-10-

customers are technicians and shop owners. Charges are assessed
on a per problem basis.

4) Autoline Telediagnosis
2714 Patton Rd.
Roseville, MN 55113
Contact no.: Rob Schuyt 800-288-6220

Autoline has been in existence for over five years. The
company handles about 10,000 calls per month and has 4200 factory
manuals and all factory bulletins. The company also has Expertec,
a CD ROM service from General Motors with PROM updates. The
company has an extensive database with 500,000 fixes logged into
the system. Customers include independent shops, service
stations, fleets, and car dealers. Autoline runs hot lines for
NAPA, Parts Plus, Mighty Auto Parts, ASA, NTDRA, Amoco, Exxon,
Chevron, BP, and Marathon. The company can also receive live data
over the phone from a modem on test equipment. Hours of operation
are 7:00 a.m. to 7:00 p.m. CST, Monday through Friday. A
quarterly newsletter giving technical information is also
published and a sample copy can be obtained from the contact
listed above. Charges for this hot line service are by the
minute, ‘with no monthly fees and no sign-up fees.

5) GE Capital Fleet Services
Three Capital Drive
Eden Prairie, MN 55244
Information source: Mike Peterzen 612-828-2103
Contact no.: 612-828-2799

GE Capital Fleet Services' past experience does not have
service center subscribers; its clients are owners of fleet
vehicles being serviced at shops not owned by the fleets. The
company provides guidance to mechanics, and also issues purchase
orders to repair or rental facilities, so drivers do not incur out
of pocket expenses.

At present, GE Capital Fleet Services is completing the
development of an Enhanced Inspection/Maintenance Technical Hot
Line. Their proposed system includes online access to emission
results by VIN, the ability to access a database of historical
data, the ability to view State parameters regarding emission
tests, and the ability to create statistical reports from the
database of calls.


-1-

1.0 REGULATORY REQUIREMENTS

Section 51.369(a) (2) of the Inspection/Maintenance Program
Requirements published November 5, 1992 in the Federal Register
states:

"The (oversight) agency shall provide a hot line service to
assist repair technicians with specific repair problems, answer
technical questions that arise in the repair process, and answer
questions related to the legal requirements of state and federal
law with regard to emission control device tampering, engine
switching, or similar issues".

In essence, this regulatory language contains three distinct
service areas that a program agency is required to provide through
a hot line. These three areas are:

(1) provide specific repair advice,

(2) provide technical information during the repair process,
and

(3) respond to legal and agency policy questions on specific
vehicle conditions/repair strategy needed for
compliance.

The provision for a hot line service is required in both
basic and enhanced I/M areas. This includes the areas of the
country that choose to opt into either the basic or enhanced I/M
programs if they seek the corresponding level of emission
reduction credit.

Further, §51.369(d) requires that the SIP (State
Implementation Plan) "... include a description of the technical
assistance plan to be implemented, ...." The "technical
assistance" language refers to the requirements of §51.369(a),
which includes the hot line service requirements.

2.0 MINIMUM HOT LINE CAPABILITIES THAT MEET REGULATORY
REQUIREMENTS

The state program agency must provide a hot line service that
provides a basic level of technical service in order to assist the
technician (or anyone seeking technical advice, e.g., do-it-
yourselfers) during the repair process and also answers the legal
and policy questions as they relate to specific vehicle conditions
and repairs. The state may choose to contract for some of these
services if certain conditions, as discussed in Section 3.0, are
met.

With regard to providing repair advice and technical
information during the repair process, the staff on this hot line
must have an understanding of the I/M test procedures used in that
state, and an understanding of the basic vehicle systems and
components, as well as a working knowledge of how the two relate
to each other in order to answer generic repair questions. It is


-6-

5.0 GUIDELINES FOR SELECTING COMMERCIAL HOT LINES

Listed below are guidelines state agencies could consider for
selection or development of a hot line service. This list may not
encompass all the criteria necessary to consider in choosing a hot
line; however, the list should be broad enough to provide useful
guidance. Even so, individual states may have specific needs not
mentioned here, and of course, those would need to be considered
when using the following guidance. In preparing these guidelines,
EPA reviewed the guidelines from several sources, including the
Coalition for Safer, Cleaner Vehicles' (CSCV), Education/Training
Advisory Board. Some of those guidelines were incorporated where
appropriate.

Even though these guidelines are directed more toward the
commercial services, many of the criteria specified in these
guidelines would still be applicable to a state-run program. When
reviewing these guidelines it is important to remember that the
IM240 data are not yet available. A hot line should have the
capability to use and incorporate these data when they do become
available.

5.1 Guidelines for Enhanced I/M Areas

1) A hot line service should provide the auto repair
facilities with comprehensive technical information.
Personnel providing repair information should have in-depth
knowledge of the vehicle in question.

The hot line should be capable of providing assistance in: a)
diagnosis and repair of malfunctions in computer controlled,
closed loop vehicles (e.g., 1981 and later) as well as
earlier vehicles (e.g., those with oxidation catalysts or
non-catalyst) to which the I/M program applies, b) the
application of emission control theory and diagnostic data to
the diagnosis and repair on the transient emission test and
the evaporative system functional checks, and c) the use of
diagnostic information on systematic or repeated failures
observed in the transient emission test and the evaporative
_system functional checks.

2) The hot line capacity should be sized to minimize access
time during periods of high demand.

3) The hot line should provide a mechanism to ensure that the
necessary preliminary systems checks have been completed
prior to making the initial repair call. This will minimize
the hot line service from being flooded with inquiries
relating to basic service questions. This may take the form
of a standard checklist to be provided by the hot line
service or initial questioning by the hot line technician to
determine if these checks have been made. The existence and


-3-

Conceptually, paraphrased areas (1) and (2), which address
the issues of providing specific repair advice and technical
information during the repair process, probably have the most
flexibility. Some of the options available to the states include
the following.

1) The state could operate the entire repair information
function itself.

2) The state could have a contractor handle all the repair
information hot line functions including detailed repair
questions.

3) The state could provide a repair hot line that provides
a basic level of technical service, and refers detailed
repair questions to commercial repair sevices. With this
approach, the referral could be: (1) to a specific hot line
service under contract, (2) to one of several hot line
services under contract, (3) to one or many hot line services
that meet state requirements (but not under contract), or (4)
any service that the state has identified that can provide
support for the specific repair questions asked by the
technicians (i.e., essentially a free market with minimal
oversight to assure that the minimum referral requirements in
Section 2.0 are met).

4) The state could turn over the operation and management
of a basic repair hot line to the state I/M contractor, and
the contractor would subsequently refer the more detailed
questions to commercial hot line services, or

5) The state could work in partnership with an I/M
contractor in establishing and operating a hot line service
(i.e., a combination of options 3 and 4 above).

Other options in admininstering the functional requirements
of the repair hot line may exist.

Paraphrased area (3) of the rule encompasses a variety of
services. The most straightforward service requirement is the
dissemination of the legal requirements and policies of the I/M
program. A more complicated service requirement is responding to
questions from the service industry that may involve interpreting
both Federal and State legal and policy guidelines for individual
situations. Interpretation of legal and policy guidelines may be
considered "an inherently governmental function" in many states.
As an aside, Federal regulations prohibit the Federal government
from performing an inherently governmental function under
contract.

EPA feels that a state could contract out area (3) if the
following conditions are met:


-2-

not necessary that such a service offer repair advice on an in-
depth vehicle-specific level which is available from many

commercial hot line services (e.g., "What is the voltage on pin 9
of model xx?" as opposed to a generic question, "How could a purge
failure affect IM240 emissions?"). Therefore, the staff of any

technical hot line service offered under §51.369(a) (2) must at
least have a general understanding of emission repair diagnostic
procedures.

With regard to responding to legal and agency policy
questions, the hot line staff that is chosen must be familiar with
state and federal specific I/M rules, regulations, and policies in
regard to all aspects of the I/M program (tampering, engine
switching policy, catalyst replacement policy, consumer protection
policy, location of I/M test stations, I/M cutpoints for different
model years, waivers, reinspection, etc.).

For minimum access requirements, it is preferable, but not
required, that the technical hot line established under
51.369(a)(2) be separate from the public awareness information
number which could be established by a state under 51.368(a).
However, technicians (or others) in need of advice during the
repair process should not be made to wait while general program
information is disseminated. If a state chooses to operate only
one hot line, it must ensure that the hot line has enough capacity
or special routing features so technicians will not have to wait
for repair information.

If the repair questions are more vehicle-specific than
generic, hot line personnel must be able to refer the technician
to additional sources of information that could further assist the
technician in the repair process. At a minimum, hot line
personnel should be prepared to provide the technicians with
general information summarizing methods to access available
commercial hot line services that support the specific area of the
question, as well as their general capabilities and costs. The
section titled, "Guidelines for Selecting Commergial Hot Lines"
discussed later in this document (Section 5.0) may provide a
starting point for the states in preparing this information.

A state may also wish to propose alternatives to this basic
referral requirement, such as referring technicians to a specific
repair manual. However, the burden would be on the state to show
how such alternatives would work in practice (e.g., would the hot
line operator have specific knowledge of appropriate repair
manuals; where would the technician obtain the manual if the
technician did not have it, etc.).

3.0 OPTIONS FOR HOT LINE MANAGEMENT

There is considerable flexibility with regard to how the rule
is administered.


-5-

hot line service, as long as sufficient information is provided to
allow a reasonable expectation that the alternate method would
result in a system that would meet the requirements of

§51.369(a) (2). Finally, §51.369(d) requires that the SIP include
a "... description of the technical assistance program to be
implemented ...." A description of the method(s) that will be

used to administer the hot line and the functions/capabilities
that will be offered by the service are considered to be part of
the description of the technical assistance program required by
§51.369(d).

4.0 REPAIR SUPPORT ENHANCEMENTS

In addition to the approaches that have been discussed above,
the state may opt to enhance its program using other approaches
beyond the minimum program that is required. Listed below are
several ideas, some of which states are presently proposing, as
enhancements to technician assistance. This may not be an
exhaustive list, but should still be useful. Individual states
may wish to develop other enhancements to meet their specific
needs.

1) The state (or its contractor) may wish to negotiate
pricing and access arrangements with one or more national
repair hot line services which a registered technician could
call for free, or at nominal charge, or at cost.

2) The state may wish to identify minimum qualifications
for referral services to be included on the state referral
list. For example, repair subjects covered, access

requirements, hours of operation, etc.

3) The state (or its contractor) could set up a diagnostic
center, establish electronic (phone or other) communication
capabilities with in-field BAR90 analyzers or other
diagnostic equipment, and could provide the capability for
technicians to take cars to the center if the over-the-phone
approach is unsuccessful.

4) The state (or its contractor) could set up an electronic
library from which the technician could down-load information
or otherwise access.

5) The state (or its contractor) could establish a library
of failure information on vehicles in the local fleet that
was electronically accessible.


United States EPA 420-B-94-002
Environmental Protection April, 1994
Agency

Air

&EPA Supplemental Guidance for
1/M Programs:
Hot Line Services



-8-

5.2. Guidelines For Basic I/M Areas

The guidelines state agencies can consider for selection or
development of a hot line service listed in Section 5.1 will
generally also pertain to the basic I/M areas. Again, this list
may not encompass all the criteria necessary to consider in
choosing or developing a hot line. Individual states may have
specific needs not mentioned here. It is also possible that
states with long-running basic I/M programs already have a state
operated hot line in place that meets and/or exceeds these
guidelines.

5.3 Enhanced Capabilities
There are several other enhanced capabilities states may look
for when selecting or developing a hot line service. These

additional capabilities require more equipment and expertise on
the part of the hot line service. It should be noted that, in
order to be in compliance with Section 51.366 of the I/M rule,
states are required to collect the repair data.

1) The capability for modem to modem transfer of data from
specific types of diagnostic equipment (e.g., BAR 90, scan
tools, etc.) to the commercial hot line. This includes the
ability to provide direct computer access to symptom/emission
failure specific repair information.

2) If possible, the state may want to provide a mechanism for
the hot line service to: 1) accept from the program agency
I/M repair data for all the repair facilities, 2) analyze the
data, and 3) incorporate the data into its database. The hot
line service would then have a much larger database to draw
from when providing assistance to repair technicians.


necessity of conducting such preliminary checks should be
widely distributed to the repair industry.

4) The information should be provided in a timely manner
after receipt of a call. In general, the information should
be provided almost immediately (e.g., within an hour).

5) The hot line should be convenient and cost effective
(local, 800, or 900 number) with minimum operating hours that

cover the hours of normal repair shop activity in the I/M
area.

6) The service should have a complete collection of factory
service manuals, wiring diagrams, factory service bulletins;
PROM update information, and a demonstrated ability to
acquire and to incorporate the most recent information
available. This collection should generally be for all model
years covered by the I/M program.

Several efforts are underway which would provide independent
service facilities/hot lines with greater access to OEMs
service information. EPA's September 24, 1991 proposed rule
on onboard diagnostics requires manufacturers to make
emission-related repair and service information (including
recall information) available to all independent technicians
and services. Portions of this proposal are expected to be
finalized in 1994. Also, beginning in 1998, the proposed
rules would require this information to be provided in a
standardized electronic format currently being developed by
the Society of Automotive Engineers (SAE) under SAE J2008:
Recommended Organization of Vehicle Service Information. A
draft version of this document was released in July of 1993.

7) The hot line should have available current access to
various service information in electronic form. The service
should be upgradeable to SAE J2008 format when available.

8) The service should remain current with the local I/M fleet
as the model year mix changes with time.

9) The hot line service should create a database with the
repair knowledge (not IM240 data) gained through the
assistance provided by the service. This database will give
historical perspective on a particular vehicle and/or vehicle
type. The database should be accessible such that it could
be easily downloaded to local or county air pollution program
databases.

10) Bilingual services are appropriate in areas with large
non-English speaking populations.

11) The hot line should have facsimile (fax) capabilities.


-4-

1) the state can legally do so (i.e., this activity would
not be considered an inherent governmental function under
state law),

2) the state is comfortable with the contractor making
these decisions, and

3) the hot line staff that is chosen should be familiar
with state and federal specific I/M rules, regulations, and
policies in regard to all aspects of the I/M program, as
discussed in Section 2.0.

Assuming that the above criteria are met, and a state could
contract out a legal/policy hot line, EPA still recommends that
the state program agency itself establish a hot line to answer the
questions related to the legal requirements and interpretation of
state and federal laws and the state I/M program itself. This is
because there can be unique repair situations that do not
conveniently fit within frequently encountered legal and policy
guidelines. For this reason, many states currently offer hot line
services to address such unusual circumstances. In addition, one
of the purposes of this section of the I/M rule was to encourage
the states to work more closely with the repair industry. If the
state contracts out all of the interface with the repair industry,
including the legal assistance, this interface element with the
repair industry envisioned by the regulations will be lost.

Another reason supporting the recommendation that the state
operate the legal hot line is because of the volume and variety of
state and local laws that a given hot line service may handle.
Because there currently are a limited number of commercial hot
line services, it is reasonable to assume that any given hot line
service contracted by a state will in reality also be supporting
many different states. Unless a contractor assigns specific
personnel for each state, there could be difficulties experienced
by a contractor in becoming familiar with the many state and local
laws and regulations, as well as the federal laws and regulations.
This could be particularly problematic if the contractor personnel
are also providing detailed repair advice. If the hot line

- service contractor is capable of establishing a hot line service
with a dedicated legal interpreter for each particular state, then
the possibility of the contractor successfully handling the legal
questions will be much greater. If a state chooses to contract
out this area, the state will ultimately have to deal with
situations that could arise if the information provided by the hot
line service is in error.

In summary, the state must provide a mechanism to ensure that
a hot line service will exist that addresses the three areas
listed in Section 1. We would expect that most states would
physically operate a hot line that handles the basic functional
requirements (including legal issues), and employ one of the
referral options discussed previously. The states are free,
however, to propose other methods for administering the required


PREFACE

This document is intended as a resource for state and local
Inspection and Maintenance (I/M) planners and administrators. It
provides guidance regarding the hot line service requirement
outlined in 40 CFR 51.369(a) (2) of the I/M program regulation.

The provision for a hot line service is required in both
basic and enhanced I/M areas. It is required in basic I/M areas
by 1994 (January 1, 1994 for decentralized programs or July 1,
1994 for centralized programs.) It is required by January 1, 1995
in enhanced I/M programs. The program agency is required to
provide a hot line that will: 1) assist repair technicians with
specific repair problems, 2) answer technical questions that arise
in the repair process, and 3) answer questions related to the
legal requirements of state and federal law with regard to
emission control device tampering, engine switching, or similar
issues.

A draft of this hot line guidance, dated January 3, 1994, was
circulated to various state and industry organizations including
hot line services. Comments from EPA reviewers, state agencies,
industry organizations, and the hot line services were
incorporated as appropriate in this version. The regulatory
requirements are discussed, followed by minimum hot line
capabilities that meet the three requirements of the rule. This
is followed by various options for implementation by a state
program agency. Also presented are enhancements, some of which
states are considering, in addition to the minimum requirements to
further assist the repair technician. This is followed by
guidelines state agencies can consider for selection or
development of a hot line service. Also provided are some
possible hot line enhancements. A bibliography of available
commercial hot line services is also provided.

Although this guidance document has not been released in time
for states to prepare their final SIPs, it will be useful in
developing those programs required by regulation to support the
"mM" side of I/M; in this case, a hot line service in support of a
basic or enhanced I/M program. Subsequently, the information in
this document will be incorporated into a revision of the draft
March 24, 1993 OMS document titled, "Supplemental Guidance for I/M
Programs: Vehicle Repair, Technician Training and Certification,
and Repair Shop Tracking." Also included will be a revised
version of the "Performance Monitoring Guidance," a draft of which
was released by this office in December 1993. Comments on this
document are welcome and should be directed to:

Pamela J. Brodowicz (EPSD/TSB)

U.S. Environmental Protection Agency
National Vehicle and Fuels Emissions Lab
2565 Plymouth Road

Ann Arbor, MI 48105

Fax: (313) 668-4368


-11-

6) Technician ONLINE
8949 Bluewater Hwy
Saranac, MI 48881
Contact: Terry L. Callaghan 616-642-9271

The Technician ONLINE hot line is, at present, a computer
accessed hot line that has been in operation since August, 1992.
It is a 24 hour service that enables the technician to access
technical bulletins and service information compiled directly from
field experiences. Files have recently been added to access IM240
emission traces, automotive Original Equipment Manufacturers (OEM)
emission/safety product recalls, and OEM recall notices in the SAE
32008 format. A monthly newsletter, Driveability Technician,
giving technical information directly from the repair technicians
is also published. A sample copy can be obtained from the contact

_ listed above. After the initial set-up and training is completed
by Technician ONLINE (with a one time charge), the cost for their
hot line service is on a per month basis. There is an additional
charge if the Technician ONLINE graphical software is desired by
the user. Technician ONLINE will also establish, for independent
states, an Automotive Information Resource Center. This center
would be based in the specific state and would be set up by
Technician ONLINE to the state's specifications and needs.


TABLE OF CONTENTS

PREFACE
Page

1.0 REGULATORY REQUIREMENTS 1
2.0 MINIMUM HOT LINE CAPABILITIES THAT MEET REGULATORY 1

REQUIREMENTS
3.0 OPTIONS FOR HOT LINE MANAGEMENT 2
4.0 REPAIR SUPPORT ENHANCEMENTS 5
5.0 GUIDELINES FOR SELECTING COMMERCIAL HOT LINES
5.1 Guidelines for Enhanced I/M Areas 6
5.2 Guidelines for Basic I/M Areas 8
5.3 Enhanced Capabilities 8
APPENDIX 1: BIBLIOGRAPHY OF COMMERCIAL HOT LINE 9

SERVICES

APPENDIX 2: OTHER PRODUCT INFORMATION HOT LINE 12

SERVICES


SUPPLEMENTAL GUIDANCE FOR
I/M PROGRAMS :

HOT LINE SERVICES

April 1994

Emission Planning and Strategies Division
Office of Mobile Sources
Office of Air and Radiation
U.S. Environmental Protection Agency


=9-

APPENDIX 1
BIBLIOGRAPHY OF COMMERCIAL HOT LINE SERVICES

The following bibliography is provided for reference only.
EPA does not endorse any particular service. Currently, at least

six companies operate commercial hot line services. If EPA
becomes aware of any additional sources, they will be added to
future updates of the guidance document. It is expected that the

state and local agencies will determine which, if any, of these
hot lines can meet the needs of an I/M program in their state.
The information below was provided by the companies operating hot
line services, and EPA makes no claims on the accuracy of the data
and provides no specific endorsement of these services.

1) ASPIRE
U.S. Hwy 1
Morrisville, PA 19067
Contact: J. R. King 800-435-1050

The hot line operated by ASPIRE was established in 1980, with
subscribers from state and industry. The ASPIRE hot line logs
about 20,000 to 25,000 minutes of call time per month. Service
charges for actual time used and the price charged depends on the
user. Calls are primarily related to driveability, performance,
and emissions. There is a separate hot line to support trainers.

2) Technet/Automotive Data Systems (ADS)
15593 Graham
Huntington Beach, CA 92649
Information source: Leith Tecklenberg 714-891-7818
Contact no.: 714-892-8330, ask for Curt Moore or
714-891-7818

The company runs four hot lines, the Shell Auto Care Hot
line, a hot line for Hurst Motor Repair Manuals, a test program
with Snap-on Tools, and Teleguide for Computer Aided Service
Corporation. Technet/ADS services approximately 7000 cars per
month with 90 to 95% of the calls related to driveability/engine
control. Over the past 10 years they have averaged 1000 to 1500
calls per day. During their 13 years of operation, the company
has compiled a vehicle repair database, tracking repair patterns
with over 300,000 cars.

3) Mitchell
9889 Willow Creek Road
P.O. Box 26260
San Diego, CA 92126
Contact: Bob Gradijan 800-854-7030, extension 6411 or
Eddie Santangelo, extension 6504

Mitchell has a call volume of 100-200 calls/week, with 75% of
calls driveability related and the rest electrical. Most of the


-12-

APPENDIX 2
OTHER PRODUCT INFORMATION HOT LINE SERVICES

There are many other companies that sponsor technical hot
lines relating to companies' own parts. Many of these other hot
lines are designed to answer specific questions on products of
particular companies; thus, they vary in usefulness and scope. If
you are a customer of these products, the hot lines are usually
free, but may be limited to directions on how to install a
particular product. Since the hot lines specified in
§51.369(a) (2) are diagnostic in nature, these other hot lines will
not be discussed here.