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## . **Research and Consulting Services 1641 Grey Owl Circle, Rosevil**  **le, 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 opportuni ty to testify at this hearing. I am

Dr. Michael St. Denis and I am the Princi pal Scientist and Owner of Revecorp, an air pollution control research company focusing on vehicle emissions. I have been working in the field of vehicle emi ssions control for almost 20 years and worked on the original pilot studies t hat 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 progr ams in the US and performed research for US EPA, the California Air Res ources Board and the auto industry.

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

NO X . 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. R egulatory agencies including US EPA

have not had the same focus on in-use v ehicle emissions r eduction programs as they have on new vehicle programs, ev en though in-use emissions programs are where major emissions reductions are ac hieved. Vehicle inspection programs can be highly cost effective at reducing ozone precursors if they are properly designed and operated. Vehicle inspecti on programs also pr ovide employment opportunities and help the a iling auto industry through stimulating the need for vehicle service and replacement parts wh ile at the same time improving air quality. Other major benef its 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% discr edit for vehicle inspection programs

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Revecorp Inc. Page 2 which were decentralized – that is – per formed by private garages. Eventually this automatic discredit was replaced with “flexibility” which allowed states to prove their vehicle inspection programs ar e 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 fo cus on vehicle inspection programs and making sure states have effective program s. 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 t he 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 t hat 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 accelera ted aging of the nation’s vehicle fleet and ensure that pollution from those ca rs and trucks remains within acceptable limits. EPA’s focus and guidance must include providing the research necessary

for states to evaluate their vehicle in spection programs, requiring states to perform program evaluations, and requiri ng programs to meet the level of effectiveness they claim.

Thank you.