## The State of New**Jersey**

**Department of Env ironmental Protection** 

**Proposed Rev isions to the Enhanced Inspection and**  **Maintenance (I/M) Program for the State of New Jersey**  **Proposed I/M Program Modeling and Rev ised**  **Performance Standard Modeling**

**S IP Rev**  **ision**

**December , 200**  **9**i **Preface** This document is a revision to the State of New Jersey’s Inspection and Maintenance (I/M) program State Implementation Plan (SIP). Specifically, this document provides the United States Envi ronmental Protection Agency (USEPA) with documentation on the emission impacts that will result from proposed changes to New Jersey’s enhanced I/M program including a comparison to the USEPA I/M performance standard. The proposed changes to New Jersey’s I /M program include: the establishment of a new exhaust emission test for gasoline fueled vehicles called the Two Speed Idle (TSI) test that will replace both the ASM5015 and 2500 RPM tests, the elimination of repair cost waivers, the increase in the inspection frequency (to annual) for certain classes of commercial vehicles such as limousines, taxis and jitneys, and the subjecting of light duty diesel vehicles to emissions testing. The primary reason for this SIP revision is to satisfy the USEPA's requirem ents for the State to implement the changes to the I/M program. The State of New Jersey entered into a contract, effective May 6, 2008, with Parsons Commercial Technology Group Inc. that includes the transition to the proposed I/M program.

**Ac kno** **wledgments** The New Jersey Department of Environmental Protection (NJDEP) acknowledges the efforts and assistance of the many agencies and individuals whose contributions were instrumental in the preparation of this SIP revision. In particular, the NJDEP wishes to acknowledge the many individuals within the New Jersey Department of Transportation (NJDOT), the New Jersey Motor Vehicle Commission (NJMVC), the USEPA Region II, and the staff within the NJDEP for their assistance and gu idance.ii **Table of Contents :**  PREFACE

................................ ................................ ................................ ........................ I ACKNOW LEDGMENTS

................................ ................................ ................................ ... I TABLE OF CONTENTS

................................ ................................ ................................ .. II LIST OF TABLES

................................ ................................ ................................ ........... III LIST OF APPENDICES

................................ ................................ ................................ . IV ACRONYMS AND ABBREVI ATIONS

................................ ................................ ............. V EXECUTIVE SUMMARY

................................ ................................ ................................ VI I. INTRODUCTION

................................ ................................ ................................ ...... 1 A. B ACKGROUND

................................ ................................ ................................ ......... 1 B. P URPOSE

................................ ................................ ................................ ............... 1 II. PROPOSED I/M PROGRAM MODELING AND REVISED PERFORMANCE STANDARD MODELING

................................ ................................ ................................ 2 A. B ACKGROUND

................................ ................................ ................................ ........ 2 B. M ODELING P ARAMETERS AND A SSUMPTIONS

................................ ............................ 3 C. M ODELING R ESULTS

................................ ................................ ............................. 13 III. CONCLUSION

................................ ................................ ................................ ..... ..25iii **LIST OF TA BLES**  **:** TABLE 1: P ERFORMANCE S TANDARD AND NJ E NHANCED I/M P ROGRAM D ESIGNS

................. 4 TABLE 2: VAR IOUS V EHICLE C ATEGORIES AND A PPLICABLE E MISSION T ESTS

......................... 9 TABLE 3: O THER M ODELING A SSUMPTIONS

................................ ................................ ....... 13 TABLE 4: M ODELING R ESULTS

................................ ................................ .......................... 25iv **List of A ppendices**  **:** Appendix I : His tory of New Jersey’s I/M SIP Appendix II : Documentation of the Emission Benefit Estimates for the Performance of I/M on Light Duty Diesel Vehicles Appendix I II : MOBILE Input and Output files for 2013 Modeling of the NJ Existing I/M Program, NJ Proposed I /M Program and USEPA I/M Performance Standard (available in electronic format) Appendix I V : Calculation Spreadsheet for 2013 Modeling of the NJ Existing I/M Program, NJ Proposed I/M Program and USEPA I/M Performance Standard Appendix V : Public Participat ionv

**Ac rony**  **ms and A bbreviations**  **:** ASM Acceleration Simulation Mode CAA Clean Air Act CIF Central Inspection Facility CO Carbon Monoxide EGR Exhaust Gas Recirculation Fed. Reg. Federal Register gpm Grams Per Mile HC Hydrocarbons HDGV Heavy Duty Gasoline Vehicle I/M Inspection and Maintenance LDGT Light Duty Gasoline Truck LDGV Light Duty Gasoline Vehicle LEV Low Emission Vehicle MY Model Year NAAQS National Ambient Air Quality Standards NHSDA National Highway System D esignation Act NJDEP New Jersey Department of Environmental Protection NJMVC New Jersey Motor Vehicle Commission NJDOT New Jersey Department of Transportation NO x Oxides of Nitrogen OBD On
- Board Diagnostics OTR Ozone Transport Region PCTG Parsons Commercia l Technology Group Inc. PCV Positive Crankcase Ventilation PIF Private Inspection Facility ppm Parts Per Million psi Pounds Per Square Inch ROP Rate of Progress RPM Revolutions Per Minute SIP State Implementation Plan TSI Two - Speed Idle USEPA United States Environmental Protection Agency VMT Vehicle Miles Traveled VOC Volatile Organic Compounds ZEV Zero Emission Vehiclevi **Executive Summary** This document is a revision to the State of New Jersey’s enhanced Inspection and Maintenan ce (I/M) State Implementation Plan (SIP) due to proposed changes to the I/M program. This SIP revision includes emission modeling that quantifies the impacts of the proposed program changes including a comparison to the USEPA performance standard. The pri mary reason for this SIP revision is to satisfy the USEPA's requirements for the State to implement the changes to the I/M program. It demonstrates that the proposed changes to the I/M program do not compromise the State’s efforts to meet and/or maintain N ational Ambient Air Quality Standards (NAAQSs) for ozone or carbon monoxide. It also demonstrates that New Jersey’s I/M program continues to meet the USEPA I/M performance standard after the proposed changes to the I/M program are implemented. The State of New Jersey entered into a contract, effective May 6, 2008, with Parsons Commercial Technology Group Inc. that includes the transition to the proposed enhanced I/M program. In addition, the Department of Environmental Protection (Department) is finaliz ing new rules and rule amendments , and the Motor Vehicle Commission is finalizing changes to both regulation and law, that implement these changes to the I/M program. New Jersey has proposed numerous changes to its enhanced I/M program to be fully implem ented by 2012. These changes include the following:

o Emission tests will no longer require the use of a dynamometer. Emission tests will include On
- Board Diagnostics (OBD), gas cap, visible smoke and two
- speed idle (TSI) tailpipe tests. The TSI test repla ces both the ASM5015 and 2500 RPM tests. o Repair cost waiver provisions have been removed. o Gas cap testing is excluded for vehicles of model year 2001 and newer. o Certain classes of commercial vehicles, limousines, taxis and jitneys will require annual (more frequent) inspection. o Central Inspection Facilities (CIFs) will not conduct any inspections for vehicles less than four years old, or for any cars at change of title. If a motorist wants a courtesy inspection, he/she will be directed to Private Inspection Facilities (PIFs). o Light duty diesel vehicles will now be subject to emission testing. This SIP revision evaluates the emission impacts of the proposed enhanced I/M program changes by comparing emission factors calculated using the USEPA MOBILE6 model for the existing and proposed programs. The emission factors were estimated for 2013 which follows the expected implementation of the proposed enhanced I/M program. The model results indicate that there is no significant difference between emission facto rs for the existing and proposed enhanced I/M programs for ozone precursors (VOCs and NO x ). The proposed enhanced I/M program provides a small reduction in the predicted carbon monoxide emission factor relative to the existing program.vii

This SIP revision also revises the State's enhanced I/M performance standard modeling to account for the proposed I/M program changes. This revision shows that the State's proposed enhanced I/M program meets the low enhanced performance standard.1

I. Introduction : A. Background In accordance with the requirements of the Clean Air Act (CAA), the State of New Jersey implemented an enhanced Inspection and Maintenance (I/M) program on December 13, 1999. The implementat ion of this program continues to be an integral part of New Jersey’s plan to attain and maintain compliance with the health
- based National Ambient Air Quality Standards (NAAQS) for ozone and for carbon monoxide. Reducing the emissions of carbon monoxide, as well as emissions of volatile organic compounds (VOCs) and oxides of nitrogen (NO x ) (precursors to ozone formation), will help the State in its efforts to improve its air quality and protect the health and welfare of its citizens. New Jersey’s enhanc ed I/M program design is a hybrid network system that consists of both centralized (test
- only) and decentralized (test
- and
- repair) facilities. A private contractor to the State operates the centralized portion of the inspection network. The decentralized network is comprised of over 1, 3 00 Private Inspection Facilities (PIFs) that are privately owned and operated, and licensed by the NJMVC to perform vehicle inspections on behalf of the State. This hybrid network design gives motorists a choice as to where to have their vehicles inspected. B. Purpose This document revises the State of New Jersey’s enhanced Inspection and Maintenance (I/M) State Implementation Plan (SIP) due to proposed changes to the I/M program. A complete history of New Jersey’s I/M SIP is provided in Appendix I. This SIP revision includes emission modeling that quantifies the impacts of the proposed program changes including a comparison to the USEPA performance standard. The primary reason for this SIP revision is to satisfy the USEPA's requirements for the State to implement the changes to the I/M program. It demonstrates that the proposed changes to the enhanced I/M program do not compromise the State’s efforts to meet and/or maintain National Ambient Air Qua lity Standards (NAAQSs) for ozone or carbon monoxide. It also demonstrates that New Jersey’s I/M program continues to meet the USEPA I/M performance standard after the proposed changes to the I/M program are implemented. The State of New Jersey entered i nto a contract, effective May 6, 2008, with Parsons Commercial Technology Group Inc. that includes the transition to the proposed enhanced I/M program. T he Department of Environmental Protection (Department) is finalizing new rules and rule amendments to N.J.A.C. 7:27
- 14, 7:27
- 15, 7:27B
-4 and 7:27B
- 5 that implement these changes to the I/M program. In addition, the Motor Vehicle Commission is finalizing changes to both regulation and law to implement these changes.2

II. Proposed I/M Program Modeling an d Revised Performance Standard Modeling A. Background As part of its final rule for Inspection and Maintenance (I/M) requirements, the USEPA established a “model” program for areas that were required to implement enhanced I/M programs. This model program is termed by the USEPA as the “I/M performance standard” and is defined by a specific set of program elements. 1 The purpose of the performance standard is to provide a gauge by which the USEPA can evaluate the adequacy and effectiveness of each state’s enhanced I/M program. As such, states are required to demonstrate that their enhanced I/M programs achieve applicable area
-wide emission levels for the poll utants of interest that are equal to, or lower than, those which would be realized by the implementation of the model program. The USEPA allows for a margin of error of +/
- 0.02 gpm in determining compliance with the performance standard. 2 Originally, th e USEPA only designed one enhanced performance standard, as specified at 40 C.F.R

. § 51.351, and required all enhanced I/M program areas to meet or exceed that standard. However, on September 18, 1995, the USEPA promulgated the “low” enhanced performance s tandard. 3 , 4 The low enhanced performance standard is a less stringent enhanced I/M performance standard established for those areas that have an approved SIP for Rate of Progress (ROP) for 1996, and do not have a disapproved plan for ROP for the period a fter 1996 or a disapproved plan for attainment of the air quality standards for ozone or carbon monoxide. 5

1 40 C.F.R . §51.351.
2 40 C.F.R . §51.351(g)(13).
3 60 Fed

. Reg . 48029 (September 18, 1995).
4 On July

19, 1996, the USEPA also establishing a n additional enhanced I/M performance standard for qualified areas in the Northeast Ozone Transport Region (OTR), often referred to as the OTR low enhanced performance standard. The emission reduction targets for the OTR low enhanced performance standard a re less than both the low enhanced performance standard and the basic performance standard. The USEPA established two criteria that areas have to meet in order to be eligible for the OTR low enhanced performance standard: 1) the standard applies only

in a ttainment areas, marginal ozone non
- attainment areas and certain moderate ozone non - attainment areas with populations under 200,000 in an OTR and 2) the standard program must be supplemented by other measures in order to achieve emission reductions equal to or greater than that which would have occurred had a regular low enhanced I/M program been implemented. New Jersey did not meet the criteria to qualify for use of the OTR low enhanced performance standard.
5 40 C.F.R . §51.351(g).3

New Jersey is currently demonstrating compliance with the Clean Air Act requirements for ROP and attainment and is therefore now only required to meet the “low” enhanced performance standard. The revised performance standard modeling included as part of this submittal is designed to show attainment of the low enhanced performance standard. In accordance with the USEPA’s final rule for I/M require ments, a state must design and implement its enhanced I/M program such that it meets or exceeds, within +/
- 0.02 grams per mile (gpm) 6 , a minimum performance standard. The performance standard is expressed as average gpm emission levels from area
-wide hig hway mobile sources as a result of the enhanced I/M program. 7 Areas must meet the performance standard for the pollutants that cause them to be subject to the enhanced I/M requirements. 8 New Jersey was required to implement its enhanced I/M program becau se of its non
attainment status for two criteria air pollutants; ozone (of which volatile organic compounds (VOCs) and oxides of nitrogen (NO x ) are precursors) and carbon monoxide. The USEPA’s final rule on I/M requirements also requires that the equiva lency of the emission levels achieved by the State’s enhanced I/M program design compared to those of the performance standard must be demonstrated using the most current version of USEPA’s mobile source emission model. 9 Currently, the latest version is MOBILE 6.2.03 (dated September 24, 2003), which was used for this analysis. B. Modeling Parameters and Assumptions Table 1 outlines the main program parameters of the low enhanced performance standard model program. In addition, this table presents New Jersey’s enhanced I/M program design for both the existing and proposed programs for evaluation year 2013. The emission factors were estimated for 2013 because it follows the expected implementation of the proposed enhanced I/M program. Although each state must model the performance standard using the parameters specified in Table 1, the performance standard emission factor results will vary for each state. This variation is the result of the use of s tate
- specific inputs such as registration distribution and vehicle miles traveled (VMT) mix. Other local parameters, such as fuel type, add to state variations in determining the emission factors for the USEPA’s performance standard program.

6 40 C.F.R . §51.351( g)(13) allows for a margin of error of +/
- 0.02 gpm for each pollutant result.
7 40 C.F.R . §51.351(a), 57 Fed

. Reg . 52988 (November 5, 1992).
8 Ibid.
9 40 C.F.R

.

§51.351(d), 57 Fed

. Reg . 52988, (November 5, 1992).4 **Table 1 : Per** **formance Standard and NJ Enhanced I/M Program Designs**

**Program Element Low Enhanced**  **Performance Standard New Jersey’s Existing**  **Enhanced I/M Program**  **New Jersey’s Proposed Enhanced**  **I/M Program** Network Ty pe 100% centralized hy brid

– 70% centralized/30% decentralized hy brid
- 70% centralized/30% decentralized Credit Assumed for Decentralized Program NA 80% 80%
Program Start Date 1983 1 1974 1974 Test Frequency annual biennial 2 biennial 2
Em ission Standards Those specified at 40 C.F. R . Part 85, Subpart W Initial ASM5015 exhaust em ission standards Two - Speed Idle Standards of 1.2% for carbon monoxide and 220ppm for HC Model Year (MY) Coverage 1968 and later MY all vehicles not specifically exempt all vehicles not specifically

exe mp t Vehicle Ty pe Coverage All light
- duty gasoline
fueled vehicles and trucks (up to 8,500 lbs. GVW R) All gasoline
- fueled vehicles and trucks (both light and heavy duty vehicles) All gasoline
- fueled

vehicles and trucks (both light and heavy duty vehicl es) Exhaust Emission Test Idle
- 1968
- 2050 MY OBD
- 1996 and later MY beginning 6/1/03 ASM5015

– 1981
- 1995 MY am enable to dy no. testing 2500 RPM test

– certain exempt vehicles and those 1981 and newer MY not am enable to dy no. testing Idle
- pre - 1981 and HDGVs OBD
- 1996 and later MY beginning 6/1/03 Two - Speed Idle

– 1981
- 1995 MY Idle
- pre - 1981 and HDGVs5 **Program Element Low Enhanced**  **Performance Standard New Jersey’s Existing**  **Enhanced I/M Program**  **New Jersey’s Proposed Enhanced**  **I/M Program**

Visual Inspections Positive Crankcase Ventilation (PCV) valve
-- 1968

– 1971 MY inclusive Exhaust Gas Recirculation (EGR) valve

– 1972 and ne wer Visual inspection of the cataly tic converter, presence of a gas cap, and fuel inlet restrictor
-- 1975 and newer (beginning calendar 1985) Visual inspection of the cataly tic converter, presence of a gas cap, and fuel inlet restrictor
-- 1975 and ne wer (beginning calendar 1985)

Evaporative System Function Checks N/A Gas Cap Testing

– 197 1 and later vehicles 3 (beginning calendar year 1998) Gas Cap Testing

– 197 1

– 2000 MY inclusive 3 (beginning calendar year 1998) Pre
- 1981 MY Stringency 20% 30% 30%
Wa iver Rate 3% 3% 4 0% Compliance Rate 96% 98% 98% Evaluation Date 5 January 1, 20 02 January 1, 2013 January 1, 2013 On
- Road Testing 0.5% of the subject vehicle population or 20,000 vehicles (whichever is less) 0.5% of the subject vehicle population or 20,000 vehicles (whichever is less) 0.5% of the subject vehicle population or 20,000 vehicles (whichever is less) 1 For programs with existing I/M programs, like New Jersey’s basic I/M program. 2 Except for new vehicles of model year 2000 or later purchased after January 1, 2003. These vehicles are exempt from their first emission inspection for two inspection cycles (i.e., four years) and thereafter must be inspected biennially (or once e very other year). 3 Only those pre
- 1981 ve hicles that were equipped with sealed gas caps will be subject to the gas cap check. The State estimates that model year vehicles prior to 1970 were not equipped with a sealed gas cap. 4 The State assumed a zero percent waiver rate for pre
- 1981 vehicles as these vehicles are not eligible for a waiver based on the NJMVC inspection rules. 5 For all scenarios, summer season and temperatures were used for VOC/NO x evaluations, while winter season and temperatures were used for carbon monoxide evaluations.
The remainder of this section discusses in detail the various New Jersey program parameters used to model the existing and proposed enhanced I/M programs. The State has also included, in Appendices II and III of this document, the MOBILE6 input and output fi les and the spreadsheet that compiles the results.6

1. Network Type: New Jersey’s enhanced I/M program is comprised of a hybrid network of both centralized test
- only facilities and decentralized test
- and
- repair facilities. The State has assumed a 70 /30 CIF/PIF split for its enhanced I/M network (that is, 70 percent of the vehicle owners are expected to pass inspection at a centralized inspection facility and the remaining 30 percent are expected to pass inspection at a decentralized private inspectio n facility). New Jersey claimed, in accordance with the flexibility afforded states by the NHSDA, that the decentralized portion of its enhanced I/M program would be 80 percent as effective as the centralized portion of its program. 10 As part of its Augus t 31, 2001 enhanced I/M SIP revision submittal, New Jersey demonstrated that its private inspection network is achieving this 80 percent assessment. In fact, this analysis showed that the State was conservative in its initial 80 percent estimation. In add ition, the effectiveness of the private inspection network may have increased further after the introduction of OBD testing. Therefore, New Jersey has assumed 80 percent credit for the decentralized portion of its program. To address the State's inspect ion facility type split and the 80 percent credit for the decentralized portion of the program, the NJDEP calculated an overall I/M effectiveness rate. The I/M effectiveness rate was 94 percent (that is, 0.70 * 100 percent + 0.30 * 80 percent). This rate was used as an input to the MOBILE6 model to account for New Jersey’s specific network type. 2. Start Date: The I/M program start date is defined as the date on which vehicles were first inspected using an evaporative or tailpipe exhaust emission inspe ction in the State. As such, for New Jersey this date is 1974 (all modeling dates are assumed to be January 1 of the given year), the date when the State implemented its basic I/M program. Although this is New Jersey's start date as outlined in the low e nhanced performance standard requirements, the NJDEP considers other programmatic start dates in determining the final emission factors associated with New Jersey's program. The State implemented its enhanced I/M program on December 13, 1999, which, for m odeling purposes, is assumed to be January 1, 2000. As such, the January 1, 2000 date is assumed in modeling the enhanced portion of the State's program, while January 1, 1974 continues to be assumed for the basic (idle) portion of the State's program. F inally, the State assumed a January 1, 2004 start date for OBD implementation.

10 Revision to the State Implementation Plan (SIP) for the Control of Mobile Source Ozone Air Pollution
-- Enhanced Inspection and Maintenance (I/M) Program, March 27, 1996, Section 3, Network Ty pe and P rogram Evaluation, pages 14
- 15.7

3. Test Frequency: The current test frequency of New Jersey’s enhanced I/M program is biennial (that is, vehicle inspections are required once every two years). In additio n, starting on January 1, 2003, New Jersey implemented a 4
- year new vehicle exemption. The 4
- year new vehicle exemption was modeling as a grace period with the age of vehicles first subject to mandatory I/M program requirements set to 4.
4. Model Year a nd Vehicle Type Coverage: Vehicles currently receive different types of emission tests, depending on the type and model year of the vehicle. Pre
- 1981 vehicles are given an idle exhaust emission test. Currently, model year 1981
- 1995 vehicles which are: 1 ) classified as light
- duty gasoline
fueled motor vehicles (LDGVs), or light
- duty gasoline
-fueled trucks 1 and 2 (LDGT1s and LDGT2s) 11 , 2) amenable to dynamometer
- based testing, and 2) not specifically exempted 12 from enhanced testing, are subjected to the AS M5015 exhaust emission test. Those model year 1981
- 1995 vehicles that are not amenable to dynamometer testing currently receive a 2500 RPM test. All 1996 and newer vehicles receive an OBD inspection unless they are exempt from that test in which case the y receive the applicable exhaust emission test. New Jersey has proposed numerous changes to its enhanced I/M program to be fully implemented by 2012. These changes include the replacement of the ASM5015 and 2500 RPM tailpipe tests with the two
- speed idl e (TSI) tailpipe test. Also repair cost waiver provisions have been removed and gas cap testing is excluded for vehicles of model year 2001 and newer. Another proposed program change requires certain classes of commercial vehicles, limousines, taxis and ji tneys to receive annual (more frequent) inspection. In addition, although it is not modeled by MOBILE6, it is proposed that light duty diesel vehicles will be subject to emission testing. As part of the documentation of the rule changes, t he Department e stimated emission reduction benefits of 4 9 tons per year of VOC + NO X for the extension of the I/M program to light duty diesel vehicles. Details regarding these estimated emission reduction benefits are provided in Appendix II.

11 To determine whether a vehicles is classified as a LDGV, LDGT1, LDGT2, or HDGV, please refer to the definition section of either of the NJDEP’s rules for the implementation of the enhanced I/M program at N.J.A.C. 7:27
- 15. 1 and N.J.A.C. 7:27B
-4.1.
12 Specifically

exempted vehicles are those vehicles which have been exempted from enhanced emission testing, or alternatively , from emission testing all together, through NJMVC regulations and statute. These vehicles include coll ector motor vehicles, low mileage vehicles, and historic motor vehicles.8

Table 2 (in Section B.5) shows each vehicle category and the applicable OBD, exhaust and/or evaporative emission tests to which that vehicle category is subjected for both the existing and proposed enhanced I/M programs. 5. Exhaust Emission Test Type: The majority of gasoline
-fueled motor vehicles inspected as part of the enhanced I/M program currently receive either an OBD inspection or an ASM5015 exhaust emission test. Table 2 outlines the different vehicle categories and the applicable tests for those categories.9

**Table 2 : Various Vehicle Categories and A** **pplicable Emission Tests Vehicle Category**  **Exhaust Emission Test Evaporative Emission Test(s)**  **NJ Existing Enhanced**  **Program NJ Proposed** 

**Enhanced Program**  **NJ Existing**

**Enhanced Program**  **NJ Proposed**

**Enhanced Program**  pre - 1981 vehicles idle idle gas cap test only 1 gas cap test only 1 1981
- 1995 ASM5015 2 TSI gas cap test only gas cap test only 1981
- 1995 vehicles not amenable to dy namometer
- based testing 2500 RPM TSI gas cap test only gas cap test only
1981
- 1995 low mileage vehicles 3 2500 RPM TSI gas cap test only gas cap test only 1996
- 2000 low mileage vehicles 3 OBD OBD OBD and gas cap test4 OBD and gas cap

test4 2001 and newer low mileage vehicles 3 OBD OBD OBD and gas cap test4 OBD 1996
- 2000 vehicles OBD OBD OBD and gas cap test4 OBD and gas cap

test4 2001 and later vehicles OBD OBD OBD and gas cap test4 OBD collector motor vehicles 5 exempt exempt exempt exempt historic motor vehicles exempt exempt exempt exempt 1981 and newer vehicles registered as school buses 6 OBD OBD OBD and gas cap test4 OBD and gas cap

test4 1 Only those pre
- 1981 vehicles that were equipped with sealed gas caps will be subject to the gas cap check. The State estimates that model ye ar vehicles prior to 1970 were not equipped with a sealed gas cap. 2 Unless the vehicle is not amenable to dy nam om eter
- based testing or is specifically exempt. 3 The “low mileage vehicle” category , as required by the enhanced I/M legislation, is defined an d discussed at P.L. 1995, Chapter 112, Section39:8
- 2b.(1), approved June 2, 1995. The “low mileage vehicle” category

is being removed in the proposed enhanced I/M program because there will no longer be a difference in the test requirements between low mi leage and non
- low m ileage vehicles for each model ye ar
.10 4 The OBD test includes checks for monitored failures of both the exhaust and evaporative systems, thereby substituting for traditional tailpipe and evaporative pressure and purge tests. In additio n to these checks, the State will also perform a traditional gas cap pressurization inspection on these vehicles. 5 The “collector motor vehicle” category , as required by the enhanced I/M legislation, is defined and discussed at P.L. 1995, Chapter 112, Se ction39:8
- 1a., approved June 2, 1995. 6 All gasoline
- fueled vehicles registered as school buses in the State are inspected by the NJMVC's School Bus Inspection Unit. If applicable, t hese vehicles receive an OBD test. School buses not am enable to an OBD te st will receive the 2500 RPM tailpipe test instead of the ASM5015 tailpipe test under the proposed program. As part of its last performance standard modeling submittal, the State estimated the number of vehicles that would be exempt from the ASM5015 e xhaust emission test because they were not amenable to dynamometer testing (i.e., either vehicles which employ full
- time, four
-wheel drive or which are installed with non
- switchable traction control). This estimation (10%) was then used to determine the lo ss in credit attributed to these vehicles receiving a 2500 RPM test in lieu of the ASM5015 exhaust emission test. In 2013 the number of vehicles that would be exempt from the ASM5015 exhaust emission test will be extremely small because the vast majority of the vehicles will be receiving OBD testing. Therefore for the 2013 model runs that represent the existing program it is no longer necessary to perform a separate set of runs to model the loss in credit for these vehicles. T his will no longer be an iss ue for the model runs that represent the proposed enhanced I/M program because the ASM5015 test is being eliminated. The NJMVC’s regulations and State statute specifically exempt several types of vehicles that would otherwise be subjected to enhanced I /M testing from the enhanced tests or from emission testing as a whole. These vehicles include: 1) low mileage vehicles, and 2) collector motor vehicles. To determine whether or not a vehicle qualifies for either of these categories, see the NJMVC’s defi nitions at N.J.A.C. 13:20
- 43.1. Note that the low mileage vehicle category is being removed in the proposed program because there will no longer be a difference in the test requirements between low mileage and non
- low mileage vehicles for each model year. In addition, the NJMVC’s regulations maintain a vehicle category that exempts applicable vehicles from basic I/M emission testing. These vehicles are classified by the NJMVC as historic motor vehicles. To determine whether or not a vehicle qualifies as a historic motor vehicle, see the NJMVC’s definitions at N.J.A.C. 13:20
-43.1 and N.J.S.A. 39:3
- 27.3. The NJDEP did not include these vehicles as part of this revised performance standard modeling for two reasons: (1) the number of vehicles in these cate gories was so small that their emissions were not significant enough to impact the modeling, and (2) the vehicles in the category, by definition, fell well outside the 25 model year analysis window examined by the MOBILE model.11

6. Emission Control Devic e Inspections: A visual inspection to determine the presence of a catalytic converter is performed on all 1975 and newer motor vehicles. This was assumed in the State’s revised performance standard modeling. In addition, the State assumed that all vehic les subject to the gas cap inspection also receive a visual gas cap inspection for the presence of a cap and to examine the cap for any cracks, outside damage, etc. Finally, the State included in its revised performance standard modeling fuel inlet restri ctor testing for all applicable model years. The purpose of the fuel inlet restrictor test is to determine whether or not a leaded gasoline pump nozzle could fit into the vehicle’s gasoline inlet, allowing for the possibility of leaded gasoline usage. Us e of leaded gasoline interferes with effectiveness of the vehicle’s catalytic converter. Although the State began fuel inlet restrictor testing as part of its annual inspections in June 1990, New Jersey stopped performing inlet restrictor tests in 1994 b ecause it was no longer possible for New Jersey motorists to obtain leaded gasoline. However, according to a USEPA guidance memorandum on highway source modeling 13 , states that have, in the past, performed fuel inlet tests for at least one full cycle (and have required catalyst replacement upon failure) may claim the SIP credit associated with this testing without future testing. Since New Jersey meets these requirements, the State took emission credit for the fuel inlet restrictor test in this revised per formance standard modeling. 7. Evaporative System Function Checks: In addition to outlining the exhaust emission tests applicable to each vehicle category, Table 2 also shows which vehicle categories are currently subject to the State’s evaporative em ission tests. Although OBD monitors a vehicle's evaporative system, and as such has a "self
- contained" evaporative functional check, the USEPA has recommended that states needing significant hydrocarbon reductions to meet their attainment goals should supp lement OBD
- I/M testing with a separate gas cap inspection. 14 This recommendation is based on the fact that when the USEPA compared failure rates for the evaporative portion of the OBD
- I/M test to the failure rate for the stand
- alone gas cap test, they foun d that the separate gas cap test was able to identify a substantial number of leaking gas caps that were not identified by the OBD monitors due to the different failure thresholds. For the proposed I/M program the gas cap applicability is amended to exclu de vehicles of model year 2001 and newer. This is because by model year 2001 the vehicle manufacturers had refined their OBD systems to more reliably detect evaporative system malfunctions and tighter evaporative emission tests were imposed by the USEPA.

13 Memorandum dated September 16, 1994 from Phil Lorang, then Director of the Emission Planning and Strategies Division, USEPA to All Regional Air Directors entitled “Discontinuation of Tail Pipe Lead and Fuel Inlet Tests.” 14 "Performing Onboard Diagnostic System Checks as Part of a Vehicle Inspection and Maintenance Program", EPA420
- R
- 01015, June 2001.12

The pressurized gas cap inspection is designed to insure that the gas cap seals properly and has no leaks. In the existing I/M program all gasoline
-fueled motor vehicle manufactured with a sealed gas cap are subject to this pressured gas cap inspecti on, which the NJDEP determined is all 1971 and later vehicles.
8. Stringency: For modeling purposes, a 30 percent emission test failure rate was assumed for pre
1981 vehicles.
9. Wa iver Rate: In accordance with 40 C.F. R . 51.360(d)(1), each state’ s SIP must include “a maximum waiver rate expressed as a percentage of initially failed vehicles.” The purpose of this waiver rate is to estimate emission reduction benefits in a modeling analysis. In the USEPA enhanced low I/M performance standard, a 3 percent waiver rate was used. Using this 3 percent assumption as guidance for its own enhanced I/M program, New Jersey assumed a 3 percent waiver rate for 1981 and newer vehicles in its enhanced I/M SIP. It should be noted here that under New Jersey’s ex isting enhanced I/M program, any vehicle that applies for a waiver must show compliance with the idle test, in addition to meeting the minimum cost expenditure. Since all pre
- 1981 vehicles receive the idle test as their official inspection test under the enhanced I/M program, these vehicles are not eligible for a waiver. Thus, the pre
- 1981 waiver rate is assumed to be zero. In addition, the State extended the waiver option to those vehicles failing an OBD inspection, in addition to those failing an ASM50 15 exhaust emission test, so long as they meet the minimum cost expenditure and pass an idle exhaust emission test. The proposed enhanced I/M program has removed the option for vehicles to comply with emission standards by receiving a waiver. W aiver ra tes are zero for all vehicles in the proposed I/M program. 10. Compliance Rate: For modeling purposes, a 98 percent compliance rate was assumed for the overall enhanced I/M program.13

11. Evaluation Date: An evaluation date of January 1, 2002 is used for the p erformance standard runs
. 15 An evaluation date of January 1, 2013 is used for the program evaluation runs because the proposed I/M program should be fully implemented by this date.

15 40 C.F.R. § 51.351(g)(13). In addition to the parameters and assumptions discussed previou sly in Subsection B, the NJDEP had to make other assumptions in order to complete its performance standard and program evaluation modeling. The following table shows what those assumptions were and what values where used to complete the modeling:
**Table 3**  **: Other Modeling A ssumptions** 
**Modeling Parameters Value Used for**  **Av erage Summer**  **Runs (VOC and NO**  **x )**  **Value Used for Av** **erage Winter Runs**  **(Carbon Monoxide)**  Maximum Temperature (F) 82.9 41.2 Minimum Temperature (F) 66.3 26.7 Absolute Humidity

(grains/pound) 85.59 20.00 Speed MOBILE6 Defaults MOBILE6 Defaults Mechanic Training and Certification ye s - 100% ye s - 100% NJ Low Emission Vehicle Program w/o ZEV Mandate ye s ye s Gasoline RVP (psi) 6.8 15 Oxygenated Gasoline 10% Eth anol 10% Ethanol

C. Modeling Results : The following table shows the emission factors (in grams per mile) obtained for the USEPA performance standard program, New Jersey’s existing enhanced I/M program, and New Jersey’s proposed enhanced I/M program for VOC, NO x and carbon monoxide, respectively. Modeling files are provided in Appendix III and the modeling results are summarized in Appendix IV.14

**Table 4 : Modeling Results**  Program Type VOC (gpm) NO x (g pm) Carbon Monoxide (gpm) USEPA Low Enhanced Performance Standard (2002) 0.9 03
- 0.9 43 * 2

. 376
- 2

. 416 * 21

. 834
- 21

. 874 * New Jersey Existing Enhanced I/M Program (2013) 0.349 0.687 10.04 5 New Jersey Proposed Enhanced I/M Program (2013) 0.348 0.68 8 10.025
* The performance standard values are expressed as a range to account for the +/
- 0.02 gpm margin for error allowed for by the USEPA. Therefore, the standards are met so long as they fall below the upper lim it of the range.
IV. Conclusion As shown in Table 4, the model results indicate that there is no significant difference between emission factors for New Jersey’s existing and proposed enhanced I/M programs for ozone precursors (VOCs and NO x ). A slight increase in the emission factor for NO x is offset by a slight decrease in the emission factor for VOCs although the magnitude of the increases and decreases are well below the USEPA margin of error of +/
- 0.02 gpm. In addition, the emission factors calculated for New Jersey’s proposed enhanced I/M program do not reflect the emission reductions associated with the addition of light duty diesel vehicles to New Jersey’s I/M program. As part of the documentation of the rule changes, the Department estimated emission reduction benefits of 4 9 tons per year of VOC + NO X for the extension of the I/M program to light duty diesel vehicles. The proposed enhanced I/M program provides a small reduction in the predicted carbon monoxide emission factor relative to the exi sting enhanced I/M program. This demonstrates that the proposed changes to the enhanced I/M program do not compromise the State’s efforts to meet and/or maintain National Ambient Air Quality Standards (NAAQSs) for ozone or carbon monoxide. Also, as shown in Table 4, the State's proposed enhanced I/M program meets the USEPA low enhanced performance standard.