1 STATE OF NEW JERSEY

2 DEPARTMENT OF ENVIRONMENTAL PROTECTION

3 BUREAU OF AIR QUALITY

4

5 IN THE MATTER OF: :

 :

6 PROPOSED STATE IMPLEMENTATION PLAN :

REVISION TO THE ENHANCED INSPECTION & :

7 MAINTENANCE PROGRAM FOR THE STATE OF :

NEW JERSEY EXTENSION OF THE NEW VEHICLE :

8 INSPECTION EXEMPTION FROM 4 TO 5 YEARS :

__________________________________________

9

10

11

12

13 TRANSCRIPT OF PROCEEDINGS

14 TUESDAY, AUGUST 17, 2010

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16

17

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20 ROSENBERG & ASSOCIATES, INC.

21 Certified Court Reporters & Videographers

22 425 Eagle Rock Ave., Suite 201 575 Madison Ave.

23 Roseland, New Jersey 07068 New York, New York 10022

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1 (Whereupon, the proceedings commence at 10:10 a.m.)

2 MS. DAVIS: Good morning and welcome. I

3 am Sharon Davis, Acting Chief of the Bureau of Air

4 Quality Planning of the Department of Environmental

5 Protection's Division Air Quality. I will be the

6 Hearing Officer this morning. Joining me on the

7 hearing panel today are Mobile Sources Manager,

8 John Gorgol, and the Chief of the Bureau of Motor

9 Vehicles Inspection and Maintenance, Dave West.

10 The purpose of today's hearing is to

11 accept comments on proposed revisions to the State

12 Implementation Plan (SIP) for changes to the

13 Enhanced Inspection and Maintenance Program. Notice

14 of this hearing and the availability of the

15 proposed SIP revision were: Provided through

16 mailings, posted on the Department of Enviromental

17 Protection's website, distributed to libraries,

18 published in six newspapers throughout the State on

19 or about July 12, 2010, and published in the New

20 Jersey Register on August 16, 2010.

21 The subject of this hearing is a revision

22 to New Jersey's Inspection and Maintenance (I/M)

23 program State Implementation Plan (SIP) reflecting

24 changes to the program. A recent New Jersey statute

25 change has specified an extension of the new
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1 vehicle inspection exemption from 4 to 5 years. The

2 Department has also demonstrated that New Jersey's

3 decentralized I/M network (the private inspection

4 facilities, or PIFs) is currently 96 percent as

5 effective as New Jersey's centralized I/M network

6 (the centralized inspection facilities or CIFs).

7 PIFs were previously assumed to be 80 percent as

8 effective as CIFs.

9 This SIP revision evaluates the emission

10 impacts of the enhanced I/M program changes by

11 comparing emission factors calculated using the

12 USEPA MOBILE6 model for the existing and new

13 programs. The emission factors were estimated for

14 2012, which is when the full impact of the

15 anticipated changes are expected to occur. The

16 emission factor, in this case, is grams of

17 pollutant released per mile of vehicle travel, and

18 is a representation value that relates the quantity

19 of a pollutant released to the atmosphere with an

20 activity associated with the release of that

21 pollutant. The model results indicate that there is

22 no difference between emission factors for the

23 existing and new enhanced I/M programs for ozone

24 precursors (volatile organic compounds or VOCs and

25 oxides of nitrogen or Nox). The new enhanced I/M
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1 program provides a small but significant increase

2 in the predicted carbon monoxide relative to the

3 existing program. Therefore, this SIP revision

4 demonstrates that the change from 4 to 5 years new

5 vehicle exemption does not increase emission

6 factors or actual emissions when compared to the

7 current I/M program. This SIP revision demonstrates

8 that the proposed changes to the I/M program do not

9 compromise the State's efforts to meet and/or

10 maintain National Ambient Air Quality Standards

11 (NAAQSs) for ozone or carbon monoxide.

12 In addition, this SIP revision also

13 revises the State's I/M performance standard

14 modeling to account for the proposed I/M program

15 changes. As part of its final rule for I/M

16 requirements, the USEPA established a"model"

17 program for areas that were required to implement

18 enhanced I/M programs. This model program is termed

19 by the United States Environmental Protection

20 Agency (USEPA) as the"I/M performance standard" and

21 is defined by a specific set of program elements.

22 The purpose of the performance standard is to

23 provide a gauge by which the USEPA can evaluate the

24 adequacy and effectiveness of each state's enhanced

25 I/M program. States are required to demonstrate
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1 that their enhanced I/M programs achieve applicable

2 area-wide emission levels for the pollutants of

3 interest that are equal to, or lower than, those

4 which would be realized by the implementation of

5 the model program. This SIP revision shows that the

6 State's new enhanced I/M program meets the

7 applicable USEPA performance standard.

8 The Department is accepting comments on

9 this proposed SIP revision. Information on how to

10 submit comments is provided in the handouts

11 available on the side table in this hearing room. A

12 limited number of copies of the proposal are also

13 available on the side table in this hearing room.

14 Electronic copies of the proposal are available

15 from the Department's website. We have also

16 provided a handout with further information

17 regarding notice of the proposal and information on

18 submitting written comments by August 20, 2010.

19 There is also a handout with information on how

20 hearings are conducted. Please review this

21 information if you intend to comment at today's

22 hearing.

23 Let me remind you that everyone present

24 is invited to sign in at registration desk. We ask

25 that you complete a registration card if you wish
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1 to comment. When your name is called, please come

2 forward. State your name, and spell it for the

3 benefit of the stenographer. Also state the name of

4 your organization, company, or interest that you

5 represent. If you have copies of your prepared

6 written statement, please leave one copy with the

7 stenographer. Also, at this time, please silence

8 all cell phones and pagers. Thank you.

9 That is the end of the opening

10 statement. If you wish to make any statement or

11 comment regarding this revision?

12 AUDIENCE SPEAKER: Well, actually, maybe I

13 think I will. I was expecting a little bit more

14 than this. I wanted to listen to other folks'

15 comments because I believe some of my comments may

16 be moot, but I will enter them into the record just

17 obviously this is a formality here today.

18 MS. DAVIS: Can you state your name?

19 MR. RISALVATO: Sal Risalvato,

20 R I S A L V A T O. I'm the Executive Director of

21 New Jersey Gasoline Seastar and Automotive

22 Association. I represent about 1500 small

23 businesses that are in the gasoline service station

24 business, and most of my members are private

25 inspection facilities.
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1 We were opposed to the change. We still

2 are opposed to the change. However, we are

3 committed to working with the MVC for a smooth

4 transition for further further changes that would

5 benefit both state budget and public and, of

6 course, the small businesses of this state.

7 Everything that you just stated may be

8 factually correct. I don't have a means of

9 checking up to verify everything. Somehow I

10 remember disputing the fact that somebody claimed

11 PIFs were 80 percent as effective as SIFs at one

12 point. Quite frankly, they are 100 percent as

13 effective. So I want to be on the record as making

14 that claim. The one factor that cannot be taken

15 into account, that your department cannot take into

16 account because it's an unknown.

17 However, the experience of my members and

18 the personal experience that I have having spent 23

19 years in a private inspection facility until the

20 last I/M program change was made back in 2000, that

21 experience must be taken into account. And your

22 numbers cannot take that into account. And that is

23 the fact that you are claiming. That the

24 technology of today's cars now makes it possible

25 for people to know when their car is emitting
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1 pollutants. And that the technology keeps our cars

2 running cleaner. And that, in fact, is true.

3 The factor you cannot account for is that

4 a motorist on occasions will ignore those warnings,

5 those lights, those indicators that will alert them

6 to those facts until they are mandated and required

7 to bring the car in for an inspection and get an

8 approval sticker. The car could come in for

9 service a hundred times with the indicator lights

10 on, and as long as the customer is not feeling a

11 malfunction, to them leave it alone. What's it

12 going to cost?

13 In many instances its unknown cost has a

14 relationship to emissions components and computer

15 components. Diagnosis is expensive. Repair is

16 expensive. I'll bring the car back to do that once

17 I start to feel a problem with driveability. That

18 is extremely common.

19 Now, I know you're not addressing the

20 safety issues. I've already exhausted all of

21 that. I'm not going to beat a dead horse.

22 However, the same thing applies to the safety

23 aspects. We are still documenting instances where

24 people bring their cars in are told of serious

25 safety issues, and they are ignored now because we
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1 don't need to put a sticker on the car. The same

2 thing applies with emissions. And our state agency

3 is banking on the fact that the technology is there

4 and it is but there's nothing in that technology

5 that makes it mandatory for those cars to be

6 repaired.

7 We have just extended by a year the

8 period by which somebody can ignore that and

9 pollute. When we from one year to two year

10 inspections if somebody's car starts polluting the

11 day after they got the sticker they can go two

12 years and pollute the air. For some reason on a

13 personal level I am extremely offended when I'm

14 driving by a car that I know is emitting pollutants

15 because it's in the cab of my car. Their exhaust is

16 in the cab of my car, and I am offended by that.

17 That's on a personal basis.

18 On a professional level, and as somebody

19 that lobbies the State of New Jersey, as somebody

20 that has a constituency that performs service for

21 the State of New Jersey as a private inspection

22 facility, I can tell you that our professional

23 experience is that you are wrong. You cannot take

24 that factor into account at all unless you are

25 monitoring every single car as it goes in for
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1 service and record the ignoring of the malfunction

2 until the necessary mandate is approaching or has

3 approached. That factor is an unknown that you

4 cannot take into consideration.

5 I'm going to suggest very strongly that

6 it is our professional experience that it happens

7 very often and that needs to be taken into account.

8 MR. WEST: If I could just -- first of

9 all, thank you for attending today. I know you

10 have a busy schedule. We appreciate your

11 comments.

12 As far as the check engine light being

13 on, what impact in your opinion these cars -- most

14 of these cars would be under warranty in that time

15 frame, 4 to 5 years. So that if that light comes

16 on what impact would -- having coverage under the

17 emissions warranty, wouldn't that be an incentive?

18 MR. RISALVATO: Well, warranties don't go

19 for that long.

20 MR. WEST: Really?

21 MR. RISALVATO: We went through a period

22 where warranties were touted to be -- I guess

23 Chrysler started a number of years ago 7 years/

24 7,000 miles. Then we've had some manufacturers,

25 most prominant of them is Mitsubishi, 100,000.
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1 However, the standard is three years/36,000 miles.

2 I would find less to argue with if this

3 were a three year inspection because of that.

4 However, at four years we have gone past the

5 expiration warranties. At five years we are

6 exacerbating that.

7 I will tell you that this is more common

8 and more prevalent today because of the economy. We

9 documented safety where people with photos,

10 documentation and people refusing -- not refusing.

11 I don't want to use the word refuse, but declining

12 a repair at this time. And I think many of them

13 have the intention of, okay, you know what maybe

14 next month I'll come in. Or month after that I'll

15 get that. I'll get my tires. Then I'll get my

16 brakes.

17 Just yesterday a family has a motor

18 vehicle inspection done last week. Leaves this past

19 weekend. And because it was no safety, gets their

20 emissions tested. Leaves this weekend on a trip to

21 Maryland. In Maryland their brakes are not working

22 and they pulled into a service facility that says

23 you can't drive the car. That car should have

24 failed the week before in a safety inspection. Now,

25 that's an indication, not of a customer that
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1 declined something, but we have instances

2 particularly with tires that people ignore getting

3 the tire now. Check engine lights in my 23 years in

4 the business it was such a commonplace thing that

5 that check engine light came on and you did not

6 notice a thing different about your car. It was

7 indicating some malfunction.

8 The technology of today's cars aren't --

9 we have eliminated so much pollution is that the

10 technology is so precise that every component needs

11 to work properly from the temperature, the air to

12 the pressure of the ambient pressure to the speed

13 of the car. All -- every little thing. And when

14 any one or more of those things are not working

15 properly the light comes on. That does not mean my

16 car is going to perform poorly. That does not mean

17 I'm not going to get it started. It does not mean

18 anything until my car does not perform properly.

19 And it's at that time that I will get it addressed.

20 There is way too much of that. And with the

21 difficult economy it has exacerbated. The problem

22 has without a doubt gotten worse in the last

23 several years.

24 Your intentions are good. I'm with you

25 on making all the changes that save the state money
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1 and that save the motorists a hassle. I'm all for

2 it. Your intentions are good. You're missing an

3 important factor. And it is a critical factor.

4 And you have no way of calculating it.

5 Professional experience dictates that you

6 should be aware of that fact.

7 MR. WEST: Now, you indicated that you

8 support the increase in the PIF effectiveness

9 factor which we've increased.

10 MR. RISALVATO: I will tell you without

11 outwardly and openly trashing anybody in the

12 central inspection facilities, because that

13 operation has markedly improved over years,

14 however, for anybody to think that they do a better

15 inspection and have better results than private

16 inspection facilities is nuts.

17 In this whole thing I did a little bit of

18 intelligence by sending people and documenting

19 what's going on in the inspection lanes for no

20 other reason other than to time the inspections, to

21 see how many personnel are working on different

22 aspects of the inspections. And literally I sent

23 two people at the very same time to two different

24 locations. And they got -- I wasn't even looking

25 for this. The report came back to me with two
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1 completely different inspections. And we tried to

2 reason that maybe one aspect of the safety

3 inspection was not performed because the car was

4 newer. Except that in the location they didn't

5 perform a particular inspection of the safety

6 inspection. That car was quite a bit older.

7 So, if anything, it should have been

8 reversed. So I have no idea what their rationale

9 is, or if simply the employees in the lanes are

10 just not doing their prescribed job. I don't have a

11 clue. I sent the people there to record other

12 things. And when this was reported back to me I

13 was floored. It wasn't something that I -- so I

14 wasn't addressing that.

15 However, that suggests to me that any

16 shortcomings in an inspection whether it's an

17 emissions inspection or safety inspection, any

18 shortcomings exist in the central inspection

19 facilities the same as the private inspection

20 facilities, personnel are going to be made to do

21 their jobs in all instance. I could make a case

22 where the personnel in my shops would do a better

23 job than personnel in Parons (phn) lanes. That

24 wouldn't be fair without documents. I have

25 nothing. Again, those people I think for the most
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1 part they're good hard working people. There are

2 instances where they have their shortcomings. They

3 do not perform as is the case in the private

4 facilities.

5 To say that -- to put a number to

6 rationalize -- to analyze and rationalize that

7 there's a 96 percent effectiveness, okay, well it's

8 less offensive than 80 percent. But, folks, we are

9 as effective as them. And if we're going to do

10 that analyzation and rationalization I'm willing to

11 bet that you could find the exact opposite is true.

12 MS. DAVIS: You already made statements

13 that the safety inspection, any changes is not part

14 of this revision.

15 MR. RISALVATO: No. I understand that

16 completely.

17 MS. DAVIS: I'm just clarifying that for

18 the record.

19 MR. RISALVATO: Absolutely. I understand

20 that completely. However, the rationale exists

21 that people won't address a safety issue because

22 they'll put it off for financial reasons. They'll

23 certainly do the same because there's a light on

24 that's not going to cause them any irreparable

25 harm. When the car is not performing properly
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1 they'll address it.

2 But it is common for that light to be

3 on. And if that light was on there isn't anybody

4 that would know there's a performance problem with

5 the car. And I think that if people would ignore

6 safety things because they're not compelled to do

7 them, they will certainly do that. And it is my

8 personal experience and it is an abundance of

9 experience fed to me by my members that that is the

10 case.

11 MR. WEST: Let me just ask a question. If

12 a typical customer comes in for maintenance and the

13 check engine light is on would a typical member of

14 your organization advise?

15 MR. RISALVATO: Yes.

16 MR. WEST: As to what that problem is?

17 MR. RISALVATO: Yes. You all drive cars.

18 You all get your oil changed. You can see oil

19 change signs out on the road as low as 14.95. You

20 could find coupons for free oil changes. Come for

21 a set of tires, free oil change. The object of the

22 oil change is, it's something that's a maintenance

23 that is required on your car. Not everybody honors

24 the interval it's supposed to be done at. But they

25 certainly know if I don't do this my engine -- I'm
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1 going is have thousands of dollars of repairs.

2 So the object is to have the customer

3 come in not to sell them things they don't need,

4 but to point out the things that are needed. And

5 if your car is on my lift in my shop and I say Mr.

6 West look at your brakes. You have 40,000 miles on

7 the car. Look at your brakes. Maybe you've got a

8 thousand or 2,000 miles left. If you've got time

9 if I give you a good estimate and I can do it now,

10 you are going to get it done. Or you may like me --

11 and the thing is that I'm polite. I presented

12 myself well. It's convenient for me. I'll come

13 back tomorrow. Or can I make an appointment for

14 next week? You are in my shop. That's the object

15 of an oil change. And very competitive price on

16 oil charge. I want you in there so that I can tell

17 you that that's what you need that's my job to tell

18 you what you need. If your check engine light is on

19 you can bet I'm going to tell you. When your check

20 engine light is on and I say Mr. West you're due

21 for inspection next month or in three months, can I

22 check that out for you? You know, I got to hook

23 everything up. Maybe it's 50 dollar diagnosis

24 charge because I have to do all that. I'll do it

25 for you for 20 dollars. Am I making money at the
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1 20? No. But if you need oxygen sensors, if you

2 need catalyst converter, well in order to repair

3 that and I give you a fair estimate there's a

4 profit in that for me to do that. That's my

5 motivation to do that. Not to sell you something

6 you don't need. There are people that will do

7 that.

8 The object is to have your car there and

9 tell you what's wrong with it. It is commonplace --

10 I think if you spent a day in a shop and you saw --

11 just observed the items that are declined, and now

12 you'll never have the opportunity of having the

13 little hammer that says you're going to be due for

14 inspection. That is the compelling reason to

15 repair what is there. If it can be ignored it can

16 be ignored.

17 Now, again, we don't have this, you know,

18 documented recently on a emissions kind of thing

19 because I was documenting safety kinds of things.

20 But -- and I have a customer that was willing to

21 sign an affidavit at the time. Brought a car to a

22 member and said listen, my check engine light is

23 not on. I know it's going to pass. I want to sell

24 the car in a couple months, which by the way in 23

25 years I must have had hundreds of cars that said
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1 listen I'm getting rid of the car, don't worry

2 about it. Two years later they were still bringing

3 me the same car.

4 This one's documented, and the customer

5 was willing to sign an affidavit sent to the

6 legislature. I know that everything's, you know,

7 okay with the car. You know, do the inspection and

8 let's sail it through. And my member checks the

9 car and the brakes are really not that good. So he

10 pulls the wheels and there's not a lot of brakes.

11 He calls the customer. The customer says well it

12 hasn't been stopping as well as it used to but I do

13 want to get rid of the car. My member says I can't

14 pass it for inspection. This was a couple months

15 ago. The guy says okay then do it. He knew ahead

16 of time that it just wasn't stopping well but he

17 thought he could get by inspection. He didn't want

18 to do it.

19 Now, that same customer I'm willing to

20 bet if he wasn't due for inspection and his check

21 engine light was -- especially he knew. He came in

22 and it wasn't on so it should pass, that same

23 customer is the exact customer that the light comes

24 on. The car's running fine. I don't need to

25 address this until I'm due for inspection.
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1 We just extended that by a year. That car

2 is polluting for another year. And I don't think

3 you can tell me how we can solve that problem

4 because I can't tell you how to solve that problem.

5 MR. WEST: Okay. Good. Anything else?

6 MS. DAVIS: We'll just take a short

7 break. If there's no further commentors when we

8 get back we'll formally close the hearing. We can

9 take about a 15, 20 minute break. We'll come back

10 at 11.

11 (Whereupon, a recess is taken

12 at 10:40 a.m.)

13 (Whereupon, the proceedings resume

14 at 11:00 a.m).

15 MS. DAVIS: It is now 11 o'clock and it

16 does not appear anybody has appeared who is

17 interested in making comments at this hearing.

18 I will officially close the hearing.

19 Thank you.

20 (Whereupon, the proceedings are

21 concluded at 11:01 a.m.)

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6 C E R T I F I C A T E

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8

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10 I, MADALENE PALAZZO, a Certified Court

11 Reporter and Notary Public of the State of New

12 Jersey, do hereby certify that the foregoing is a

13 true and accurate transcript of my stenographic

14 notes of the within proceedings, to the best of my

15 ability.

16

17

18

19

20

21

22 ______________________

23 MADALENE PALAZZO, C.C.R.

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A

ability 21:15

about 2:19

6:22 12:6

19:2 20:9

Absolutely

15:19

abundance 16:8

accept 2:11

accepting 5:8

account 4:14

7:15,16,21

7:22 8:3

9:24 10:7

accurate 21:13

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16:1 19:25

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after 9:11

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19:15

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air 1:3 2:3,5

4:10 9:12

12:11

alert 8:5

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15:12

ambient 4:10

12:12

analyzation

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and/or 4:9

another 20:2

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3:15

anybody 13:11

13:14 16:3

20:16

anything 12:18

14:7 20:5

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applicable 5:1

5:7

applies 8:22

9:2

appointment

17:13

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10:10

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10:3

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areas 4:17

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13:22

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3:20

ASSOCIATES

1:20

Association

6:22

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atmosphere

3:19

attending 10:9

AUDIENCE 6:12

August 1:14

2:20 5:18

Automotive

6:21

availability

2:14

available 5:11

5:13,14

Ave 1:22,22

aware 13:6

a"model 4:16

a.m 2:1 20:12

20:14,21

B

back 7:20 8:16

13:25 14:12

17:13 20:8,9

banking 9:3

basis 9:17

beat 8:21

because 6:15

7:16 8:25

9:15 11:3,8

11:19 13:12

14:3 15:21

15:23 16:6

17:24 18:19

20:4

before 11:24

being 10:12

believe 6:15

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7:5

best 21:14

bet 15:11

17:19 19:20

better 13:14

13:15 14:22

between 3:22

bit 6:13 13:17

14:6

both 7:5

brakes 11:16

11:21 17:6,7

19:9,10

break 20:7,9

bring 8:7,16

8:24

bringing 19:2

Brought 18:21

budget 7:5

Bureau 1:3 2:3

2:8

business 6:24

12:4

businesses

6:23 7:6

busy 10:10

C

cab 9:15,16

calculated

3:11

calculating

13:4

called 6:1

calls 19:11

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19:13 20:4

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14:3,6 15:25

16:5,23 17:5

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18:24 19:1,3

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20:1

carbon 4:2,11

card 5:25

cars 7:24 8:1

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10:13,14
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claim 7:14

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Court 1:21

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17:25

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16:24 17:10

don't 7:8 9:1

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13:2 15:1

17:9 19:9

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hammer 18:13

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16:13 17:18

17:20 18:22

19:21,23

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ROSENBERG & ASSOCIATES, INC. (800) 662-6878

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listen 6:14

18:22 19:1

literally

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little 6:13

12:13 13:17

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10:19

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M

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17:25

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17:21

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N

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newspapers

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operation

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organic 3:24

organization

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other 6:14

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outwardly

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oxides 3:25

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ozone 3:23

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21:23

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Plan 1:6 2:12

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Register 2:20

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relationship

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T
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ROSENBERG & ASSOCIATES, INC. (800) 662-6878

table 5:11,13

take 7:15,22

9:23 10:4

20:6,9

taken 7:14,21

10:7 20:11

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16:22 17:14

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today 2:7 6:17

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transcript

1:13 21:13

transition 7:4

trashing 13:11

travel 3:17

tried 14:1

trip 11:20

true 8:2 15:11

21:13

TUESDAY 1:14

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www.rosenbergandassociates.com

ROSENBERG & ASSOCIATES, INC. (800) 662-6878

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