REVECORP INC. Research and Consulting Services 

1641 Grey Owl Circle, Roseville, CA 95661 USA 916.786.1006 

Testimony Before EPA Regarding Revised NAAQS for Ozone 

Docket ID No. EPA–HQ–OAR–2005–0172

February 4, 2010

Dr. Michael J. St. Denis, Principal 

Revecorp Inc. 

1641 Grey Owl Circle 

Roseville, CA 95661 

(916) 786-1006 

Michael@Revecorp.com 

First I would like to thank EPA for the opportunity to testify at this hearing. I am 

Dr. Michael St. Denis and I am the Principal Scientist and Owner of Revecorp, an 

air pollution control research company focusing on vehicle emissions. I have 

been working in the field of vehicle emissions control for almost 20 years and 

worked on the original pilot studies that resulted in the development of the 

vehicle emissions testing procedures still in use today, including those used in 

California’s “Smog Check” program. I have worked with all of the test equipment 

and emissions testing service providers in the industry, more than half the state 

government Inspection/Maintenance programs in the US and performed research 

for US EPA, the California Air Resources Board and the auto industry. 

Vehicles are the single largest source of the ozone precursors, hydrocarbons and 

NOX. Significant progress has been made over the past 20 years to reduce 

emissions from vehicles including great focus on new vehicle emissions control 

technology. Unfortunately, new vehicles are only new and emitting at new levels 

for a relatively short period of time. The bulk of excess vehicle emissions come 

from changes which take place while the vehicles are in-use and are dependent 

upon maintenance by vehicle owners. Regulatory agencies including US EPA 

have not had the same focus on in-use vehicle emissions reduction programs as 

they have on new vehicle programs, even though in-use emissions programs are 

where major emissions reductions are achieved. Vehicle inspection programs 

can be highly cost effective at reducing ozone precursors if they are properly 

designed and operated. Vehicle inspection programs also provide employment 

opportunities and help the ailing auto industry through stimulating the need for 

vehicle service and replacement parts while at the same time improving air 

quality. Other major benefits include improved fuel economy and the associated 

reductions in dependence on foreign oil that are achieved through these 

programs, as well as cost savings for consumers and health benefits for 

everyone. 

In the mid 1990’s EPA proposed a 50% discredit for vehicle inspection programs 
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which were decentralized – that is – performed by private garages. Eventually 

this automatic discredit was replaced with “flexibility” which allowed states to 

prove their vehicle inspection programs are as effective as they claim. Fifteen 

years later, EPA has not forced states to do the required “program evaluations” 

to prove program effectiveness and the less efficient decentralized programs are 

still in effect in places like CA. If EPA is serious about reducing public exposures 

to ozone, you must increase your focus on vehicle inspection programs and 

making sure states have effective programs. CA has found in their own studies 

that there is an almost 50% fraud rate – the same as the discount EPA proposed 

in the mid 1990s, yet fifteen years later the CA program is allowed to operate 

their vehicle inspection program in the same ineffective manner as always and 

take full credit. 

If the ozone standard is reduced, vehicle inspection programs can help achieve 

the revised standard. The industry has the technology to achieve emissions 

reductions in a cost effective manner. I support the reduction in the ozone 

standard, but only if EPA provides more support and focus on vehicle inspection 

programs in the future. The recession that has hit the country has resulted in 

lower new car and truck sales, with older vehicles remaining on the road longer. 

These vehicles will pollute more as they continue to age and accumulate higher 

mileages. Particularly under the current economic conditions, vehicle inspection 

programs are needed to offset the accelerated aging of the nation’s vehicle fleet 

and ensure that pollution from those cars and trucks remains within acceptable 

limits. EPA’s focus and guidance must include providing the research necessary 

for states to evaluate their vehicle inspection programs, requiring states to 

perform program evaluations, and requiring programs to meet the level of 

effectiveness they claim. 

Thank you.