at least annually)?

__Y__ d. Is a completed repair form indicating which repairs were 

performed, 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 emissions 

test and the evaporative system functional test?

__Y__ c. Utilization of diagnostic information on systematic or 

repeated failures observed in the transient test and the 

evaporative system function test?

__Y__ d. General training on the various subsystems related to engine 

emissions control?

§51.370 Compliance with Recall Notices

__Y__ A. Are all required elements present in this portion of the SIP? ? See section 

20 of each state’s SIP narrative.

__Y__ 1. Does the SIP include provisions to ensure vehicles subject to 

enhanced I/M receive all required recall repairs? Once EPA makes 

available.

__Y__ 2. Does the SIP include legal authority to require owners or lessees of 

vehicles with unresolved recalls to show proof of compliance with 

recall in order to complete the inspection or registration cycle? 

__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 registration?

__Y__ a. Is there a process for notifying 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 was 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 quality control methods used to insure recall repairs are 

properly documented and tracked?

__N__ a. Are vehicles with unresolved recalls automatically identified 

as noncomplying when they show up for testing or 

registration?
__N__ b. Does the SIP commit to updating the list of unresolved 

recalls 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 system include the recall campaign numbers 

for vehicles with unresolved recalls? 

__N_ 3. Does the SIP 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 SIP? ? Included as 

section 21 of each state’s SIP narrative.

__Y__ 1. In enhanced areas, does the SIP include an on-road testing 

program?

__Y__ 2. In enhanced areas, does the SIP 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 SIP include a detailed description of the on-road testing 

program, including:

__Y__ a. Types 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 onroad testing?

__Y__ f. The methods for analyzing and utilizing the results of onroad testing?

__Y__ g. The number of employees dedicated to the on-road testing 

effort?

__Y__ 2. Are motorists that fail the on-road test required to get an off-cycle 

inspection and bring the vehicle into compliance?

§51.372 State Implementation Plan Submissions

__Y__ A. Are all required elements present in this portion of the SIP?
__Y__ 1. Does the SIP 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 statutory authority?

__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 analysis 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 by the Administrator is 

used, does it also meet the same performance standard?

___NA_ 3. If the program is not county wide, does the SIP 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 SIP 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 SIP include a description of personnel resources?

§51.373 Implementation Deadlines

___Y_ A. Are all required scheduling elements present in this portion of the SIP?

___Y_ 1. Does the SIP include deadlines for implementing the program?

___Y_ B. Is this portion of the SIP approvable?

___NA_ 1. If the program is a basic, decentralized system, is it scheduled to be 

fully implemented by January 1, 1994?
___NA_ 2. If the program is a basic, centralized system, is it scheduled to be 

fully implemented by July 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 SIP 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 starting 

January 1, 1996?

___NA_ 4. In areas newly required to implement I/M (not subject as of 

November 15, 1992)

___NA_ a. Does the SIP include implementation:

___NA_ i. In enhanced areas, within 2 years of obtaining legal 

authority?

___NA_ ii. In basic decentralized areas, within 1 year of obtaining 

legal authority?

___NA_ iii. In basic centralized areas, within 2 years of obtaining 

legal authority?

___NA_ b. Has the legal authority for the program been obtained during 

the first applicable legislative session?