SUBJECT: Technical Support Document for the Revision to the Missouri State Implementation Plan 

(SIP) for the St. Louis Inspection and Maintenance (liM) 

FROM: 

TO: THRU: 

Steven Brown 

Air Planning and Development Branch 

EPA-RO?-OAR-2014-0399 Joshua Tapp,"" 

Branch Chiev-WMD/ APDB 

Michael Jay, 

Section Chief, A WMD/ APDB/ AtPS 

Missouri State Implementation Plan 1/M Revisions 

TABLE OF CONTENTS 

I. INTRODUCTION 

II. DESCRIPTION OF REVISIONS 

A. INSPECTION/MAINTENANCE (liM) PROGRAM CONVERSION 

B. GENERAL REVISIONS/SPECIALLY CONSTRUCTED VEHICLE DEFINITION 

C. PLUG-IN HYBRID ELECTRIC VEHICLE (PHEV) EXEMPTION 

D. MISSOURI STATE HIGHWAY PATROL RULES REMOVAL 

III. EVALUATION OF MDNR MOBILE SOURCE SIP REVISIONS 

A. INSPECTION/MAINTENANCE (liM) PROGRAM CONVERSION 

A.l Background 

A.2 Gateway Vehicle Inspection Program (GVIP) Evaluation 

A.3 Federal JIM Regulations 40 C.F.R. Part 51 Evaluation 

B GENERAL REVISIONS/SPECIALLY CONSTRUCTED VEHICLE DEFINITION 

C. PLUG-IN HYBRID ELECTRIC VEHICLE (PHEV) EXEMPTION 

C. I Shortfall Analysis 

C.2 Shortfall Analysis Results 

D. MISSOURI STATE HIGHWAY PATROL RULES REMOVAL 

Printed on Recycled Paper 
Table A-2 Bar Graphs, 11M Performance Standard 

Table A-3 11M Performance Standard (one year of operation demonstration) 

Table C-1 2022 GVIP Mobile Emissions (NOx, VOC, CO) 

Table C-2 2022 GVIP-PHEV Mobile Emissions (NOx, VOC, CO) 

Table C-3 2022 GVIP-PHEV Mobile Emissions (NOx, VOC, CO) (GVIP to PHEV Differences) 

Table C-4 2022 GVIP Mobile Emissions (NOx, VOC, CO) (%I 03 Season Day) (GVIP to PHEV 

Differences) 

Table D-1 Missouri Department of Public Safety Division 50-State Highway Patrol Chapter 2-

Motor Vehicle Inspection 

Table 1-1 2008 and 2015 CO, NOx, and VOC Emissions 

Figure 1-2 Tons per Ozone Season Day 

Table 1-3 Total Emissions St. Louis, MO Nonattainment Area (Tons Per Ozone Season Day) 

Table 2-1a 2008-2010 St. Louis 8-hour Ozone Design Values 

Table 2-1b 2011-2013 St. Louis 8-hour Ozone Design Values 

Figure 2-2 8-hour Ozone Design Value Trends- MO 

Table 3-1 Level of Control in Tons/Ozone Season Day Emissions (GCAP vs GVIP) 

Table 3-2 StLouis Area Ozone Season Day Emissions (tons) GCAP vs GVIP 

Figure 3-2 St Louis Area Ozone Season Day Emissions GCAP vs GVIP 

Table 3-3a 2002- 2008 On-Road Mobile Decreases for CO, NOx, and VOC Emissions for the 

Missouri Portion of the St. Louis Ozone Nonattainment Area (Tons per Ozone Season 

Day) 

Table 3-3b 2008-2015 On-Road Mobile Decreases for CO, NOx, and VOC Emissions for the 

Missouri Portion of the St. Louis Ozone Nonattainment Area (Tons per Ozone Season 

Day) 

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II. DESCRIPTION OF REVISIONS 

EPA received a total of six requests from MDNR. A description of the first three requests are listed 

below in section A and the other three are each listed in sections B, C, and D. 

A. INSPECTION/MAINTENANCE (liM) PROGRAM CONVERSION 

EPA received a SIP revision from MDNR on August 16, 2007, requesting approval to 

rescind the centralized vehicle inspection maintenance program rule, 10 CSR 5.380 and 

replace with the Gateway Vehicle Inspection Program (GVIP) de-centralized vehicle 

inspection program rule, 10 CSR 10-5.381. MDNR also requested in the same letter that 

Missouri Rule, 10 CSR 10-5.375 "Motor Vehicles Emissions Inspection Waiver" be 

rescinded. EPA does not plan on taking any action on 1 0 CSR 1 0-5.3 7 5 as it is not a part 

of the SIP. 

On December 14, 2007, MDNR submitted the new GVIP plan - Inspection and 

Maintenance Program for the St. Louis 8-Hour Ozone Nonattainment Area, 2007 

Revision including a performance modeling demonstration of the new GVIP program 

requesting that EPA approve the plan and revise the SIP. 

On January 2, 2009, MDNR submitted the network type and program evaluation required 

by 40 CFR 51.3 53. This demonstration is required within one year after the VM program 

begins. MDNR's January 2, 2009, letter requested final approval of the GVIP program 

based on the submission of the required information. 

B. GENERAL REVISIONS/SPECIALLY CONSTRUCTED VEHICLE DEFINITION 

10 CSR 10-5.381- MDNR submitted this SIP revision to EPA on June 17,2009. This 

amendment defines and exempts specially constructed vehicles "kit-cars" to make the rule 

consistent with current practices. There are also other general revisions such as the addition of 

definitions and changes that add clarity to the Inspection Maintenance (VM) portion of the SIP. 

C. PLUG-IN HYBRID ELECTRIC VEHICLE (PHEV) EXEMPTION 

10 CSR 10-5.381- MDNR submitted this SIP revision to EPA on December 10,2012 requesting 

approval to exempt Plug-in Hybrid Electrical Vehicles (PHEV) from the VM program. 

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mobile source emissions. 

A. INSPECTION/MAINTENANCE (I/M) PROGRAM CONVERSION 

MDNR submitted this SIP revision to EPA on August 16, 2007, requesting approval to replace the 

existing transient IIM240 centralized program 10 CSR 10-5.380 with the GVIP basic OBD only decentralized vehicle inspection program 10 CSR 10-5.3 81. This older hybrid-enhanced centralized VM 

program was developed not only to meet the requirements for the area for a basic I/M program but also 

to achieve creditable emissions reductions to meet the obligations for a 15% reduction in VOC 

emissions as established by section 182(b)(i) of the CAA. This program is hereafter referred to at the 

Gateway Clean Air Program or (GCAP). In the same submittal, MDNR requested to rescind 10 CSR 10-

5.375. EPA is not taking action on 10 CSR 10-5.375 as it is not a part of the SIP. 

A.l Background 

In April 2000, Missouri implemented the GCAP centralized vehicle emissions testing station network to 

meet one of the CAA requirements for the St. Louis nonattainment area for the one-hour ozone standard. 

The affected areas were the City ofSt Louis, and StLouis, St. Charles and Jefferson counties. As part of 

testing for GCAP, 1971 to 1980 model year vehicles were tested with a single speed idle test; 1981 and 

newer model year vehicles were tested with the transient IM240 tailpipe and a gas cap pressure test; and 

1996 and newer model year vehicles received an On-Board Diagnostics (OBD) test. 

At the end of the ozone season in 2002, the design values for monitors in St. Louis area were below the 

1979 one-hour ozone standard. The department submitted a request to EPA to redesignate the area to 

attainment. On May 12, 2003, EPA approved the request, and St. Louis became redesignated to 

attainment under the 1979 one-hour ozone standard ( 68 FR 25418). As part of the maintenance plan, the 

department committed to retain a vehicle emissions VM program. 

In 2004, after the promulgation of the 1997 eight-hour ozone standard, EPA designated the St. Louis 

area as a "moderate" ozone nonattainment area under the newly established eight-hour ozone standard. 

The nonattainment area included St. Louis City and Franklin, Jefferson, St. Charles and St. Louis 

counties. This nonattainment designation required the department to revise their SIP to include an 

attainment plan and additional related requirements to bring the area to attainment of the eight-hour 

ozone standard by June 2010. The "moderate" ozone nonattainment status required the state to include 

within its SIP a vehicle emissions 11M program that met or exceeded EPA's Basic VM Performance 

Standard (40 CFR 51.350 (a)(4)). Since the GCAP vehicle emissions network was still operational, and 

MDNR demonstrated it exceeded EPA's Basic VM Performance Standard Test, the required control 

strategy was determined by EPA to be approvable (69 FR 51953). 

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vehicles and light duty trucks, 1997 and newer diesel powered light duty vehicles, up to eight thousand 

five hundred pounds (8,500 lbs.) Gross Vehicle Weight Rating (GVWR) are subject to the program. The 

emissions testing facilities test using OBD. This advanced computer inspection system determines 

whether 1996 and newer vehicles pass or fail the emissions inspection. Vehicles failing the OBD test 

must be repaired to pass the vehicle emissions test and to receive license registration and/or renewal. All 

subject vehicles must also pass a safety inspection. Safety inspections extend beyond safety and include 

a visual inspection of all emission component parts to insure they are in place. 

A.2 Gateway Vehicle Inspection Program (GVJP) Evaluation 

As indicated earlier, this SIP proposal will completely replace Missouri rule 10 CSR 10-5.380 with 10 

CSR 10-5.381, and a replacement of the St. Louis liM program (GCAP to GVIP). This program 

replacement has several design changes. The Gateway Vehicle Inspection Program network type of 

decentralized refers to a large network of low volume test-and-repair inspection stations as compared to 

the GCAP network type centralized program having a small network of high volume test-only inspection 

stations. By having a decentralized program it creates numerous testing locations around the five county 

area and prevents long lines lasting hours in order to receive emissions tests. This was previously a 

major recurring problem in St. Louis. It is also more cost effective and convenient to contract the work 

to auto repair businesses who qualify to become an inspection station. The main concern with a 

decentralized program is that it becomes a larger network and could be more difficult to manage. 

However, MDNR has secured the services of a sole-source contractor that has provided the 

infrastructure for a real-time, fraud-resistant decentralized emissions inspection station network. MDNR 

has also created penalties associated with fraudulent activity built into the rule and has created a penalty 

schedule to accompany it (10 CSR 10-5.381(3)). 

Both GVIP and GCAP included OBD testing for 1996 and newer vehicles. GCAP also included 1971 to 

1980 model year vehicles tested with a single speed idle test and 1981 and newer model year vehicles 

tested with the transient IM240 tailpipe and a gas cap pressure test. However, the GCAP VM SIP 

exempts up to 40% of the total vehicle fleet with 20% exemption of clean screen vehicles, 8% waiver 

rate and 12% for brand new vehicles. The GVIP I/M program, however, exempts 1995 and older vehicles from taking the I/M test, newer vehicles, has a 2.5% waiver rate and is considered a basic OBD 

VMprogram. 

As the fleet in St. Louis continues to become newer, the number of vehicles older than 1996 in the St. 

Louis area are decreasing. In fact, in just two years there is a decrease of nearly 20,000 vehicles 1995 

and older (Figure A-1 ). This trend gives the indication that the older fleet is shrinking and therefore 

makes sense to focus the OBD testing of 1.4 million vehicles that make up the fleet majority. In 

addition, the advancements of technology in vehicles has now established advanced computers with a 

second generation of OBD (OBD-II) that detects emission components that malfunction such as 02 

sensors, EGR valves and gas caps. Newer OBD detection is now a more up to date testing system. 

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145,000 

2009 

The Federal VM rule Sections 51.350-51.373 establish minimum performance standards for basic 1/M 

programs. The performance standards address the following: network type and program evaluation; 

adequate tools and resources; test frequency and convenience; vehicle coverage; test procedures and 

standards; test equipment; quality control; waivers and compliance via diagnostic inspection; motorist 

compliance enforcement; motorist compliance enforcement program oversight, quality assurance; enforcement against contractors, stations, and inspectors; data collection; data analysis and reporting; inspector training and licensing or certification, public information and consumer protection; improving 

repair effectiveness; compliance with recall notices; and on-road testing. 

MDNR submitted a demonstration of the emission impacts of the 1/M conversion to a basic VM testing 

program included in the "Inspection Maintenance Program for the St. Louis 8-Hour Nonattainment Plan 

2007 Revision" submittal, December 14,2007. This plan utilized EPA's Mobile-6 modeling to project 

the emission reduction benefits from implementing a basic decentralized VM program in the St. Louis 

nonattainment area by comparing results from the GVIP program to the basic VM performance standard 

set by EPA. The results from this analysis performed by MDNR indicate that the GVIP program 

projections met and/or exceeded the basic performance standard (Table A-2 I Bar Graphs). EPA's Basic 

Performance Standard is highlighted in red text. 

Table A-2, Bar Graphs 

11M Performance Standard 

osite Emissions Factor Com arison at 27.6 MPH) 

NOx ( m) 

No 11M Controls 0.906 9.363 0.864 

EPA Basic Performance Standard 0.868 8.696 0.819 

Gateway Vehicle Inspection Program 

( rojected) 

0.91 

0.9 

0.89 0.88 

0.87 

0.86 0.85 0.84 

0.83 0.82 0.81 ¥-----.----------,--------(' 

No 1/M controls EPA Pe rfomance Gateway 

Standard Vehicle Insp. 

Pra&ram 

• voc 

6 

0.842 

088 086 

084 

8.241 0.776 

082 

08 

0.78 

0.76 0.74 0.72 -+:=------.-------,-------t" 

No 1/M controls EPA Perfomance Gateway 

Standard Vehlclelnsp. 

Program 
y 

Standard Insp. Prosram 

As required by 40 CFR 51.3 53 Network Type and Pro gram Evaluation, a state using a decentralized 

test-and-repair vehicle emissions inspection network must submit a demonstration within one year after the VM program begins. The purpose of the demonstration is to document that the actual VM program is 

as effective as the predicted VM performance standard modeling test. MDNR submitted this 

demonstration to EPA on January 2, 2009, and the results are below in Table A-3. 

Table A-3 

Type of Program VOC (gpm) CO (gpm) NOx (gpm) 

No liM Controls 0.906 9.363 0.864 

EPA Basic Performance Standard 0.868 8.696 0.819 

Gateway Vehicle Inspection Program 0.839 8.190 0.772 (actual, after I year of operation demonstration) 

The modeling results of GVIP after one year of operations show that emissions from VOC, CO, and 

NOx are lower than EPA Basic Performance Standard (Table A-3) and lower than the projected GVIP 

VM program included in the "Inspection Maintenance Program for the St. Louis 8-Hour Nonattainment 

Plan 2007 Revision" submittal (Table A-2, Bar Graphs). 1 

A.3 Federal JIM Regulations 40 C.F.R. Part 51 Evaluation 

This section ofthe document summarizes the requirements of the Federal VM regulations and address 

whether the elements of the state's submittal comply with the Federal rule. The specific requirements for 

VM plan submissions are in 40 C.P.R. Part 51, SubpartS, and a list of required SIP elements are in 40 

C.P.R. 51.372. EPA's decisions for approval is based on the state's ability to meet the liM requirements 

for a basic program. 

Network Type and Program Evaluation - 40 C.P.R. Section 51.353 - Part C of the SIP 

Basic VM programs can be centralized, decentralized or a hybrid at the state's discretion. Missouri has 

the legal authority for and a contract in place to implement and operate a decentralized, OBD-only 

network that meets the Federal requirements. 

A state program is required to demonstrate that it achieves the same emission reductions as the model 

program described in the Federal rule (40 C.P.R. 51.353) and submit a report every two years starting 

two years after the initial start date. This report will be populated with the information collected through 

the OBD test equipment purchased by the licensed vehicle emissions stations that is stored and 

1 For more information on how to model the performance standard of an 11M program, see latest EPA guidance titled: 

Performance Standard Modeling for New and Existing Vehicle Inspection and Maintenance (liM) Programs Using the 

MOVES Mobile Source Emissions Model (25 pp, 246K, EPA-420-B-14-006, January 2014). 

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include public education and assistance and funding for other necessary functions. 

The SIP includes a detailed budget plan that describes the source of funds for personnel, program 

administration, program enforcement, and purchase of equipment. The SIP also details the number of 

personnel dedicated to audits, data analysis, program administration, enforcement, public education and 

assistance, and other necessary functions. The description of funding and resources is adequate for 

purposes of Section 51.354. Section 51.372 requires the state to demonstrate that adequate funding is 

available to meet the requirements described in this section. The SIP shows that the program will be 

funded by a $24.00 per vehicle inspection fee. A set portion of$2.50 of the inspection fee will be 

remitted to a State Treasure's account and, subject to appropriation, be expended for administration and 

enforcement achieved through the 18.02 employees ofMDNR who will be involved in the program. The 

SIP meets the Federal requirements for evidence of adequate tools and resources under Sections 51.3 72 

and 52.354. 

Test Frequency and Convenience- 40 C.F.R. Section 51. 355- PartE of the SIP 

The liM performance standard assumes an annual test frequency; however, other schedules may be 

approved if the performance standard is achieved. The Missouri legislation provides the legal authority 

to implement the biennial program. Missouri's I/M regulation provides for a biennial test frequency and 

provides for enforcement of the biennial test frequency. The Missouri submittal meets the performance 

standard. 

Although not required for a basic program, enhanced liM programs shall be designed in such a way as to 

provide convenient service to motorist required to get their vehicles tested. The state has ensured 

motorist convenience is assured by state law that requires the department to recruit vehicle repair 

stations if more than twenty percent (20%) of motorists are more than five (5) miles from a vehicle 

repair station. Therefore, this portion of the SIP meets the test frequency and convenience requirements 

for an enhanced I/M program which exceed the requirements for a basic program. 

Vehicle Coverage- 40 C.F.R. Section 51.356- Part F of the SIP 

The performance standards for enhanced liM programs assume coverage of all 1968 and later model 

year light-duty vehicles (LDV) and light-duty trucks (LDT) up to 8500 pounds gross vehicle weight 

rating (GVWR) and includes vehicles operating on all fuel types. The standard for basic liM programs 

does not include LDTs. Other levels of coverage may be approved if the necessary emission reductions 

are achieved. Missouri's submittal includes: legal authority necessary to implement and enforce 

program with respect to vehicles required to be covered in a basic and an enhanced program; a detailed 

description of the number and types of vehicles to be covered by the program; a plan for how those 

vehicles are identified, including vehicles that are routinely operated in the area but may not be 

registered in the area; and a description of any special exemptions. 

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electrically-powered vehicles; motorcycles and motor tricycles; new and unused motor vehicles, of 

model years of the current calendar year and of any calendar year within two years of such calendar 

year, which have an odometer reading ofless than 6,000 miles at the time of original sale by a motor 

vehicle manufacturer or licensed motor vehicle dealer to the first user; motor vehicles registered in the 

applicable area covered by the VM requirements which are domiciled and operated exclusively in an 

area not subject to the VM requirements, but only if the owner presents to MDNR an affidavit that the 

vehicle will be operated exclusively in an area not subject to the liM requirements for the next 24 

months; new motor vehicles not previously titled and registered, for the four-year period following their 

model year of manufacture, if the odometer readings are under forty thousand miles at the first required 

biennial safety inspection; motor vehicles driven fewer than twelve thousand miles between biennial 

safety inspections. 

Fleet testing will be conducted at official test-only stations. Some fleets owners may opt to have I/M 

testing equipment installed at their facility that will be operated and maintained by the contractor at the 

fleet owner's expense (and connected to the on-line data system). Fleet programs are required to undergo 

the same testing requirements and quality assurance procedures as other subject vehicles. Federal fleet 

vehicles are also required to comply with the same inspection program requirements as other fleet 

vehicles in the basic VM area. This rule applies to all employee-owned and leased vehicles and all 

vehicles owned by civilian and military personnel on federal installations as well as agency-owned or 

operated vehicles, except tactical military vehicles. 

This level of coverage is approvable as it meets the requirements for a basic program. In addition, 

Missouri has legal authority to implement fleet-testing requirements and to implement requirements for 

special exemptions. Therefore, this portion of the SIP is approvable as it meets the requirements for a 

basic and an enhanced VM program. 

Test Procedures and Standards- 40 C.F.R. Section 51.357 -Part G of the SIP 

The Federal rule requires Missouri to have written test procedures and pass/fail standards to be 

established and followed for each model year and vehicle type included in the program. Test procedures 

and standards are detailed in 40 C.F .R. Section 51.357 and in EPA document entitled "High-Tech VM 

Test Procedures, Emission Standards, Quality Control Requirements, and Equipment Specifications," 

EPA-400-F-92-001, dated July 20, 1998. 

The state's VM regulation, Missouri rule 10 C.S.R. 10-5.381, includes a description of the test 

procedures for an on-board diagnostic (OBD) check, and for a visual emission control device inspection. 

These test procedures conform to EPA-established standards and are approvable. 

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is working properly, that inspection records are accurately created, recorded, and stored, and the 

abnormalities in testing results are detected. In accordance with these requirements, the state's VM rule 

and contract address the quality control provisions by providing: quality control standards and criteria 

for all test equipment hardware; procedures and specifications for the maintenance of all test equipment 

hardware; procedures manual for station operations responsibilities; software requirements for tracking 

equipment maintenance, emissions test data, and vehicle repair records; 

This portion of the submittal complies with the quality control requirements set forth in the Federal VM 

regulation and is approvable. 

Waivers and Compliance via Diagnostic Inspection- 40 C.F.R. Section 51.360- Part J of the SIP 

The Federal VM regulation allows for the issuance of a waiver, which is a form of compliance with the 

program requirements that permits a motorist to comply without meeting the applicable test standards. 

For enhanced VM programs, an expenditure of at least $450 in repairs, adjusted annually to reflect the 

change in the Consumer Price Index (CPI) as compared with the CPI for 1989, is required to qualify for 

a waiver. For the basic program the minimum expenditure is $75 for pre-1981 vehicles and $200 for 

1981 and newer vehicles. 

As required, RSMo 643.335 provides legislative authority to issue waivers, set and adjust cost limits, 

and administer and enforce the waiver system. The Missouri legislation sets a minimum dollar amount 

of $450 to be spent for repairs made by a repair shop, $400 if the repairs are made by the owner of the 

vehicle or $200 if the individual meets the statutory requirement of section 643.335.8., RSMo. Waivers 

will be issued by MDNR staff for vehicles that do not pass the emission inspection, provided the 

minimum dollar amount was spent for repairs. The repair record must show that the repair expenditures 

were not covered by either a recall or manufacturer warranty and that parts costs and labor cost of 

recognized technicians total the minimum applicable amount for the model year of the vehicle. 

A waiver rate of eight percent (8%) of failed vehicles is assumed in the MOBILE modeling that 

demonstrates that the liM program meets the applicable performance standard. The State of Missouri 

maintains a waiver rate that in practice is equal to or lower than eight percent (8%). If the waiver rate 

reported in the annual report to EPA is higher than 8%, the State will attempt corrective action to lower 

the waiver rate. If the waiver rate cannot be lowered to levels committed to in the SIP, or if the State 

chooses not to implement measures to do so, then the State will revise the liM emission reduction 

projections in the SIP and will implement other program changes needed to ensure the performance 

standard is met. 

Missouri regulations include provisions that address waiver criteria and procedures, including cost 

limits, tampering and warranty-related repairs, quality control, and administration. The SIP sets a 

maximum waiver rate and describes corrective action that will be taken if the actual waiver rate exceeds 

the commitment in the SIP. The SIP meets this portion of the regulation and is acceptable. 

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associated safety inspection compliance records to enable vehicle registration and compliance 

enforcement. Paper vehicle inspection reports may not be used for registration purposes, unless the 

contractor's real time vehicle inspection database is not providing inspection information to the 

Department of Revenue on a real time basis. The MDNR shall expressly authorize, either in writing or 

by voice authorization, the use of the paper vehicle inspection reports by the Department ofRevenue 

and/or its contract offices. Thus, the enforcement method used is registration denial. State and local 

police agencies will enforce any vehicle registration failures and all remaining liM program enforcement 

actions are the responsibility ofMDNR. 

The Missouri SIP commits to a compliance rate of 96 percent which was used in the performance 

standard modeling demonstration and is approvable. The submittal includes detailed information 

concerning the registration denial enforcement process, the identification of agencies responsible for 

performing each applicable activity, and a plan for testing fleet vehicles. Therefore, this portion of the 

SIP is approvable. 

Motorist Compliance Enforcement Program Oversight- 40 C.F.R. Section 51.362- Part L of the SIP 

The Federal 11M regulation requires that the enforcement program shall be audited regularly and shall 

follow effective program management practices, including adjustments to improve operation when 

necessary. The SIP shall include quality control and quality assurance procedures to be used to ensure 

the effective overall performance of the enforcement system. An information management system shall 

be established which will characterize, evaluate, and enforce the program. 

In accord with Federal regulation, Missouri's SIP includes regulations and descriptions of procedural 

manuals and supporting documents describing how the enforcement program oversight will be qualitycontrolled and quality-assured and includes the establishment of an information management system. 

RSMo Section 643.355 provides authority to enforce against persons who misrepresent themselves as 

official emission inspection station; anyone who knowingly manufactures, conveys, or possesses any 

counterfeit documents; and anyone who knowingly operates a motor vehicle without displaying a valid emission inspection sticker. The enforcement program will be audited through data analysis of the 

registration and inspection data bases, follow-up surveys of exempt vehicles and registration changes 

triggering an exemption, confirmation of registration renewals, cross checking data bases to identify 

vehicles obtaining registration with meeting the liM requirements. As indicated in the SIP, requirements 

of this section depend on the participation of the MDOR and its fee offices, the MSHP, and the liM 

contractor with MDNR. MDNR has a Memorandum ofUnderstanding with MDOR and with the MSHP, 

and a contract specifying the duties of the contractor to meet the requirements of this section. 

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An ongoing quality assurance program must be implemented to discoyer, correct, and prevent fraud, 

waste, and abuse in the program. The program shall include coyert and overt performance audits of the 

inspectors, audits of station and inspector records, equipment audits, and formal training of all state 1/M 

enforcement officials and auditors. 

The Missouri submittal includes a quality assurance program that includes quality control and quality 

assurance procedures describing methods for reviewing inspector records, performing equipment audits, 

and providing formal training to all state enforcement officials. Performance audits of inspectors and 

stations will consist of both covert and overt audits. Each licensed station will have at least two overt 

audits and one covert audit per year. Program auditors will take 40 hours of training per year and will be 

audited once per year as well. The contractor will provide reports weekly, monthly, quarterly, and 

annually to MDNR. The SIP meets the requirements of this section. 

Enforcement Against Contractors, Stations and Inspectors- 40 C.F.R. Section 51.364- Part N of the SIP 

EPA regulation requires that enforcement against stations, contractors and inspectors shall include swift, 

sure, effective, and consistent penalties for violation of program requirements. 

Implementation and operation of Missouri's decentralized program against a licensed emissions station 

is done through provisions of the individual emissions station license issued by the MSHP. Most 

violations for improper testing, improper operation of the program, and other key criteria result in 

station license suspension or revocation. The contract includes appropriate penalty provisions and 

includes record keeping and enforcement procedures. The SIP meets the requirements of this section. 

Data Collection - 40 C.F .R. Section 51.365 -Part 0 of the SIP 

Accurate data collection is essential to the management, evaluation, and enforcement of an liM program. 

The Federal liM regulation requires data to be gathered on each individual test conducted and on the 

results of the quality control checks of test equipment, as required under 40 C.F.R. Section 51.359. 

The SIP provides a commitment to gather, maintain, summarize, and report all of the data requirements 

and has listed all the data which will be collected. The contract details the functions the contractor will 

fulfill and specifies the data to be collected and the record storage format. This test data and quality 

control will be maintained and summarized by MDNR. The SIP meets the requirements of this section. 

Data Analysis and Reporting- 40 C.F.R. Section 51.366- Part P of the SIP 

Data analysis and reporting are required to allow for monitoring and evaluating the program by the state 

and EPA. The Federal liM regulation requires annual reports to be submitted which provide information 

and statistics and summarize activities performed for each of the following programs: testing, quality 

assurance, quality control, and enforcement. These reports are to be submitted by July and will provide 

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Inspector Training and Licensing or Certification - 40 C.F .R. Section 51.367 - Part Q of the SIP 

The Federal 11M regulation requires all inspectors to be formally trained and licensed or certified to 

perform inspections. 

The SIP states that inspectors are to receive formal training, lists the curricula, sets the minimum 

examination requirements, and states that inspectors must be reexamined every two years. The curricula 

and certification examinations will be approved by the state. The contractor will conduct the training and 

certification examination. The SIP meets the requirements of this section. 

Public Information and Consumer Protection- 40 C.F.R. Section 51.368- Part R of the SIP 

The Federal 11M regulation requires the SIP to include public information and consumer protection 

programs. The state has committed to conduct public information and consumer protection programs. 

The contract specifies and lists the activities the contractor will perform to provide information to the 

public. The state has committed to following up and responding to complaints made by the motorist and 

the public, even re-inspect the vehicle if need be. This portion of the SIP submittal meets the 

requirements of this section. 

Improving Repair Effectiveness- 40 C.F.R. Section 51.369- PartS of the SIP 

Effective repair work is the key to achieving program goals. The federal regulation requires states to 

take steps to ensure that the capability exists in the repair industry to repair vehicles. The SIP must 

include a description of the technical assistance program; in enhanced areas, a description of the 

procedures and criteria to be used in meeting the performance monitoring requirements; and a 

description of the technician training resources available in the community. Training is required for 

"state recognized qualified repair technicians" and MDNR has set the training criteria for technicians 

that will be provided by non-profit and for-profit schools as well as independent trainers. The state will 

review and approve courses and set criteria for course curricula and number of class hours. The 

contractor will provide a telephone information service line to help the repair industry identify and 

repair emission problems. This portion of the SIP submittal meets the requirements of this section. 

Compliance with Recall Notices - 40 C.F .R. Section 51.3 70- Part T of the SIP 

The CAA and Federal regulation require states subject to the enhanced liM requirements to establish 

methods to ensure that vehicles that have been recalled for emission-related repairs to receive the repair 

prior to completing the emission test and/or renewing the vehicle registration. 

The Missouri 11M regulation requires owners to comply with emission-related recalls before completing 

the emission test or renewing the vehicle registration. The contractor will maintain a data base of 

vehicles that have been recalled and can identify them at the test station. Those that have obtained the 

needed repairs can complete the inspection. The submittal includes a commitment to submit an annual 

report to EPA that includes the information as required. Therefore, this portion of the SIP meets the 

requirements for an enhanced 11M program which exceed the requirements for a basic program. 

13 
The Missouri 11M Program does not contain on-road testing, but it is not relevant to EPA's proposed 

action with respect to the basic 11M requirement. 

State Implementation Plan Submissions - 40 C.F .R. Section 51.3 72 -Part U of the SIP 

States such as Missouri are required to submit a SIP, including a schedule, analysis, description, legal 

authority, and adequate evidence of funding and resources for program implementation as discussed in 

EPA's liM rule. The schedule requirements lists a number of elements that the submittal shall include 

such as the statutory authority and regulations, specification and procedures, licensing or certification of 

station inspectors, date mandatory testing will begin, and date full-stringency cut points will take effect. 

The submittal has addressed the requirements of this section. 

The following is a schedule implementing the basic liM program in the St. Louis ozone nonattainment 

area: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

Passage oflegal authority 

Signature of Governor 

Adoption of liM rule by MACC 

Issuance ofRFP 

Bid conference 

RFP bids due 

Contract awarded Complete inspector/mechanic training 

Start of Decentralized liM program testing 

2007 annual reports 2007-2008 biennial reports 

May4, 2006 

June 30, 2006 

April 26, 2007 

December 14, 2006 

January 4, 2007 

February 15, 2007 

May29, 2007 

September 29, 2007 

October 1, 2007 

June 15, 2008 June 15, 2009 

For the liM rule, the MDNR provided a 30-day public comment hearing before the MACC on March 29, 

2007. The revision was adopted by the MACC on April 26, 2007, and became effective on October 1, 

2007. MDNR followed all applicable administrative procedures in proposing and adopting the rule 

reVISIOnS. 

In addition, MDNR complied with the requirements of 40 C.F.R. Part 51, Appendix V, for SIP 

submittals. Missouri has met all the applicable requirements for a SIP revision. 

14 
rule language submitted on August 7, 2007 and narrative language submitted on December 7, 2007, is in 

accordance with the requirements of the Clean Air Act and the Federal rule. 

B. GENERAL REVISIONS I SPECIALLY CONSTRUCTED VEHICLE 

MDNR submitted this SIP revision to EPA on June 17,2009. This amendment defines and exempts 

specially constructed vehicles (kit-cars) to make the rule consistent with current practices. Included in 

this request was an analysis of the number of"kit-car" vehicles that received waivers from the St. Louis 

liM program. From April of2000 to September of2007, the GCAP program exempted 109 "kit-cars" 

from the taking the emissions test. That extrapolates to approximately 15 exemptions per year. When 

compared to the total number of vehicles tested (5,933,561) for that time period, 109 exemptions equates 

to 0.00184% which is far less than one hundredth of one percent. Specially constructed vehicles or "kitcars" have limited road use and/or designated off road use. Since there are very few and these vehicle 

types have very few miles traveled, EPA agrees with MDNR's analysis that the emission impacts are 

negligible. 

There are also general revisions such as adding definitions and text changes that help add clarity to the 

I/M portion of the SIP. The majority of the revisions to 10 CSR 10-5.381 are changes that clarify the 

rule requirements and are designed to increase the integrity of the GVIP program by adding clear 

auditing and enforcement procedures. It clarifies the exemption, inspections station, vehicle inspection, 

and waiver requirements of the rule. Revisions to the rule include sections (1), (2), and (4) and 

subsections (3)(A)-(F), (3)(H), (3)(J)-(N), (5)(A), (5)(B), and (5)(D). A summary of the revisions are 

listed below by section. 

Revisions 

(1) Applicability: 

(A) (B) 

• adds acronyms and minor text revisions 

• adds language to better clarify "Gross Vehicle Weight Rating" (GVWR) 

• adds language to better clarify "out of area exemptions" subject to the rule 

• adds language to better clarify "mileage-based exemptions" and its requirements 

• clarifies that Safety Vehicle Inspection Reports are a requirement for proof of 

exemptions 

• adds language that exemptions shall be automatically issued by inspection station 

software 

15 
(S) 

(U) 

(V) 

(W) 

(Y) 

(Z) 

• adds definition of"MDOR" (Missouri Department Of Revenue) 

• adds minor text to help clarify definitions 

• adds text to better describe the definition of"OBD" for clarity 

• adds text to better describe the definition of "Qualifying Repair" 

• adds text to better describe the definition of "Recognized Labor Costs" 

• adds definition "Specifically Constructed vehicle" 

• adds definition "Vehicle Inspection Database" (VID) 

• adds definition "Vehicle Inspection Report" (VIR) 

(3) General Provisions: 

(A) Subject Vehicle Compliance, 

(B) Emissions Inspection Intervals 

• adds minor text for referencing and clarification 

(C) Emissions Inspection Periods 

• adds text to clarify inspections are valid 120 days after the inspection date for 

registration purposes and vehicle being sold is not subject to inspection for 90 days 

after sale date 

(D) Emissions Inspection Fees 

• adds text exempting fleet operators inspecting their own fleet from inspection fee 

• adds text to clarify reinspection and reinspection requirements 

• adds language to better clarify inspection fees, applicability and oversight including 

prepaid inspection credits, reimbursements, vehicle inspection database service fee 

(E) Emissions Inspection Equipment 

• language removed and language added to better explain proper functional 

characteristics of the equipment used for inspections and the procedures during 

testing including issuing stickers, camera operation and photo capturing, 

documentation to gather and enter into the system such as VIN, license number, etc ... 

(F) Emission Inspection Station Requirements 

• language added to better clarify emissions inspection stations requirements, premises, 

equipment type, equipment leasing or purchase, maintenance, functionality 

• "Inspection Fees" language removed because it was replaced and covered earlier in 

section 3(D) 

• "Operations" language was removed because new language on this topic is placed in 

section 3(H) Emissions Inspection Procedures 

• general text is added for citing purposes and clarification 

16 
method procedures, aborted testing procedures 

(J) Emission Reinspection Procedures 

• removed "Emissions Reinspection Fees" language 

• added language describing reinspection procedures J(l)(A-E) 

(K) Emissions Inspections Waivers & Exemptions 

• removes text and adds language to better describe test procedures for cost-based 

watvers 

• added language that explains vehicle operator waiver application requirement 

• added language that notifies vehicle owner or operator may be required to bring 

vehicle to the GVIP department for visual inspection 

• added language describing that if the emissions failure is not related to the exact parts 

listed in 40 CFR 51.360, the cost of the parts fixed will not count toward the waiver 

minimum 

• language added to clarify that motorist must submit the proper cost-based waiver 

application 

• added text specifying that aftermarket parts and expenses related to fixing the vehicle 

due to the installation of said parts are not included in waiver minimum 

• added language that documented repairs performed were authorized by owner 

• added language listing conditions when a cost-based waiver estimate will be issued 

• text added that grants the department the right to investigate all cost-based waiver 

requests 

• added language reiterating what (4)(H) and explaining mileage exemption 

requirements 

• added language GVWR exemption requirements and verification requirements 

(L) Quality Control Requirements 

• language removed and replaced regarding provisions of (3)(L)(2) will result in 

penalties described in (3)(N) 

• general word edits 

• lockouts, penalties, fine language were added to this section to better clarify and cite 

Missouri rules 

• language added to explain why and how stations could be fined, locked out of the 

inspection system, or a license revoked 

• added list of specific irregularities that would constitute a lockout 

• added language explaining intentional violations which constitute fines • added explanation on civil penalties for aftermarket parts 

17 
 language replaced to better clarify specific items required to be included in the Repair 

Facility Performance Report and procedures for doing that 

(D) Repair Data Sheet 

• language replaced to better detail the preparation and requirements for the Repair 

Data Sheet 

(E) Motorist Comment Form 

• replaces language to describe procedures/requirements for Motorist Comment Forms 

(F) Cost-based Waivers 

• added language listing specific required VIR documentation requirements for CostBased Waivers including: vehicles description, money accepted by dept. toward costbased waivers, staff identification documentation, sticker requirements 

(G) Reciprocity Waivers 

• Reciprocity Waiver documentation and procedures required to be included in the VIR 

(H) Mileage-based Emission Exempt Vehicles 

• added language describing and listing all documentation requirements to gather and 

report in the VIR for Mileage-based Waivers 

(I) GVW -based Emissions Exempted Vehicles 

• added language describing and listing all documentation requirements to gather and 

report in the VIR for GVW -based Emissions Exempted Vehicles 

(J) Out-of-Area Emissions Exempted Vehicles 

• added language describing and listing all documentation requirements to gather and 

report in the VIR for Out-of-Area Emissions Exempted Vehicles 

(K) Aborted Emissions Inspections 

• added language describing and listing all documentation requirements to gather and 

report in the VIR for Aborted Emissions Inspections 

(5) Test Methods 

(B) 

• adds language to better describe specific test method procedures such as bulb check, 

data link connection, communication test, readiness monitoring test, OBD verification 

tool 

18 
MDNR performed a shortfall modeling analysis to show the impacts of exempting plug-in hybrid 

electric vehicles (PHEV) from the St. Louis area Inspection and Maintenance program, and to determine 

whether or not exempting PHEV' s from taking the emissions test would prevent their I/M program from 

meeting the minimum performance standards. MDNR followed EPA recommended procedures for this 

shortfall analysis as described below. 

Because EPA's approved mobile model, Motor Vehicle Emissions Simulator or MOVES model, does 

not categorize PHEV in a separate class of vehicles, a worst case scenario was assumed in which all 

PHEV are considered to not comply or fail the I/M program. This is reflected by adjusting the 

compliance rate within the MOVES model by the direct estimated percentage ofPHEV growth for the 

projected year 2022. Therefore, the fleet ofPHEV's within the nonattainment area counted as a portion 

of the percentage of the normal passenger vehicles that are not complying with the program. In other 

words, all PHEV's were treated as passenger vehicles that are out of compliance or failing the I/M 

program. This methodology is recognized as being extremely conservative. However, until the MOVES 

model can account for PHEV vehicles, EPA believes the MDNR's analysis to predict the future impact 

ofPHEVs being removed from liM program is approvable. MDNR ran the MOVES model for two 

different scenarios in this analysis. The first scenario ran MOVES using their current fleet and projected 

the growth of that fleet to the year 2022 (horizon year in Missouri's Maintenance Plan). The second 

modeling scenario utilized the same input parameters, but adjusted the compliance rate of the PHEV 

market growth for the year 2022. To estimate the growth ofPHEV market penetration in 2022, Missouri 

used 0.43% market sales per year, starting in 2012 until the horizon year of2022. For detailed 

information on how MDNR established the .043% ofPHEV growth, see their demonstration titled 

"Technical Support Document for the Amendment of 10 CSR-5.3 81, On-Board Diagnostics Motor 

Vehicle Emissions Inspection April 18, 2012." The modeling results were then compared for differences 

m emtsswns. 

C.2 Shortfall Analysis Results 

The results from two different modeling runs show an increase in emissions. There is an increase of 

emissions by 0.03% for VOC, 0.01% for NOx, and 0.03% for CO (Table C-1 through C-4). These 

differences are far less than one-tenth of one percent and equate to increases of 12 lbs for VOC, 10 lbs 

for NOx, and 146 lbs of CO per ozone season day emissions for the entire St. Louis area that is 

composed of five Missouri counties 

These negligible increases are only visible by rounding the ozone precursor pollutant numbers to the 

third decimal place (Table C-1 through C-4) showing a small increase in emissions. EPA recognizes that 

treating PHEV's as a normal passenger vehicle not complying or failing the liM program is drastically 

conservative. PHEV's do have the capability of operating for 40 miles of battery life before getting 

assistance from combustion power. If a driver of a PHEV is nonaggressive, the usage of the internal 

combustion motor is minimized thus, relying mostly on electric propulsion and producing little or no emissions during this time. PHEV's are certainly less polluting than an average vehicle on today's 

19 
y 

q

g

g

compound emissions in the nonattainment area, not an increase. Therefore, the penetration ofPHEV's, 

especially in a nonattainment area, are more likely to have a positive impact on air quality. 

Missouri's conservative analysis demonstrates that the emissions impacts from exempting PHEV from 

the St. Louis liM program are insignificant and consequently, even when considering an unlikely worstcase scenario whereby all PHEV's fail, Missouri's modeling demonstrates that the area will meet the 

EPA's performance standard. 

Table C-1 Table C-2 

2022 GVJP Mobile Emissions (Tons Ozone Season Day) 2022 GVJP -PHEV E xemptwn (Tons Ozone Season Day) 

County Name co NOx voc County Name co NOx voc 

Franklin County 19.573 3.128 1.395 Franklin County 19.578 3.128 1.396 

Jefferson County 27.836 4.055 2.358 Jefferson County 27.842 4.055 2.358 

St. Charles County 40.254 5.991 3.247 St. Charles County 40.264 5.992 3.248 

St. Louis County 155.186 24.638 11.234 St. Louis County 155.228 24.641 11.237 

St. Louis City 41.224 6.969 2.783 St. Louis City 41 .235 6.970 2.783 

Totals 284.074 44.781 21.017 Totals 284.147 44.786 21.023 

Table C-3 Table C-4 

2022 GVJP-PHEV Mobile Emissions 2022 GVJP-PHEV Exemption Mobile Emissions 

(Tons Ozone Season Da ) (GVIP to PHEV Differences) (% I Ozone Season Day) (GVIP to PHEV Differences) 

County Name co NOx voc County Name co NOx voc 

Franklin County +0.005 0.000 +0.001 Franklin County +0.03% 0.00% +0.07% 

Jefferson County +0.006 0.000 0.000 Jefferson County +0.02% 0.00% 0.00% 

St. Charles County +0.010 +0.001 +0.001 St. Charles County +0.02% +0.02% +0.03% 

St. Louis County +0.042 +0.003 +0.003 St. Louis County +0.03% +0.01% +0.03% 

St. Louis City +0.011 +0.001 0.000 St. Louis City +0.03% +0.01% 0.00% 

Totals +0.073 +0.005 +0.006 Totals +0.03% +0.01% +0.03% 

D. MISSOURI STATE HIGHWAY PATROL RULES REMOVAL 

On December 21, 2007 Missouri submitted a revision requesting that the Missouri State Highway Patrol 

rules that were in place to support the GCAP 11M program in the St. Louis nonattainment area, be 

removed from the Missouri SIP because the new rule 10 CSR 10-5.381 does not rely on the Missouri 

Highway Patrol rules for enforcement. The enforcement rules are embedded and listed in the GVIP 

rule10 CSR 10-5.381. Therefore, the highway patrol rules are not necessary for implementation of the 

emissions inspection program and do not need to be in the SIP separately. These rules are listed below in 

Table D-1. 

20 
50-2.070 Hours of Operation 11111183 8/12/85, 50 FR 32411. 

50-2.080 Licensing of Inspector/Mechanics 4/13178 8/12/85, 50 FR 32411. 

Inspection Station Operational 

50-2.090 Requirements 8/11178 8/12/85, 50 FR 32411. 

Requisition of Inspection Stickers & 

50-2.100 Decals 6/12/80 8/12/85, 50 FR 32411. 

50-2.110 Issuance oflnspection Stickers & Decals 12111/77 8/12/85, 50 FR 32411. 

50-2.120 MVI-2 Form 11111183 8/12/85, 50 FR 32411. 

50-2.130 Violations of Laws or Rules Penalty 5/31174 8/12/85, 50 FR 32411. 

50-2.260 Exhaust System 5/31/74 8/12/85, 50 FR 32411. 

50-2.280 Air Pollution Control Devices 12111180 8/12/85, 50 FR 32411. 

50-2.290 Fuel Tank 5/3/74 8/12/85, 50 FR 32411. 

Applicability of Motor Vehicle Emission 

50-2.350 Inspection 5/1184 8/12/85, 50 FR 32411. 

50-2.360 Emission Fee 11/1183 8/12/85, 50 FR 32411. 

50-2.370 10/13/92, 57 FR 

Inspection Station Licensing 12/21190 46778. 

50-2.380 Inspector/Mechanic Licensing 1111183 8/12/85, 50 FR 32411. 

50-2.390 Safety/Emission Stickers 11/1183 8/12/85, 50 FR 32411. 

50-2.401 10/13/92, 57 FR 

General Specifications 12/21190 46778. 

The SIP does not 

10/13/92, 57 FR include Section (6), 

50-2.402 MAS Software Functions 12/21 /90 46778. Safety Inspection. 

The SIP does not 

include Section (3)(B)4, 

Safety Inspection Sequences or 

Missouri Analyzer System (MAS) Display (3)(M)5(11), Safety 

50-2.403 and Program Requirements 12/2 1190 10/13/92, 57 FR 46778 Inspection Summary. 

The SIP does not 

include Section (5), 

Safety Inspection 

50-2.404 Test Record Specifications 12/21190 10/13/92, 57 FR 46778 Results. 

Vehicle Inspection Certificate, Vehicle 

Inspection Report, and Printer Function 

50-2.405 Specifications 12/21190 10/13/92, 57 FR 46778 

10/13/92, 57 FR 

50-2.406 Technical Specifications for the MAS 12/21190 46778. 

Documentation, Logistics and Warranty 10113/92, 57 FR 

50-2.407 Requirements 12/21190 46778. 

10/13/92, 57 FR 

50-2.410 Vehicles Failing Reinspection 12/21190 46778. 

Procedures for Conducting Only Emission 10/13/92, 57 FR 

50-2.420 Tests 12/21/90 46778. 

21 
Table 1-1 from the Early Progress Plan demonstration shows the Missouri portion of the St. Louis 

nonattainment area emissions inventory totals for 2008 and 2015, as broken down by source category 

and presented in tons per ozone season day emissions. Figure 1-2 places those totals in a bar graph to 

display a visual trend of emissions over time. Based on the emissions inventory analysis, there is a 

reported emissions decrease in all three ozone precursor pollutants between the 2008 and 2015 

timeframe. These decreases are displayed in ozone season day emissions and are as follows: (321.4 tons 

of CO), (98.4 tons ofNOx), and (26.7 tons ofVOC). 

Table 1-1 

2008 and 2015 CO, NOx, and VOC Emissions 

2008 CO, NOx, and VOC Emissions for the Missouri Portion 

ofthe St. Louis Ozone Nonattainment Area (Tons per Ozone Season Day) 

Source Category co NOx voc 

Point Sources 33.14 88.84 18.01 

Area Sources 17.31 6.52 99.47 

On-Road Mobile Sources 593.43 161.25 60.86 

Off-Road Mobile Sources 527.74 65.18 45.08 

Total 1,171.61 321.79 223.42 

2015 CO, NOx, and VOC Emissions for the Missouri Portion 

of the St. Louis Ozone Nonattainment Area (Tons per Ozone Season Day) 

Source Category co NOx voc 

Point Sources 34.33 86.32 21.6 

Area Sources 18.28 6.64 111.73 

On-Road Mobile Sources 353.49 76.70 32.70 

Off-Road Mobile Sources 444.07 53.72 30.67 

Total 850.17 223.37 196.70 

22 
400 

200 

150 

100 

50 

0 ~------------------/ 0 

2008 Emissions 2015 Emissions 2008 Emissions 

St. Louis Area Total Emissions 

Comparison 2008 & 2015 

2008 Emissions 2015 Emissions 

2015 Emissions 

2671ons 

Table 1-3 lists the total emissions for the St. Louis nonattainment area and shows a decrease of ozone p~ecursor pollutants before and after the VM program conversion. The trend of continually decreasing 

emissions even after the IIM program conversion, supports that the VM program conversion did not 

interfere with the state's ability to attain and maintain attainment of the 1997 8-hour ozone standard and 

will not interfere with or delay the state's progress toward attainment for the 2008 standard. This is 

based on the projections that show the area will continue to show significant decreasing emissions 

out to 2015. 

Table 1-3 

Total Emissions St. Louis MO Nonattainment Area (Tons Per Ozone Season Day) 

voc co NOx 

*2002 310.73 1,868.81 424.86 

*2005 272.46 1,483.13 362.03 GCAP 

2008 223.42 1,171.61 321.79 

2015 196.70 850.17 223.37 GVIP 

*Values ongmate from EPA's National EmiSSions Inventory data base (other values are from MDNR's Early Progress Plan) 

23 
The area's design value is determined by the single highest individual monitor's design value for each 

three consecutive ozone season averaging period. Design values are calculated by averaging the annual 

fourth-highest daily maximum 8-hour ozone concentrations over the three consecutive years (40 CFR 

Part 50). The standard at a site is met when the site's design value is less than or equal to 0.084 ppm (84 

ppb) for the 1997 Ozone National Ambient Air Quality Standard. For the eight-hour ozone standard, the 

design value at all monitors for the three-year time periods from 2008 through 2010 did not exceed 

0.084 ppm, and thus achieved attainment for the St. Louis nonattainment area. 

The calculated 2008-2010 8-hour design values for sites in the St. Louis nonattainment area are 

presented in Table 2-1 a. As shown in the table, all sites three-year design values are less than the 1997 

standard, demonstrating that the St. Louis area has attained the 1997 8-hour air quality standard. The St. 

Louis nonattainment area's design value monitor would be the West Alton monitor, due to its design 

value being the highest. The West Alton monitor is bold in Table 2-1a. The latest data calculating 2011-

2013 8-hour design values are listed in Table 2-1b. All monitors in the St. Louis nonattainment area are 

below the 1997 8-hour ozone standard. 

Table 2-la 

2008-2010 St. Louis 8-Hour Design Values 

(1997 NAAQS = 84 ppl b) 

2008 4th 2009 4th 2010 4th 2008-2010 

County Monitoring Sites High High High Design Value 

Missouri 

St. Charles Orchard Farm 72 73 77 74 

St. Charles West Alton 76 71 84 77 

St. Louis City Blair Street 73 65 71 69 

St. Louis Maryland Heights 69 70 76 71 

St. Louis Pacific 64 64 69 65 

Jefferson Arnold West 70 70 77 72 

Table 2-lb 

2011-2013 St. Louis 8-Hour Design Values 

(1997 NAAQS = 84 ppb) 

2011 4th 2012 4th 2013 4th 2011-2013 

County Monitor High High High Design Value 

St. Charles Orchard Farm 77 86 71 78 

St. Charles West Alton 84 92 71 82 

St. Louis City Blair Street 79 87 66 77 

St. Louis Maryland Heights 80 90 70 80 

St. Louis Pacific 70 85 67 74 

Jefferson Arnold West 75 85 69 76 

24 
100 

95 ------------------------ ______ ..,":'" ____ ------------------------------

90 .. ------"-

Bll -- -·-· ..• -- ------· ------

...... • : '!! ·, 

Concentrations in (ppb) . \ . y 

. 

"- .J • ·· '\ .

..... 

/ 

80 - - - - -- -- -- - .. --- ____ , - - - ----- -

., "<.;<>.. 

.. 

-

75 . 

....... 

... _ 

• ' 

. 

'• 

70 -··----------· ------------------------------------------- --

., 

65 . - - '\.---

60 

08-10 

-orchard Farms 92 88 86 86 89 82 71 74 

--West Alton 91 89 85 85 89 811 78 77 

Clark (relocated) 74 70 

- Blair Street 84 78 711 69 

--Margaretta (discontinued) 89 86 84 79 86 81 

South Broadway (discontinued) 83 

--Ferguson (relocated) 88 83 

- Maryland Heights 88 82 77 71 

- Ladue (discontinued) 85 81 

Breckenridge Hills (discontinued) 86 83 

Sunset Hills (discontinued) 91 811 82 79 86 78 

Queeny Parks (relocated) 88 82 78 

_......,..___.,Pacific 83 76 71 65 

Arnold (relocated) 87 81 81 80 85 

___.__ Arnold West 79 711 72 

- - . - Violation of the 1997 NAAQS 85 85 811 85 811 85 811 811 

25 
p

g

y 

g 

g 

y 

of projected attainment for the 2008 8-hour ozone standard. 

First, emissions totals and monitor values for all ozone precursors have been steadily decreasing since 

the GVIP program was implemented. As fully described in Section IV 1 and 2, total emissions of ozone 

precursor pollutants for the St. Louis nonattainment area have been continually decreasing even after the 

VM program conversion. In addition, monitoring data illustrates trends of decreasing ozone 

concentrations since 2008, indicating improved air quality throughout the St. Louis area. These trends 

support that the VM program conversion did not interfere with the area's ability to maintain attainment 

of the 1997 8-hour ozone standard and will not interfere with or delay the state's progress toward 

attainment for the 2008 8-hour ozone standard. 

Furthermore, EPA has analyzed and modeled the differences in emissions between the GCAP and GVIP 

programs. That analysis shows a decrease in NOx and VOC emissions from GVIP compared to GCAP, 

which is consistent with overall inventory trends. While it may appear that because the GCAP program 

included an I/M240 tailpipe test for some vehicles, it would produce better controls than that of the 

GVIP OBD-only program. In reality however, there are multiple aspects in which the revised GVIP VM 

program and associated state rules are more stringent in practice with respect to air quality. Specifically, 

the programs' differences in waiver rates, compliance rates, removing clean screening, testing diesel 

vehicles, and enforcement with an implemented penalty schedule represent increased stringency 

compared to the GCAP program.2·i 

To determine whether the SIP revision complies with Section 110(1) ofthe Act, EPA Region 7 utilized 

MOVES2014 and performed a mobile modeling exercise to show the differences in emissions between 

the previous GCAP VM program and the revised GVIP liM program.3 EPA modeled the five counties 

making up the St. Louis 2008 8-hour ozone nonattainment area for the year 2015. This is the year the St. 

Louis area is projected to show attainment for the 2008 ozone standard. 

As explained above, several elements of the GVIP program are more rigorous than those of the GCAP 

program. One important element is the clean screening provision included in the GCAP program.2 The 

clean screening provision in GCAP was aimed at reducing the number of vehicles subject to required 

tailpipe testing up to 40% based on remote sensing. In the Missouri GCAP VM SIP, MDNR used an 

extremely conservative approach to account for clean screening using MOBILE 6. Because MOBILE 6 

was not fully equipped to account for clean screening, MDNR characterized clean screening by setting 

the VM Effectiveness input in MOBILE 6 at 50% of what would otherwise be assumed for a centralized 

VM program. In other words, MDNR assumed that the emissions benefits of GCAP would be reduced 

by 50% due to the clean screening provision. For EPA's modeling demonstration, because MOVES2014 

is similarly not equipped with parameters to account for clean screening, and to ensure consistency with 

2 There are other elements of the GCAP program that are less stringent than the GVIP program but are difficult to quantify in 

terms of emissions reductions. For a full discussion of the improvements of the revised program, see endnote i. 

3 Run-Specs for the MOVES20 14 input parameters are included in the docket. 

26 
2015 NOx voc 

GCAP I/M240 ( 100% liM Effectiveness) 4.94 4.10 

(50% liM Effectiveness) 2.47 2.05 

GCAPIIM240 2.47 2.05 

GVIP OBD Only 3.48 2.32 

Table 3-2 and Figure 3-2 display the St. Louis area mobile modeling results of total NOx and VOC onroad mobile emissions, which show an emissions decrease of 1.01 tons for NOx and 0.27 tons for VOC 

emissions with the new GVIP program. 

35.00 30.00 

25.00 

20.00 

15.00 10.00 

5.00 

0.00 

Table 3-2 

StLouis Area Ozone Season Day Emissions (tons) 

GCAPvs GVIP 

2015 NOx voc 

GCAP liM 240 33.24 24.16 

GVIP OBD Only 32.23 23.89 

Difference 1.01 .27 

Fi ure 3-2 

St. Louis Area Ozone Season Day 

Emissions 

GCAPvs GVIP 

• Nox • voc 

GCAP 1/M 240 GVIP OBD Only 

27 
despite the changes to the VM program. 

Table 3-3a 

On-Road Mobile Decreases for CO, NOx and VOC Emissions for the Missouri Portion 

of the St. Louis Nonattainment Area (Tons Per Ozone Season Day) 

( GCAP - Prior to the 11M Conversion) 

co NOx voc 

*2002 On-Road Mobile Source 1,316.13 191.39 109.04 

2008 On-Road Mobile Source 593.43 161.25 60.86 

On-Road Total Emissions 

Decreases 722.70 30.14 48.18 

*The 2002 On-Road emissions originates from EPA's National Emissions Inventory database. 

Table 3-3b 

On-Road Mobile Decreases for CO, NOx, and VOC Emissions for the Missouri Portion 

of the St. Louis Ozone Nonattainment Area (Tons per Ozone Season Day) 

(GVIP - After the 11M Conversion) 

Source Category co NOx voc 

2008 On-Road Mobile Sources 593.43 161.25 60.86 2015 On-Road Mobile Sources 353.49 76.70 32.70 

On-Road Total Emissions 

Decreases 239.94 84.55 28.16 

In conclusion, an evaluation ofthe overall trend of emissions decreases, EPA's MOVES2014 mobile 

modeling and analysis showing emissions decreases, indicates that the program conversion does not 

interfere with the area's ability to maintain the 1997 8-hour ozone standard, nor interfere with area's 

progress toward attainment or cause or contribute to a delay in the timeframe of projected attainment for 

the 2008 8-hour ozone standard. 

Kit-Cars 

For the SIP revision related to "kit-cars" as discussed in detail in Section 3.B, based on the number of 

"kit-cars" in the area (fifteen) as compared to the 1.5 million vehicles subject for testing in the area, this 

amounts to less than 1 oath of one percent of the total vehicles (section B). Any emissions produced from 

the minute number of"kit-cars" is considered a negligible amount and would be account for in the 

decreasing emissions from the VM program conversion from GCAP to GVIP (Table 3-2). Therefore, 

exempting "kit-cars" in St. Louis does not interfere with the area's ability to maintain the 1997 8-hour 

ozone standard, nor interfere with area's progress toward attainment or cause or contribute to a delay in 

the timeframe of projected attainment for the 2008 8-hour ozone standard. 

28 
introducing PHEV

s into St. Louis would likely decrease VOC, CO and NOx emissions. Therefore, 

exempting PHEV's do not interfere with the St. Louis area's ability to maintain the 1997 8-hour ozone 

standard, nor interfere with area's progress toward attainment or cause or contribute to a delay in the 

timeframe of projected attainment for the 2008 8-hour ozone standard. 

SUMMARY AND FINAL CONCLUSION 

The SIP revisions submitted by MDNR are: (A) INSPECTION/MAINTENANCE (liM) PROGRAM 

CONVERSION, (B) GENERAL REVISIONS/SPECIALLY CONSTRUCTED VEHICLE 

DEFINITION, (C) PLUG-IN HYBRID ELECTRIC VEHICLE (PHEV) EXEMPTION, (D) MISSOURI 

STATE HIGHWAY PATROL RULES REMOVAL, all of which include an emissions impact 

demonstration, data analysis of the changes to the liM program, or an explanation of general edits to text 

language. After analyzing the demonstrations and data analysis, as discussed in sections A, B and C, the 

results demonstrate that the SIP revisions will not have an adverse impact on air quality. 

Aside from the mobile source demonstrations and data analyses, the ozone precursor emissions 

inventory, over time, shows an overall trend of decreasing emissions as discussed in sections 1 and 2. 

MDNR's Early Progress Plan demonstration shows the projected decreases in CO, NOx and VOC 

emissions from 2008 to 2015 are 27%, 31% and 12% respectively, resulting in a significant decrease of 

321.4 tons of CO, 98.4 tons ofNOx, and 26.7 tons ofVOC per ozone season day emissions. In other 

words, 2008 emissions for these pollutants for ozone season day were much higher than ozone season 

day emissions projected in 2015 (Table 1-1) (Figure 1-2). 

Furthermore, the monitoring values show a decrease in ozone concentrations that began in the mid2000's and continues to decrease well below the 1997 8-hour ozone standard for all monitors in the St. 

Louis area. As stated earlier, all sites in the area are now in compliance of the 1997 ozone standard, as 

shown by the design value data in Figure 2-1 a and 2-1 b. Moreover, the trend continues to decrease 

(Figure 2-1), thus, supporting that none of these SIP revisions will have a negative impact on the state's 

ability to maintain the air quality for the 1997 ozone standard nor interfere with state's progress toward 

attainment or cause or contribute to a delay in the timeframe of projected attainment for the 2008 8-hour 

ozone standard. 

Tables 3-3a and 3-3b show decreasing mobile source emissions directly after the implementation of the 

new GVIP liM program and associated state rules. Furthermore, the overall emissions inventory trends 

from 2008 to 2015 show there are decreasing NOx and VOC emissions in the area and supports there are 

no increases from these SIP revisions. In fact, any possible slight increase in emissions in an unlikely 

worst-case scenario, by exempting PHEV's or exempting "kit-cars" have been accounted for alone by 

the liM conversion from GCAP to GVIP. This modeling analysis shows decreases in ozone precursor 

emissions in the St. Louis area by implementing the newer GVIP liM program (Table 3-2, Figure 3-2). 

29 
p

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p

p

g

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y 

passenger vehicles and some heavy-duty vehicles. This will result in significant reductions in pollutants 

such as ozone, particulate matter and air toxics across the country and help state and local agencies in 

their efforts to attain and maintain health-based National Ambient Air Quality Standards. In 2030, a 

reduction from NOx and VOC emissions from on-highway vehicles will be reduced by an estimated 

21%, and CO emissions reduced by 24%. Reductions will continue beyond 2030 for NOx and VOC of 

nearly 31% by 2050. For more information see the final rule web page titled Tier 3 Vehicle Emission 

and Fuel Standards Program at http://www.epa.gov/otaq/tier3.htm. 

In conclusion, the evidence provided in this technical support document and Missouri's SIP submittal 

demonstrations show these changes to the VM program and associated rule do not interfere with state's 

ability to attain or maintain the 1997 8-hour ozone standard nor interfere with state's progress toward 

attainment or cause or contribute to a delay in the timeframe of projected attainment for the 2008 8-hour 

ozone standard. Therefore, MDNR's VM program SIP revision demonstrates that St. Louis continues to 

meet the applicable VM performance standard, and that the changes to the VM program does not and 

will not compromise the State's efforts to meet and/or maintain the 1997 8-hour ozone, 2008 8-hour 

ozone, or PM2.5 NAAQS and therefore, EPA supports approving these SIP revisions that add and 

amend 10 CSR 10-5.381. 

References: 

1. 1990 CAA ofNovember 15. 1990: 

section 182(b)(4); requirement for VM programs, 

section, 182(a)(2)(B); requirement for EPA to publish updated guidance for state I/M programs, section 11 O(k)(3 ), EPA action on SIP submissions, 

section 11 0(1) 

2. VM regulations promulgated on November 5, 1992 (57 FR 52950), and codified in 40 C.F.R. 

Part 51 , SubpartS, sections 51.350 - 51.373. 

3. Contract for the VM program 

4. MOCSR 

5. MDNR Early Progress Plan 

6. Tier 3 Vehicle Emission and Fuel Standards Program http://www.epa. gov/otaq/tier3.htm 

7. St. Louis Clean Data Determination (76 FR 33647, June 9, 2011). 

i When the St. Louis vehicle liM SIP was revised in 2007 to change from a centralized network featuring IM240 testing on 

model year 1995 and older vehicles and OBD testing on model year 1996 and newer vehicles to a decentralized program that 

only tests model year 1996 and newer vehicles using the OBD test, it would seem that the overall program had been 

weakened. In reality and practice, however, many elements of the revised, decentralized St. Louis program are more rigorous 

than those of the centralized program the newer program replaces, largely offsetting any potential shortfall created by 

dropping the ever-shrinking number of non-OBD-equipped vehicles from the inspection. The following lists areas in which 

the newer, OBD-based decentralized program represents a strengthening of the 11M SIP relative to the previous version. 

Rolling Model Year Vehicle Testing for IIM240 

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component aimed at exempting 20% of the subject fleet based upon remote sensing device (RSD) readings indicating that the 

vehicles in question might pass the regular inspection. Because remote sensing only looks at tailpipe emissions and is 

generally less rigorous compared to the regular 11M testing used in the program, some of these vehicles identified as "clean" 

would fail the regular inspection, which in turn would lower the emission reductions expected from the program. For 

example, a vehicle failing its gas cap evaporative emission or the OBD evaporative emission tests would not be detected by a 

test that only looks at tailpipe emissions. Additionally, RSD would not "see" OBD-identified emission control malfunctions 

that do not immediately result in high tailpipe emissions but will eventually, as a result of, for example, catalyst poisoning. It 

is this "early warning" feature of OBD that makes it superior to traditional tailpipe testing for vehicles so equipped. The 

removal of the "clean screen" component as part of the newer St. Louis 11M program therefore represents a strengthening of 

the program compared to the earlier 11M SIP. 

100% versus 50% 11M Effectiveness: Following the release of the MOBILE6 model that Missouri used to estimate the 

emission reductions attributable to the earlier GCAP 11M program, EPA provided a utility that was to be run in conjunction 

with the MOBILE model to estimate the loss of reductions resulting from a clean screen program like the one described 

above. There is no evidence in the SIP submission for that earlier GCAP program that the State made use of the MOBILE6 

clean screen utility. Instead, Missouri appears to have used a far more conservative approach by setting the 11M Effectiveness 

input for the earlier SIP program at 50% of what would otherwise be assumed for a centralized program without clean 

screening. Because the newer GVIP program eliminates the clean screen component and is otherwise equivalent to the 

effectiveness of a centralized 11M program of comparable design (i.e., 100% effective), the MOVES2014 modeling 

performed to estimate any potential shortfall between the older GCAP and newer GVIP St. Louis 11M programs has assumed 

a 100% effectiveness level for the new program, while adjusting the MOVES2014 results for the old GCAP program to 

reflect the 50% effectiveness level assumed by the State in the earlier 11M SIP. 

8% versus 3% Waiver Rates: The previous GCAP 1/M SIP for St. Louis assumed an 8% waiver rate, meaning that roughly 

8% of vehicles that initially failed the 1/M inspection would not be fixed to pass the inspection but would qualify for a waiver 

instead after spending a set amount on relevant albeit unsuccessful repairs. Given that waivers are limited to vehicles that are 

known to have failed, a small increase in the waiver rate can have a disproportionately negative impact on the emission 

reductions achieved by the program. Conversely, a reduction in the waiver rate can have a significantly positive impact on the 

emission reductions achieved by the program. In the case of the new St. Louis 11M program versus the older program, the 

latter case holds, with the newer GVIP program reporting actual waiver rates of just 2.5% for the last several years, meaning 

that the new GVIP program is more rigorous than the GCAP program it replaces. 

Improved Penalty Schedule Adopted: Under the previous GCAP 11M program, the State's penalty schedule was relatively 

lax with the cost of compliance often being higher than the penalty for non-compliance. Under the newer program, a formal 

penalty schedule was adopted to correct this deficiency. While the impact of the improved penalty schedule cannot be 

directly quantified, it nevertheless represents another way in which the new GVIP program is stronger than the older GCAP 

program it replaces. 

Adding Diesel Vehicles Tested: In the previous GCAP 11M SIP, vehicles operating on diesel fuel were not required to be 

tested. The revised GVIP program requires 1997 and newer vehicles operating on diesel fuel below 8,500 pounds gross 

weight subject to testing. 

Compliance Rate of GCAP versus GVIP: The previous GCAP 11M program SIP assumed a 96% compliance rate for the 

entire program. EPA believes that this number overestimates the program. In any case, the revised GVIP program has been 

reporting a 98.59% compliance rate for several years. Once again, the newer GVIP program is stronger than the older GCAP 

program it replaces. 

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