Alaska Department of Environmental Conservation

Amendments to:

State Air Quality Control Plan

Vol. II: Analysis of Problems, Control Actions

Section III.A: Statewide Carbon Monoxide Control Program

Adopted

August 20th, 2010
Adopted August 20th, 2010

III.A.1-1

Volume II, Section III.A is proposed to be amended as follows:

III.A STATEWIDE CARBON MONOXIDE CONTROL PROGRAM1

III.A.1. Carbon Monoxide- Air Quality Standards & Health Effects 

A.1.1 Carbon Monoxide National Ambient Air Quality Standards

The U.S. Environmental Protection Agency (EPA) has set the National Ambient Air 

Quality Standard (NAAQS) for Carbon Monoxide (CO) at 35 parts per million (ppm) for 

a 1-hour average and 9 ppm for an 8-hour average, not to be exceeded more than once per 

year (See 40 CFR 50.8). This health-based standard is intended to protect those most 

sensitive to the effects of CO exposure. In order for a community to violate the health 

standard it must have two exceedances at the same site during the calendar year (i.e., two 

exceedances equals one violation).

A.1.2 Carbon Monoxide Health Effects

Carbon monoxide (CO) is a colorless, odorless, and poisonous gas produced by 

incomplete fuel combustion. Research indicates that high levels of CO deleteriously 

affects the human cardiovascular and central nervous systems. The health threat from 

CO appears most serious for those who suffer from cardiovascular disease, particularly 

those with angina or lung disease. Other probable risk groups include fetuses and young 

infants, pregnant women, and the elderly, especially those with compromised heart and 

lung function. There is also evidence that neurobehavior (e.g., eye-hand coordination, 

visual sensitivity, etc.) may be affected by exposure to CO concentrations above the 

NAAQS. 

Exposure to high levels of CO causes adverse impacts to health, due primarily to 

diminished oxygen transport by the blood and interference with biochemical utilization of 

oxygen in the tissues. CO competes with oxygen for chemical binding with hemoglobin 

in the blood. Moreover, the binding of CO to hemoglobin is roughly 240 times stronger 

than that of oxygen. This binding results in elevated carboxyhemoglobin (COHb) levels, 

with a reduction in the oxygen-carrying capacity of the blood proportional to the amount 

of COHb present. As a result, elevated ambient CO concentrations cause the partial 

exclusion of oxygen from its normal physiological role in the human body.

 

1: In this document each reference to “CAAA” means the Clean Air Act Amendments 

of 1990, P.L. 101-549.
Adopted August 20th, 2010

III.A.1-2

At extremely high CO concentrations (e.g., in the case of exhaust system leakage into a 

car's passenger compartment), COHb levels rapidly reach a level where inadequate 

amounts of oxygen reach the tissues, and carbon monoxide poisoning results. Such highlevel, short-term exposures result in unconsciousness and death unless victims are 

removed from the CO source and provided with medical care. CO uptake in the blood is 

a reversible process. Because of this, medical care for acute CO poisoning often includes 

treatment with 100% oxygen. When available, hyperbaric oxygen therapy (where the 

victim is placed in a pressurized chamber filled with oxygen) is preferable.

In urban areas, lower-level acute exposure to CO often results from concentrations near 

the NAAQS. Such marginal CO levels avoid the high-level acute effects, but still may 

cause adverse cardiovascular and central nervous system effects. The NAAQS was 

therefore set at a threshold below the lower level where adverse human health effects 

begin to occur. In particular, it was set to protect the health of the most susceptible 

individuals, including those with cardiovascular conditions, pregnant women, and young 

children. 

In addition to the acute effects described above, there has been speculation that adverse 

health effects may be caused by exposure to very low-level, long-term chronic CO 

concentrations. This has led some Anchorage residents and others to suggest that 

ambient CO concentrations should be reduced well below the NAAQS.

According to an air quality criteria document previously prepared by EPA ("Air Quality 

Criteria for Carbon Monoxide,” October 1979), a threshold is usually defined as the point 

where an effect is noticed 50 percent of the time. Although the NAAQS is set at a "safe" 

level, some research has indicated there is no CO level where all adverse health effects 

can be avoided. If chronic CO exposure produces adverse health effects, lowering 

ambient CO concentrations to levels well below 9 ppm for an 8-hour average could be 

expected to have some health benefits beyond merely achieving the ambient standard. 

The EPA criteria document, however, states that "the presence of a clinical state of 

chronic CO poisoning ... has not been verified." (This issue relates to possible adaptation 

to CO in humans resulting from chronic exposures.) No evidence is presented in the 

criteria document that supports the theory of adverse health effects from chronic 

exposure. Medical experts believe that the NAAQS represents a level that reasonably 

protects public health from ambient CO pollution. Subsequent reviews of the CO 

NAAQS have reaffirmed the 9 ppm eight-hour standard.
Adopted August 20th, 2010

III.A.2-1

III.A.2 Alaska’s Carbon Monoxide Control Strategy 

The Alaska Department of Environmental Conservation (ADEC) is the primary agency 

responsible for air quality control in Alaska. ADEC’s CO control strategy in Alaska is a 

multifaceted approach consisting of public participation, statute and regulation 

development, CO control program development, CO monitoring, compliance and 

enforcement. The following section provides a brief description and history of the MOA 

and the FNSB CO maintenance areas. This section describes the role of ADEC, MOA 

and FNSB in implementing programs that reduce CO emissions including a 

chronological history of Alaska’s State Implemenation Plan (SIP) submissions. This 

section also briefly describes the role of EPA, the Alaska Department of Transportation 

& Public Facilities (ADOT/PF) and the Federal Highway Administration (FHWA) in 

assisting the two CO maintenance areas in achieving and maintaining the CO NAAQS. 

Finally, this section provides a brief history of Alaska’s vehicle emissions inspection and 

maintenance (I/M) program; and a detailed description of Alaska’s I/M and Oxygenated 

Fuels programs as they exist currently. Combined, these efforts make up ADEC’s CO 

control strategy in Alaska with respect to its CO maintenance areas. 

A.2.1 Alaska’s Carbon Monoxide Maintenance Areas

In Alaska, ambient CO concentrations above the NAAQS have been predominantly 

caused by on-road vehicular traffic in both Anchorage and Fairbanks. Consequently, 

EPA classified portions of the Municipality of Anchorage (MOA) and the Fairbanks 

North Star Borough (FNSB) as CO nonattainment areas. These areas have since been 

classified as CO maintenance areas (See 18 AAC 50.015(d)). This section provides a

brief CO attainment history, CO maintenance area maps, CO monitoring concentrations

and CO control measures for the MOA and FNSB CO maintenance areas. More detailed 

histories of the MOA and FNSB CO maintenance areas are found in Volume II, Sections 

III.B and III.C, respectively. 

2.1.1 Municipality of Anchorage Carbon Monoxide Maintenance Area

Portions of the MOA were first declared a nonattainment area for CO on January 27, 

1978 (See Figure III.A.2-1). In 1982, MOA prepared a CO attainment plan which was 

incorporated as a revision to Alaska’s State Implementation Plan (SIP). A primary goal 

of the Anchorage CO attainment plan was to attain the CO NAAQS by December 31, 

1987. MOA failed to achieve attainment by the December 31, 1987 deadline mandated 

in the 1977 Clean Air Act Amendments (CAAA). The Clean Air Act (CAA) was 

amended again in November 1990. When these amendments were published, EPA 

designated Anchorage as a “moderate” nonattainment area for CO and required the 

submission of a revised CO attainment plan to bring Anchorage into attainment with the 

NAAQS by December 31, 1995. The MOA prepared a revised CO attainment plan that 

was approved by the Anchorage Metropolitan Area Transportation Solutions (AMATS) 

Policy Committee and Anchorage Assembly in December 1992. ADEC adopted the CO 

attainment plan and it was later approved by EPA as a revision to Alaska’s SIP in 1995. 
Adopted August 20th, 2010

III.A.2-2

Figure III.A.2-1- Anchorage Carbon Monoxide Maintenance Area.

The Anchorage CO nonattainment area has not exceeded the 1-hour CO NAAQS since 

1980. The Anchorage CO nonattainment area had two exceedances of the 8-hour 

standard in 1994, no exceedances in 1995, and then violated the standard twice in 1996.

2

 2

: Three exceedances of the NAAQS were measured at both the Seward Highway site and Benson 

site. Because the NAAQS allows one exceedance of the NAAQS per year at each site, three 

exceedances at a site constitutes two violations.

 
Adopted August 20th, 2010

III.A.2-3

Table III.A.2-1 lists the number of exceedances of the 8-hour CO NAAQS in the MOA 

and FNSB from 1994 through 2009. As a consequence of these violations, on July 13, 

1998, EPA reclassified Anchorage from a “moderate” to a “serious” nonattainment area 

for CO. Anchorage has not violated the CO NAAQS since 1996 and, upon review of 

Anchorage CO monitoring data, EPA determined that MOA had attained the NAAQS. 

This finding was published in a July 12, 2001 Federal Register Notice (66 FR 36476, 

August 13, 2001). The MOA CO attainment plan, demonstrating that Anchorage 

achieved the emission reductions necessary to attain the CO NAAQS by the December 

31, 2000 deadline, was completed and approved by the Anchorage Assembly on 

September 25, 2001. ADEC adopted the plan as a revision to the Alaska SIP which was 

later approved by EPA, effective October 18, 2002. 

Table III.A.2-1. Number of 8-Hour CO NAAQS Exceedances in MOA & FNSB

CO Maintenance Areas, 1994-2009.

YEAR ANCHORAGE FAIRBANKS

1994 2 3

1995 0 9

1996 3 1

1997 0 4

1998 1 2

1999 1 3

2000 0 1

2001 1 0

2002 0 0

2003 0 0

2004 0 0

2005 0 0

2006 0 0

2007 0 0

2008 0 0

2009 0 0

After the approval of the CO attainment plan, MOA prepared a CO maintenance plan

which demonstrated that CO emissions in Anchorage would remain at a level that assures 

continued attainment of the NAAQS through calendar year 2023. The CO maintenance 

plan was approved by the Anchorage Assembly on October 7, 2003 and submitted to 

ADEC as a proposed revision to the Alaska SIP. ADEC obtained approval of this SIP 

revision by EPA, effective July 23, 2004. With this approval, the EPA Regional 

Administrator reclassified Anchorage from serious CO nonattainment to an area that is in 

attainment with the NAAQS. The primary CO control measures committed for 

implementation in the 2004 CO maintenance plan were the Vehicle Emissions Inspection 

and Maintenance (I/M) Program, a Share-A-Ride/Vanpool Program and a block heater 

promotion program. 
Adopted August 20th, 2010

III.A.2-4

On November 6, 2007 the Anchorage Assembly voted to discontinue the I/M Program by 

December 31, 2009 or earlier. However, on July 15, 2008 the Anchorage Assembly

revoked this action and voted to continue I/M with some modifications. The most 

significant change to the I/M Program made at this time was extending the testing 

exemption for new cars from four to six years. Beginning January 2010, the first I/M test 

is required six years after the purchase of a new car instead of four years. At the same 

time (July 2008), however, the Anchorage Assembly also directed its Department of 

Health and Human Services to work with the ADEC to remove the I/M Program as a CO 

control requirement in the SIP with the stipulation that it be retained as a local option and 

not be subject to a further SIP revision if further local action results in changes to or a 

discontinuation of the program. 

ADEC and MOA decided to implement the changes mandated by the Anchorage 

Assembly in a two-phase SIP revision. The first phase of the revisions makes the 

relatively straight-forward changes necessary to extend the new car I/M test exemption 

from four to six years. The Assembly adopted these revisions on May 26, 2009 and a 

revised SIP was submitted and then adopted by ADEC on August 5th, 2009. This SIP 

revision also included an updated CO emission inventory, an updated motor vehicle 

emission budget and changes to the contingency measure provisions in MOA’s CO 

Maintenance Plan. 

The second phase of the CO maintenance plan revisions, which are reflected in the 

current SIP revision, addresses the more complicated issue of deleting MOA’s 

commitment to I/M program while preserving the right of the MOA to continue the 

program as a “local option”. The second phase of these SIP revisions, contained herein, 

deletes the commitment to I/M as a primary CO control measure. I/M is now included in 

the menu of contingency measures that could be implemented by MOA if it were to 

violate the NAAQS in the future. Because I/M provides reductions in CO emissions, the 

elimination of I/M was factored into new projections of future CO emissions and 

probability estimates for continued maintenance of the CO NAAQS. No other 

substantive changes have been made to the SIP. 

The implementation of Alaska’s I/M regulations act as primary CO control and 

contingency measures. With the adoption of this SIP submittal and following approval by 

the EPA, MOA plans to remove its I/M Program as a primary CO control measure and 

suspend the I/M program but is retaining its I/M program as a CO contingency measure 

in case of future violations of the CO NAAQS. With the adoption of this SIP submittal

and following approval by EPA, MOA also has the option of retaining or discontinuing 

its I/M program without having to modify its CO Maintenance Plan. 

The State of Alaska retains its regulatory authority to re-establish the local I/M programs

under 18 AAC 52.007. In the event that the MOA or FNSB CO maintenance areas 

violate the CO NAAQS in the future, ADEC would work with the MOA or FNSB to 

restart their I/M program if the violations were found to be related to vehicular traffic and 

I/M was the contingency measure selected for implementation. 
Adopted August 20th, 2010

III.A.2-5

2.1.2 Fairbanks North Star Borough Carbon Monoxide Maintenance Area

The urban portion of the FNSB was designated in 1990 as a “moderate” nonattainment 

area for CO under the CAA (See Figure III.A.2-2). On March 30, 1998, the FNSB was 

reclassified as a “serious” nonattainment area for failing to attain the ambient eight-hour 

CO NAAQS by the December 31, 1995 deadline mandated for moderate CO 

nonattainment areas. As a serious nonattainment area, the FNSB was required to prepare 

a CO attainment plan as a SIP revision that demonstrated attainment by December 31, 

2000. Since violations of the ambient CO NAAQS were recorded in calendar year 1999

(see Table III.A.2-1), and 24 months of clean data are required to demonstrate attainment, 

it was not possible for the FNSB to prepare a SIP revision that satisfied this requirement. 

Figure III.A.2-2 Fairbanks North Star Borough Carbon Monoxide Maintenance Area. 
Adopted August 20th, 2010

III.A.2-6

In March 2001, the FNSB and ADEC submitted a formal request to EPA for an extension 

of the attainment date to December 31, 2001. The FNSB and ADEC submitted a new CO 

attainment plan on August 30, 2001, and EPA approved the plan on February 4, 2002 (67 

FR 5064). On July 5, 2002 EPA announced that the Fairbanks serious CO nonattainment

area attained the NAAQS for CO by its attainment date of December 31, 2001. On June 

21, 2004, ADEC submitted a CO maintenance plan for the FNSB CO nonattainment area 

to EPA for approval. On July 27, 2004, EPA announced that it was approving the FNSB 

CO Maintenance Plan and redesignating the FNSB CO nonattainment area to attainment 

with an effective date of September 27, 2004 (69 FR 44601). The complete FNSB CO 

Maintenance Plan is found in Volume II, Section III.C of Alaska’s SIP. 

The approved FNSB CO Maintenance Plan demonstrated continued attainment of the CO 

standard in Fairbanks between 2005 and 2015. The key to the success of the plan was an 

on-going, integrated planning process that allows for local participation and coordination 

among governmental agencies. The plan’s goals and objectives focused on 

enhancements to the existing vehicle I/M program, including technical improvements 

through the Alaska2000 equipment upgrades, support of ADEC enforcement efforts, 

implementation of onboard diagnostic checks, electrical plug-ins to facilitate the use of 

block heaters for employee parking spaces and public awareness campaigns to boost 

transit rider ship. Contigency measures were focused on expanded transit operations, 

increasing the number of parking spaces equipped with electrical plug-in units and road 

system improvements. Ordinance No. 91-044 (October 1991) requires the FNSB to issue 

twice-daily CO forecasts during the months of November through February.

Subsequent to the approval of the FNSB CO Maintenace Plan in 2004, the FNSB

Assembly determined that the I/M Program was no longer necessary for continued 

maintenance of the CO NAAQS and therefore decided to suspend the program after

December 31, 2009. Recognizing the I/M Program is one of the primary control 

measures, the CO maintenance plan was revised to include an updated emissions forecast, 

a demonstration of attainment without the I/M Program through 2015, a new conformity 

budget and a request for EPA approval to shift the I/M Program from an active measure 

to a contingency measure. ADEC adopted the revised FNSB CO Maintenance Plan on 

April 4, 2008. The State of Alaska retains its regulatory authority to re-establish the local 

I/M programs under 18 AAC 52.007. In the event that the FNSB CO maintenance area 

violates the CO NAAQS in the future, ADEC would work with the FNSB to restart their 

I/M program if the violations were found to be related to vehicular traffic and I/M was 

the contingency measure selected for implementation. The FNSB I/M program was 

suspended on January 1, 2010. 3

 

3: See SIP Volume II, Section III.C. “Fairbanks Transportation Control Program”, Adopted by 

the State of Alaska, April 4, 2008.
Adopted August 20th, 2010

III.A.2-7

A.2.2 Alaska’s Carbon Monoxide Control Agencies & Responsibilities

This section describes the role of ADEC, MOA and the FNSB in implementing programs 

that reduce CO emissions and includes a chronological history of Alaska’s State 

Implemenation Plan (SIP) submissions pertaining to its CO Maintenance Areas. This 

section also briefly describes the role of the EPA, Alaska Department of Transportation 

& Public Facilities (ADOT/PF) and the Federal Highway Administration (FHWA) in 

assisting the two CO maintenance areas in achieving and maintaining the CO NAAQS. 

2.2.1 Department of Environmental Conservation 

ADEC is the primary agency responsible for air quality control in Alaska. ADEC’s CO 

control strategy in Alaska is a multifaceted approach consisting of public participation, 

statute and regulation development, CO control program development, CO monitoring, 

compliance and enforcement. ADEC provides technical and resource assistance to the 

MOA and FNSB and ensures that statewide air quality priorities and financing are 

accomplished in a rational and cost-effective manner. In carrying out these functions 

ADEC is responsible for the following: 

• Advising and assisting Anchorage and Fairbanks Metropolitan Planning 

Organization (MPOs) in development of air quality control plans and 

transportation improvement programs;

• Maintaining active participation in the Anchorage Metropolitan Area 

Transportation Study (AMATS) and Fairbanks Metropolitan Area Transportation 

Study (FMATS) Air Quality Technical and Policy Committees, which are set up 

as a supplemental part of the transportation planning process;

• Providing technical assistance and air quality evaluations of proposed 

transportation projects, programs and plans. This is provided on an as needed 

basis to the Alaska Department of Transportation and Public Facilities 

(ADOT/PF) for the Anchorage and Fairbanks CO maintenance areas and through 

regular participation in the interagency consultation process required under 

transportation conformity regulations;

• Annually coordinating, reviewing and making recommendations to the 

appropriate agencies concerning air quality control efforts for the coming year, 

including placing a priority on available funds; and

• Writing, implementing and enforcing new air quality control statutes and 

regulations.

ADEC is required to submit SIP revisions to EPA for approval each time the State of 

Alaska adopts a new air quality regulation, statute, or other modification that affects its 

SIP. These approvals are codified in the Code of Federal Regulations and serve as a 

permanent, enforceable record of approvals to Alaska’s SIP. 
Adopted August 20th, 2010

III.A.2-8

A dated record of SIP milestones and amendments pertaining to the MOA and FNSB CO 

Maintenance Plans is provided in Table III.A.2-2.

Table III.A.2-2. Statewide Carbon Monoxide Control Program SIP Milestones, 

Amendments and Adoption Dates.

CO SIP Milestones & Amendments Date of Action or 

State Adoption

Proposal of draft I/M regulations 04/12/93

Public hearings on draft I/M regulations: Anchorage

 Palmer

 Fairbanks

 05/17/93

05/18/93

 05/19/93

Adoption of I/M regulations by emergency order. 01/21/94

Effective date of I/M regulations. 02/01/94

Permanent adoption of I/M regulations. 03/24/94

Begin certifying BAR-90 stations and mechanics. 02/01/94

Begin mandatory BAR-90 testing for all subject vehicles. 03/01/94

Full stringency cutpoints in effect. 03/01/94

Issuance of final BAR-90 specifications and procedures. 04/15/94

Submittal of I/M SIP to EPA. 07/11/94

First biennial report due to EPA. 07/01/97

Begin biennial test frequency. 01/01/97

Begin I/M credits test program. 01/06/97

Complete I/M credits test program. 06/07/97

Introduce Alaska2000 EIS I/M Program. 06/07/97

OBD II & Oxyfuel Fee. 12/30/00

Implement On Board Diagnostic Testing. 07/01/01

Fairbanks Serious CO SIP. 09/21/01

Anchorage Serious CO SIP. 01/27/02

I/M Update (2002). 03/27/02

Anchorage CO Maintenance Plan (2004). 02/20/04

Fairbanks CO Maintenance Plan (2004). 06/24/04

I/M program flexibility updates. 09/19/06

I/M Suspension & Reestablishment Requirements. 04/04/08

Fairbanks North Star Borough I/M Program Suspension. 04/04/08

Municipality of Anchorage I/M Program Exemptions. 08/05/09

Municipality of Anchorage I/M Program Suspension. 08/20/10
Adopted August 20th, 2010

III.A.2-9

2.2.2 Municipality of Anchorage

The MOA includes the following agencies that participate in air quality and 

transportation related activities: 

• Department of Community Planning and Development is responsible for 

transportation planning and implementation; 

• Transit Department, operates Anchorage's "People Mover" public transit system 

and the Anchorage Rideshare program; 

• Department of Health and Human Services is responsible for air quality planning 

and air pollution control in Anchorage, including the operation of the Anchorage 

Vehicle Inspection Program; and 

• Anchorage Metropolitan Area Transportation Study (AMATS) planning group is 

the lead agency responsible for coordinating and complying with the 3C 

transportation planning process required under federal regulation. 

MOA is the lead governmental agency for carrying out the Anchorage Air Quality 

Control Plan and is responsible for the following:

• Developing, adopting and submitting an approvable air quality control plan to 

ADEC that demonstrates attainment and maintenance of the NAAQS for carbon 

monoxide. MOA is also responsible for implementing the local control measures 

included in the plan;

• Operating a motor vehicle I/M program that complies with state I/M regulations;

• Evaluating and implementing transportation planning activities to ensure the 

continued federal certification of the Anchorage Metropolitan Area 

Transportation Solutions;

• Conducting ambient air and meteorological monitoring to characterize carbon 

monoxide concentrations throughout the maintenance area;

• Conducting an annual review of the Anchorage Carbon Monoxide Control 

Program, based on new monitoring data and ongoing control efforts through the 

AMATS Air Quality Technical and Policy Committees;

• Participating in the interagency consultation process required under 

transportation conformity regulations; and

• Enforcing the carbon monoxide episode plan.

2.2.3 Fairbanks North Star Borough

The FNSB was designated by ADEC in 1978 as the lead air quality agency in the 

Fairbanks area. The FNSB has primary responsibility for carrying out an effective 

transportation control plan for the area. In accordance with this, its principal 

responsibilities are the following:

• Developing, adopting, and submitting an approvable air quality control plan to 

ADEC which demonstrates attainment and maintenance of the NAAQS for 

carbon monoxide; 
Adopted August 20th, 2010

III.A.2-10

• Iimplementing the local control measures included in the plan;

• Operating a motor vehicle I/M program that complies with state I/M regulations;

• Conducting ambient air and meteorological monitoring to characterize carbon 

monoxide concentrations throughout the maintenance area;

• Conducting an annual review of the Fairbanks Carbon Monoxide Control 

Program based on new monitoring data and ongoing control efforts;

• Participating in the interagency consultation process required under transportation 

conformity regulation; 

• Enforcing the carbon monoxide episode plan; and 

• Working with FMATS to ensure coordination between the air quality and 

transportation planning processes.

2.2.4 United States Environmental Protection Agency

The EPA has major responsibilities in reducing CO emissions in Anchorage and 

Fairbanks because of its direct involvement in the Federal Motor Vehicle Emission 

Control Program (FMVCP). In particular, EPA has the obligation to ensure that the 

federal motor vehicle control activities are effective in cold weather regions such as 

Alaska. It also must ensure that sufficient federal funding will be available to carry out 

evaluation studies and control actions required of the state. In carrying out its functions, 

EPA is responsible for the following:

• Establishing and enforcing requirements outlined in the 1990 CAAA for the 

Federal Motor Vehicle Control Program. The federal certification program 

requires all new cars sold in the 49 states (California has its own certification 

program) to meet certain emissions standards. While these standards vary 

according to vehicle age and type, new vehicles must generally meet more 

stringent emission standards than the older vehicles that they replace. This results 

in a decline over time in allowable emissions from newly manufactured vehicles, 

and thus a drop in overall emissions from the motor vehicle fleet as older, dirtier 

vehicles are replaced with newer, cleaner vehicles;

• Establishing and enforcing requirements for the cold temperature CO certification 

program for new motor vehicles, as described in Section III.A.2.3.1;

• Establishing and updating guidance on the structural requirements of the 

oxygenated fuels program;

• Working with the United States Department of Transportation (USDOT) to 

establish and amend conformity criteria as required by section 176(c) of the

CAAA (42 U.S.C. 7506(c);

• Ensuring that Alaska has access to available federal money for implementation of 

control strategies;

• Providing technical assistance as necessary; and

• Providing funding support for the needed local and state programs.
Adopted August 20th, 2010

III.A.2-11

2.2.5 Alaska Department of Transportation and Public Facilities (ADOT/PF)

ADOT/PF is a key agency in controlling carbon monoxide emissions in both Anchorage 

and Fairbanks because of its role in both communities' transportation planning and 

construction processes. ADOT/PF is represented on both the Policy and Technical 

committees of AMATS and FMATS. ADOT/PF responsibilities are the following:

• Providing technical assistance and support to AMATS and FMATS as needed;

• Participating in the air quality transportation planning process, through the Air 

Quality Technical and Policy Committees of AMATS and FMATS;

• Maintaining the Highway Performance Monitoring System (HPMS);

• Incorporating the latest and most accurate air quality data and analysis techniques 

into transportation project evaluations and in major corridor studies as soon as the 

information becomes available. Assistance and support is provided by ADEC in 

this effort;

• Participating in the interagency consultation process required under transportation 

conformity regulations; and

• Participating, through the air quality transportation planning process, in the 

allocation of Congestion Mitigation and Air Quality funding to projects that 

reduce carbon monoxide emissions in both Anchorage and Fairbanks.

2.2.6 Federal Highways Administration (FHWA)

The FHWA has the responsibility for ensuring that federally funded transportation 

planning and construction in Alaska will be compatible with air quality objectives and 

requirements. FHWA provides an important function in ensuring that air quality criteria 

are effectively carried out in these activities.

In particular, FHWA is responsible for annually reviewing the Unified Work Program in 

Anchorage with all involved agencies, to ensure that needed air quality activities are 

prioritized, funded and carried out. FHWA, along with the AMATS and FMATS 

planning groups in Anchorage and Fairbanks, is also responsible for ensuring that the 

long-term and short-term transportation activities that are federally funded will be 

compatible with air quality requirements. The overall objective of the conformity 

determinations is to ensure that the regional transportation plan for each community 

conforms to this SIP for all transportation projects. State conformity procedures 

applicable to transportation projects, plans and programs in MOA and FNSB are 

described in state regulations at 18 AAC 50.700-725.
Adopted August 20th, 2010

III.A.2-12

A.2.3 Alaska’s Carbon Monoxide Control Regulations & Programs

Alaska’s regulations pertaining to Emissions Inspection and Maintenance (I/M) 

Requirements for Motor Vehicles are found in Title 18 of Alaska Administrative Code 

(AAC) Chapter 52. Alaska’s I/M regulations have been implemented through a unique 

I/M program which has been tailored to meet Alaska’s cold winter temperatures and, 

therefore, a brief history of the development of Alaska’s I/M program is provided in 

Section 2.3.1. Section 2.3.2 describes Alaska’s Emissions Inspection and Maintenance 

Requirements for Motor Vehicles (I/M) program as originally approved by EPA in order 

to meet federal regulations found in 40 CFR 51, Subpart S. Section 2.3.3 describes 

Alaska’s now suspended Oxygenated Fuels Program, provides an evaluation of the

MOA’s discontinued Ethanol Program and describes health concerns related to the 

oxygenated fuels program. Alaska’s oxygenated fuels program was suspended in 2004. 

Alaska’s regulations necessary for implementing its oxygenated fuels program are found 

in 18 AAC 53 Fuel Requirements for Motor Vehicles

The implementation of Alaska’s I/M and oxygenated fuel regulations act as primary CO 

control and contingency measures. With the adoption of this SIP submittal and 

subsequent approval by EPA, MOA, like FNSB, will be suspending its I/M Program as a 

primary CO control measure and retaining the I/M program as a CO contingency measure 

in case of future violations of the CO NAAQS. The State of Alaska also retains the 

regulatory authority to re-establish the local I/M programs under 18 AAC 52.007. In the 

event that the MOA or FNSB CO maintenance areas violate the CO NAAQS in the future 

ADEC would work with the governing agencies to restart the I/M program if these 

violations were found to be related to vehicular traffic and I/M was the contingency 

measure selected for implementation. 

2.3.1 History of Alaska’s Vehicle Emissions Inspection & Maintenance Program

CO Cold Start Certification Program Development

ADEC, in cooperation with the MOA and the FNSB, has been very active in addressing 

the problem of cold-start emissions and helped secure adoption of the cold temperature 

CO vehicle certification program in the 1990 Clean Air Act Amendments. The 1970 

CAA stated that new vehicles must meet a 90% emission reduction criteria "when in 

actual use throughout their useful life,” in order to satisfy EPA certification requirements 

under the Federal Test Procedure (FTP), the laboratory test procedure used by EPA to 

certify new vehicles. EPA interpreted this to mean that the reduction must be met at 

ambient air temperatures of 68° F to 86° F. Thus, new vehicles were not required to 

achieve a stringent CO standard of 3.4 grams per mile (g/mi) below the 68°-86° F 

temperature range. In fact, they were allowed to emit substantially higher levels of CO at 

lower ambient temperatures. This is the primary reason less progress has been achieved 

in the control of emissions during cold weather than under the temperatures similar to 

those used during EPA's certification testing. Thus, Anchorage and Fairbanks, which 

exceed the NAAQS for CO during cold wintertime air stagnation episodes, received less 

benefit from EPA's vehicle certification program than warmer regions of the country.
Adopted August 20th, 2010

III.A.2-13

Several factors contribute to the fact that exceedances of the CO NAAQS typically occur 

at temperatures well below those employed in the FTP. During the FTP, vehicles are 

required to be driven over a standard driving cycle at standard test conditions, which is 

limited to the 68°-86° F temperature-range. Starting a cold vehicle requires excess fuel 

that cannot be completely burned, which results in higher levels of partially burned fuel 

(carbon monoxide) and unburned fuel (hydrocarbons). In addition, the conversion 

efficiency of a catalyst (the primary CO control technology used on late-model vehicles) 

is very low during the first few minutes of a vehicle's operation. Also, periods of low 

winds and atmospheric inversions often occur during low temperatures. Because vehicles 

account for roughly 90% of the CO emitted in urban areas, the lack of cold temperature 

CO control is the primary reason that the Alaska CO nonattainment areas continued to 

exceed the CO NAAQS throughout the 1980s and 1990s.

ADEC, in conjunction with the MOA and FNSB, devoted significant efforts during the 

1980s to directing EPA's and Congress’ attention to the issue of non-FTP (cold 

temperature) emissions. These efforts succeeded in getting non-FTP CO emissions 

addressed in the CAAA. As a result, CAAA section 202(j) (42 U.S.C. 7521 (j)) required 

EPA to promulgate regulations regarding CO emissions certification at 20° F, as well as 

under FTP conditions. Under EPA's final rulemaking on this program, emissions from 

light-duty vehicles may not exceed 10.0 g/mi CO at 20° F, and 3.4 g/mi under FTP 

conditions. (The relative difference in standards reflects the greater difficulty in 

controlling CO emissions under cold-temperature conditions, particularly during coldstart enrichment.) Light-duty trucks must meet a standard comparable in stringency to 

the cold CO standard for light-duty vehicles.

The above standards took effect beginning with the 1994 model year according to the 

following phase-in schedule:

• 40% of each manufacturer's sales volume of model year 1994 light-duty vehicles 

and light-duty trucks;

• 80% of each manufacturer's sales volume of model year 1995 light-duty vehicles 

and light-duty trucks; and

• 100% of each manufacturer's sales volume of model year 1996 and later lightduty vehicles and light-duty trucks. 

In addition, because six or more CO nonattainment areas remained nationwide as of June 

1, 1997, EPA was required, under the CAAA, to promulgate the Phase II cold CO 

standard of 3.4 g/mi for light-duty vehicles and 4.4 g/mi for light-duty trucks beginning 

with model year 2002 vehicles. However, as of June 2010, the Phase II cold CO standard

has yet to be implemented.

ADEC considers EPA's cold-temperature CO certification program an integral part of 

federal, state and local efforts to attain and maintain the NAAQS for CO in Anchorage 

and Fairbanks. However, the cold CO program provided relatively minor benefits in both 
Adopted August 20th, 2010

III.A.2-14

communities by the moderate attainment deadline of December 31, 1995, because the 

phase-in schedule for the CO standard resulted in an insignificant turnover in local fleets 

to cold temperature-controlled vehicles. However, program benefits will grow 

significantly as fleet turnover continues, thus providing additional emission reductions 

needed to help offset future growth in population and vehicle travel in Fairbanks and 

Anchorage. The first phase of the cold CO program provided significant benefits for the 

serious area CO control plans which had attainment deadlines of December 31, 2000 in 

Anchorage and December 31, 2001 in Fairbanks. As the fleet turnover continues, 

additional benefits will occur. However at some point in the future, no additional benefit 

will be seen as a result of the Phase I cold CO control program. ADEC considers the 

cold-temperature CO certification program to be the essential control strategy for 

ensuring long-term maintenance of the NAAQS for CO in the two communities.

Vehicle Emissions Inspection and Maintenance Improvements

In the early 1980s, ADEC was concerned about the effectiveness of motor vehicle 

emissions I/M program in reducing cold-start and cold temperature emissions. Therefore, 

ADEC, with EPA's support, conducted a test program in Fairbanks in the winter of 1982-

1983 to study this issue. ADEC and local communities used results from the test 

program to design I/M programs (subsequently implemented in Fairbanks and 

Anchorage) that would maximize the reduction of cold-start and cold temperature 

emissions.

In 1990, Section 187(a)(4) of the 1990 CAAA (42 U.S.C. 7512a (a)(4)) required 

moderate CO areas with existing I/M programs to upgrade the programs as necessary to 

be either no less stringent than that required by EPA prior to enactment of the CAAA or, 

if the SIP commitment was more stringent than EPA requirements, than that committed 

to in the SIP in effect at the time of enactment. Furthermore, section 182(a)(2)(B) (42 

U.S.C. 7511a(a)(2)(B)) required I/M programs already existing in 1990 in moderate 

areas to continue to meet a performance standard set by EPA for a "basic I/M program". 

In November 1992, EPA adopted federal I/M regulations applicable to all state and local 

I/M programs. The regulations specify a basic performance standard that the MOA and 

FNSB I/M programs had to meet. This performance standard requires all I/M programs 

to generate emission reductions that are equivalent to the benefits produced by a 

centralized inspection of all 1968 model year and later light-duty vehicles. Overall, the 

MOA and FNSB I/M programs are more effective than EPA’s basic program. In 

addition, the federal regulations contain specific requirements that have mandated 

numerous changes in I/M program design and administration for both FNSB and MOA.

The State’s I/M regulations (18 AAC 52) require the MOA's and FNSB's I/M programs 

to comply with the federal I/M regulations. However, ADEC considers some of the 

federal I/M provisions infeasible for Alaska. These provisions are highlighted in Table 

III.A.2-3 below, which compares the contents of the Alaska I/M programs to the federal 

regulations based on a January 1, 1996 evaluation. Data are presented to support 

ADEC’s position and an alternative to each requirement is presented whenever possible 
Adopted August 20th, 2010

III.A.2-15

throughout this section. In addition, 18 AAC 52 includes an I/M program for vehicles 

commuting into the MOA. The commuter I/M program began in February 1994 and will 

be discontinued upon the suspension of the MOA I/M program as a primary control 

measure. 

Table III.A.2-3 1996 Comparison of the FNSB and MOA I/M Programs

to EPA's "Basic Program" Parameters*

Parameter "Basic Program" FNSB MOA

Network Type Centralized Decentralized Decentralized

Start Date January 1, 1983 July 1, 1985 July 1, 1985

Test Frequency Annual Annual** Annual**

Model Year 

Coverage

MY 1968 and Newer MY 1975 and Newer MY 1968 and Newer

Vehicle Type 

Coverage

LDV Only LDGV, LDGT1, 

LDGT2, and HDGV

LDGV, LDGT1, 

LDGT2, and HDGV

Tailpipe Test Type Idle Only Idle/2500 rpm Idle/2500 rpm

Emission Standards 40 C.F.R. Part 85, 

Subpart W

Sliding scale/ 

Complies with 

minimum standards

Sliding scale/ 

Complies with 

minimum standards

Underhood 

Inspection

None Visual and 

Functional Checks 

of MY 1975+ 

Vehicles

Visual and 

Functional Checks 

of MY 1975+ 

Vehicles

Waiver Rate 0% 1% 1%

Compliance Rate 100% 96% 95%

MOBILE5a 

Estimate of 1996 

FNSB I/M Benefits

Composite CO 

emission factor = 

35.683 g/mi

Reduction in 

Emissions = 11.4%

Composite CO 

emission factor = 

33.740 g/mi***

Reduction in 

Emissions = 16.2%

n/a

MOBILE5a 

Estimate of 1996 

MOA I/M Benefits

Composite CO 

emission factor = 

30.960 g/mi

Reduction in 

Emissions = 11.2%

n/a Composite CO 

emission factor = 

29.752 g/mi***

Reduction in 

Emissions = 14.7% * Based on an evaluation date of January 1, 1996. ** Due to extremely low failure rates, all models are exempted from the first inspection cycle. *** Based on 85% of MOBILE5a test-only benefits.

Bills adopted during the 1995 and 1996 sessions of the Alaska State Legislature, 

mandated that all Alaska I/M programs implement biennial I/M testing beginning no later 

than January 1, 1997. As required, I/M program amendments in 1997 began a biennial 
Adopted August 20th, 2010

III.A.2-16

I/M testing schedule in all Alaska I/M programs and delayed the initial test on new 

vehicles until its second year. In 2006, additional amendments delayed new vehicle 

testing until the vehicle’s fourth model year. (e.g., the initial inspection for a 2004 

model-year vehicle begins in 2008 and every two years thereafter.) In 2009, amendments 

were submitted that delayed new vehicle testing until the vehicle’s sixth model year (e.g.,

initial inspection is after the third biennial registration cycle).

Beginning in 2000, the Alaska I/M programs switched to the Alaska2000 Emissions 

Inspection System (EIS) specifications from the BAR-90 Test Analyzer System 

specifications (TAS). The reasons for this changeover include maintenance problems 

with BAR-90 hardware and necessary “Year 2000” (Y2K) adjustments. In addition, by 

July 2001, all light-duty 1996 and newer model year vehicles were required to have 

onboard diagnostic (OBD) testing. Alaska2000 EIS hardware has OBD testing capability.

Refer to the appendix to section III.A for a copy of Alaska’s current I/M regulations (18 

AAC 52). These regulations include the State I/M Program Manual (consisting of the 

Alaska2000 Emissions Inspection System (EIS) specifications; Mechanic Training 

Course Requirements; General Information for Certified Mechanics; Inspection and 

Repair Procedures and Standards; and List of Approved Aftermarket Parts. Refer to 

Appendices III.B.5 and III.C.5, respectively, for MOA and FNSB I/M ordinances and 

I/M Program design documents.

2.3.2 Alaska’s Inspection & Maintenance Program Description

This section presents a detailed description of Alaska’s I/M program design elements as 

origianlly approved by EPA and as required by the federal I/M regulations found at 40 

C.F.R. Part 51, Subpart S. ADEC’s legal authority for implementating the requirements 

of 40 C.F.R. 51 is found in Alaska Statute (AS) 46.03 and 46.14 (see the appendix to 

Section II for copies of 46.03.760, 46.03.765, 46.03.780, 46.03.790, 46.14.030, 

46.14.400, 46.14.410, and 46.14.510). The legal authority does not contain any sunset 

provisions. Alaska’s current Emissions Inspection and Maintenance Requirements for 

Motor Vehicles (I/M) regulations are found in 18 AAC 52. 

40 C.F.R. 51.350 Applicability - The Alaska I/M program is divided into three separate 

programs, based on the designated implementing agency. The I/M programs in 

Anchorage and Fairbanks are locally implemented and operated with the MOA and the 

FNSB having legal and administrative responsibility for their respective programs. 

ADEC is responsible for administering an I/M program aimed at vehicles that commute 

into Anchorage for work or school until this program is discontinued upon the adoption 

and subsequent approval by EPA of this SIP submittal which suspends the MOA I/M 

program as a primary CO control measure. 

Both Anchorage and Fairbanks have been classified as CO maintenance areas since 

2004. The 1980 census population of each urbanized area was under 200,000, therefore,

neither community was required to implement an enhanced I/M program. Both areas

must continue to operate their existing programs and upgrade them as necessary to meet 
Adopted August 20th, 2010

III.A.2-17

EPA's basic I/M performance standard and other program requirements. The existing 

programs cover the entire MOA and the FNSB and thus meet the federal geographic 

coverage requirements. The state regulations for I/M programs are found in the 

Appendix to Section III.A. Local ordinances establishing I/M program requirements and 

boundaries for both MOA and FNSB are included in Appendices III.B.5 and III.C.1, 

respectively. 

AS 46.14.510(e), states “If the department adopts regulations requiring emissions 

inspection for a motor vehicle, the department may not require the vehicle be inspected 

more than once every two years”. State I/M regulations (18 AAC 52) include this 

biennial-testing requirement. The local ordinances and program design documents, 

contained in Appendices III.B.5 and III.C.5, reflect the required switch over to biennial 

testing. Local I/M ordinances adopted by the MOA and FNSB must conform to the state 

regulations; therefore, inclusion of the state regulations in Appendix III.A is sufficient to 

demonstrate legal authority for biennial testing.

The ADEC-administered commuter I/M program is not linked to a specific geographical 

area but is instead aimed at vehicles that are regularly operated in, but not registered in, 

the MOA I/M program area. Because of this, no specific geographical requirements 

apply to this program. The design document for the commuter I/M program is in the 

State I/M manual adopted by reference in 18 AAC 52.

40 C.F.R. 51.351 Enhanced I/M Performance Standard - Not applicable to Alaska.

40 C.F.R. 51.352 Basic I/M Performance Standard - Basic I/M programs must be 

equivalent (based on a 1996 analysis year) to a program that contains the following 

design features:

• centralized testing network;

• 1983 program startup date;

• annual testing of all 1968 and later light-duty vehicles;

• idle test required;

• emission standards as stringent as specified in federal regulation;

• no under-hood inspections required;

• 20% failure rate for pre-1981 model year vehicles;

• 0% waiver rate; and

• 100% compliance rate.

Alaska’s I/M regulations (18 AAC 52.035(d)) require local I/M programs in Alaska to 

meet the federal I/M basic performance standard. As of the 1996 evaluation year, the 

MOA and FNSB I/M programs, described in Sections III.B.5 and III.C.5 respectively, 

met the federal I/M basic performance standards. Copies of the MOBILE5a input and 

output files supporting these determinations are included in the appendix to III.A. A

summary of the features of the two I/M programs and the MOBILE5a modeling results 

for each program (based on a January 1, 1996 evaluation date) are included in Table 
Adopted August 20th, 2010

III.A.2-18

III.A.2-3. The Anchorage commuter I/M program had the same design features as shown 

in Table III.A.2-3 for the MOA I/M program.

A one-time evaluation date of calendar year 1996, as specified in 40 C.F.R. 51.352, was 

used to demonstrate compliance with the I/M basic performance standard when the CO

areas were in nonattainment. EPA I/M staff in Ann Arbor, Michigan directed ADEC to 

use a January 1, 1996, MOBILE5a evaluation date for comparison with the performance 

standard.

4 The modeling results summarized in Table III.A.2-3 reflect the annual 

inspection frequency that was in place in both the MOA and FNSB on January 1, 1996.

Detailed descriptions of the current features of each I/M program are contained in the 

Anchorage I/M Ordinance found in Appendix III.B.5; and the FNSB Alaska 2000 Motor 

Vehicle Inspection and Maintenance Program Handbook found in Appendix III.C.5.

40 C.F.R. 51.353 Network Type and Program Evaluation - All three Alaska I/M 

programs operated on a decentralized test-and-repair basis. For the 1996 evaluation 

presented in Table III.A.2-3, based on ADEC’s “good faith estimate” of emissions 

reductions at that time, ADEC originally assumed an 85% credit in its MOBILE5a

analysis. At that time, the state recognized that this credit request was probably 

conservative and that, based on their design and data, the Alaska I/M programs could 

justifiably request greater credit. In November 1998, ADEC submitted a qualitative 

evaluation of the I/M programs to EPA.5 In addition, major revisions made to the I/M 

program between 1998 and 2001had increased their effectiveness. For this reason, 

ADEC claimed that the Alaska I/M test and repair programs were 100% as effective as a 

test-only program. The FNSB CO attainment plan claimed 100% credit for a test-only 

program as demonstrated by the data. However, in the MOA CO attainment plan,

analysis continues to rely on an 85% credit. This conservative approach provided a extra 

margin of safety in their emission estimates and is not a reflection of a less stringent I/M 

program.

40 C.F.R. 51.354 Adequate Tools and Resources- With this SIP submittal and 

subsequent approval from EPA, MOA will suspend the I/M Program as a primary CO 

control measure and retain the I/M program as a CO contingency measure in case of 

future violations of the CO NAAQS. The State of Alaska also retains the regulatory 

authority to reestablish the I/M program under 18 AAC 52.007 in the event that the MOA 

or FNSB CO maintenance areas violate the CO NAAQS in the future. 

In the event that either the MOA or FNSB CO Maintenance Areas violate the CO 

NAAQS in the future and the I/M program is selected as the contingency measure for 

implementation, MOA, FNSB and the State commit to providing the necessary 

administrative, personnel, and equipment resources to fully re-start, implement and 

 

4: Personal communication with David Sosnowski, United States Environmental Protection 

Agency, October 3, 1995.

5: ”Alaska ECOS/STAPPA/EPA I/M Credit Evaluation Data Submittal”, ADEC , November 

1998.
Adopted August 20th, 2010

III.A.2-19

maintain the Alaska I/M program. The federal performance standard will be met or 

exceeded by all Alaska I/M programs by implementing all provisions of the CAA and 40 

C.F.R. 51, Subpart S applicable to Alaska. These include vehicle coverage, test 

frequency, test equipment and procedures, program enforcement, quality assurance and 

quality control procedures, data analysis, training, and public information. In the event 

that the local I/M programs are restarted they will be carried out under state oversight 

with some components being completed by local government personnel and some being 

performed by one or more contractors. In addition, the state will continue to provide 

added oversight of the local I/M programs to ensure that they are operated in accordance 

with 18 AAC 52 and 40 C.F.R. 51, Subpart S.

In the event that either MOA or FNSB is unable or unwilling in the future to provide 

adequate tools or resources, ADEC commits to ensuring that all necessary administrative, 

personnel, and equipment resources are provided to fully restart, implement and maintain 

the Alaska I/M program. 

Under the authority of 18 AAC 52.030(a)(2), ADEC will, in its discretion, take over the 

administration of a local I/M program if the local implementing agency is found to be 

administering an inadequate program.

All necessary program financing for each of the Alaska I/M programs is provided by I/M 

test fees assessed on each vehicle that passes an I/M test. The fee schedule for ADECadministered programs is described at 18 AAC 52.020(f). When the I/M programs 

shifted from annual to biennial inspection in January 1997, the fee for a certificate of 

inspection increased from 10 dollars to 20 dollars. Based on past I/M program 

performance, it is the position of MOA, FNSB and ADEC that this financing mechanism 

will ensure adequate financing of the I/M programs in the future.

A discussion of adequate resources for the local MOA and FNSB I/M programs is 

included in appendices III.B.9 and III.C.9. Copies of the annual operating budgets and 

staffing levels for the MOA and FNSB I/M programs from 1994, which demonstrate 

adequate funding and personnel to properly administer the programs, are included in 

Appendices III.B.11 and III.C.11. 

MOA, FNSB, and ADEC will work with their respective legislative bodies to budget for 

adequate equipment resources to achieve I/M program objectives and meet all I/M 

program requirements. 

The MOA and FNSB referee facilities provided multi-functional services for their 

respective programs. MOA contracts with a private contractor for its referee facility 

while the FNSB referee facility was operated by FNSB staff. Services provided by the 

two facilities include public motorist and mechanic information and assistance, mechanic 

training and certification testing and referee functions. These facilities are equipped with 

at least one certified Alaska2000 Emissions Inspection System (EIS) and other diagnostic 

and repair equipment which are used for referee inspections, verification of waiver 
Adopted August 20th, 2010

III.A.2-20

requests, setting up and testing covert and overt vehicles and other related functions. The 

referee facilities maintain inventories of calibration gases and audit equipment and gases.

Data collection and processing are major elements of the Alaska2000 I/M testing 

program. Alaska2000 analyzers uses a centralized host system called a Vehicle 

Information Database (VID) and an electronic transfer (ET) system that allow the transfer 

of data from the VID to the EIS and from the EIS to the VID. Near the beginning of an 

Alaska2000 I/M test, the EIS electronically calls the VID to download the vehicle 

information and system parameters. At the end of the test, the EIS software 

automatically transfers (uploads) the results back to the VID with a second call.

The VID can also be used for a number of other actions including the remote lockout of 

an EIS, the transmittal of messages to one or more EIS and data analysis related to 

enforcement actions. A sophisticated I/M management software program performs many 

of the quality assurance/quality control (QA/QC), data analysis, reporting and 

enforcement functions required under 40 C.F.R. 51 and 18 AAC 52. Security and levelof- access controls are used to prevent tampering and loss of data.

Privately owned vehicles are obtained on an as-needed basis from the public for covert or 

overt performance audits. Adequate numbers of vehicles are used to prevent recognition 

by station mechanics and to maintain an I/M test fleet that is representative of the 

community’s vehicle mix. 

40 C.F.R. 51.355 Test Frequency and Convenience –All regulated vehicles within the 

Alaska I/M program areas were subjected to an annual I/M test until January 1, 1997. 

The MOA exempted all new vehicles subject to the program from their first annual 

inspection, due to the extremely low failure rate that new models experience during the 

first inspection cycle. As noted above, biennial testing for Alaska I/M Programs began on 

January 1, 1997. Beginning with model-year 2004, new vehicles were exempt from 

testing until expiration of the vehicle’s second registration.. (For example, the initial 

inspection year for a 2004 model year is due no more than four years after its initial 

registration as a new vehicle.). Beginning with model-year 2006, new vehicles are 

exempt from testing until the current calendar year equals the vehicle model year plus six

years; subsequent inspections are due every two years after the year the vehicle’s first 

inspection is due.

Test frequency for the MOA and FNSB I/M programs is enforced via the State of Alaska 

motor vehicle registration process. The vehicle registration database maintained by the 

Alaska Division of Motor Vehicles (DMV) includes a field that indicates whether each 

individual vehicle is subject to an I/M program. If a vehicle is listed as subject to I/M 

testing, a valid Certificate of Inspection must be submitted along with the vehicle's 

registration notice before the vehicle can be re-registered. To be valid, a Certificate of 

Inspection must have an inspection date within the 90-day period before the registration 

date. DMV usually receives Certificate of Inspection information electronically within 

24 hours of testing. This system allows motorists to register by mail, telephone or over 

the Internet.
Adopted August 20th, 2010

III.A.2-21

For the commuter I/M program, only those vehicles that commute (to work or school) 

into the MOA from areas outside of the municipal boundaries must be inspected. This 

program, therefore, is not linked to the DMV registration process. Instead, commuter 

vehicles subject to the I/M program are identified through searches of several confidential 

databases. The owners of vehicles identified in this manner are notified by ADEC of the 

requirement to obtain an inspection. Database tracking procedures implemented by 

ADEC track vehicles to ensure that they are brought in for I/M testing after notification 

and that they are renotified when a reinspection is required. A Certificate of Inspection 

issued to such a vehicle is not submitted to DMV upon registration, but must instead be 

kept in the vehicle with the vehicle registration. 

ADEC acknowledges that it may be more difficult to maximize compliance in the 

commuter I/M program, as compared to the MOA and FNSB I/M programs, due to the 

absence of any link to the vehicle registration process. ADEC believes that any 

significant level of compliance in the commuter I/M program increased the compliance 

rate for the I/M program overall. ADEC will maintain test requirements for the 

commuter program until it can be discontinued upon the adoption and subsequent 

approval of EPA of this SIP submittal, which suspends the MOA I/M program as a 

primary CO control measure.

Beginning in early 2000, under the Alaska2000 program, vehicles that either passed the 

I/M test or obtained a waiver received a windshield sticker along with the paper 

Certificate of Inspection. In 2005, vehicles began only receiving windshied stickers. The 

windshield sticker serves as either the vehicle’s Certificate of Inspection or proof of 

inspection or maintenance exemption eligibility. Because a windshield sticker provides 

immediate visual evidence that a vehicle has met the requirements of the I/M program it 

strengthens I/M program enforcement and compliance objectives.

40 C.F.R. 51.356 Vehicle Coverage - Except as provided in 18 AAC 52 (Appendix to

III.A) or the local I/M program design documents (Appendices III.B.5 for Anchorage and 

III.C.5 for Fairbanks), all light-duty gasoline vehicles (LDGVs), light-duty and mediumduty gasoline trucks (LDGT1s and LDGT2s), and heavy-duty gasoline vehicles 

(HDGVs) lighter than 12,001 pounds unladen weight, that are principally located or 

operated in either the MOA or FNSB, are subject to I/M testing. In the MOA, all 1968 

and newer models are subject to the program, while 1975 and newer models are subject 

to the FNSB program. Any 1968 or newer model used to commute into the MOA is 

subject to I/M testing as well. Visual and functional inspections are performed on only 

1975 and later models in all three I/M programs. Amendments to 18 AAC 52 in 2001

allow implementing agencies the option of eliminating the visual and functional 

inspections requirement from their local program manual for 1996 and later model year 

vehicles which undergo on-board diagnostic testing. Diesel-powered vehicles are not 

required to be I/M tested, but must be inspected upon initial registration and after changeof-ownership to confirm the existence of a diesel engine. The following classes of 

vehicles are exempted from the programs:

• a vehicle not principally located or operated in an I/M area;
Adopted August 20th, 2010

III.A.2-22

• a 1967 or older vehicle in the MOA;

• a 1974 or older vehicle in the FNSB;

• a new vehicle prior to its third registration;

• a gasoline-powered vehicle that is over 12,000 pounds unladen weight:

• a special test vehicle that has a State exemption;

• a military tactical vehicle;

• a motorcycle, golf cart, all-terrain vehicle, snow machine, and moped; 

• a vehicle in Alaska for less than 30 days; 

• an electric vehicle;

• a motor vehicle for which the Division of Motor Vehicles has issued historic 

vehicle plates for historic exhibition use; 

• a motor vehicle for which the Division of Motor Vehicles has issued custom 

collector plates; and

• a motor vehicle located in an I/M area that has had its I/M program suspended 

under 18 AAC 52.007.

Fleet vehicles are subject to the same program requirements and testing procedures as 

other vehicles. Fleets may self-test; however, such fleet testing facilities must meet the 

following requirements:

1. they must be certified as official I/M test stations;

2. they must use certified I/M mechanics to conduct all I/M tests;

3. all I/M tests and certificate issuance must be conducted using certified 

Alaska2000 EIS; and

4. they must comply with all other I/M program requirements. 

Vehicles registered in one I/M program area, but primarily operated in another I/M area, 

may obtain a certificate of inspection from any one of the three areas (MOA, FNSB or 

the Mat-Su Valley) in which official I/M stations are located. At the request of a vehicle 

owner or lessee, an official I/M test can be provided to a vehicle registered elsewhere. 

With the exception of tactical military vehicles, all vehicles operated on federal 

installations in an I/M area must be tested, and the installation must provide proof of 

compliance to the I/M implementing agency. (Procedures for ensuring such compliance 

are included in Appendices III.B and III.C.)

The I/M program design documents including 18 AAC 52, local ordinance and Fairbanks 

Handbook include a detailed description of the type of vehicles covered by the I/M 

programs, and a plan for how those vehicles are to be identified. The program design 

documents include descriptions of the special exemptions and waivers granted by the 

programs as well. 

The following information was developed as part of the 1996 comparison to the basic I/M 

program standards. The number of vehicles subject to the I/M programs in the MOA and 

FNSB were estimated in 1993 to be roughly 163,000 and 51,000, respectively. The

estimate for FNSB includes seasonally waived vehicles, as described below, since they 

are subject to the I/M program. The FNSB estimate does not, however, include 1968-
Adopted August 20th, 2010

III.A.2-23

1974 model year vehicles, since they are not currently subject to the I/M program. The 

MOA and FNSB totals are both based on 1993 I/M test records coupled with estimated 

compliance rates for each area. It is noted that these vehicle counts differ substantially 

from the number of vehicles for each area contained in the DMV vehicle registration 

database. (For example, the DMV database shows roughly double the number of I/Meligible vehicles for FNSB as the amount actually being I/M tested.) Large numbers of 

invalid entries in the DMV database are the suspected cause of this discrepancy, 

primarily due to vehicles that are maintained on the database for an extended period after 

not being re-registered. 

Estimates of the percentage and number of vehicles affected by the special exemptions in 

each I/M program are presented below. For the purpose of developing these estimates, 

only those vehicles were included that would be included pursuant to the basic I/M 

program parameters contained in 40 C.F.R. 51 (i.e., 1968 and newer gasoline-powered 

light-duty vehicles) but which are exempted by 18 AAC 52 or local ordinance. For 

example, diesel vehicles are not listed as exempt (although they are exempted from I/M 

testing requirements), since they are not included in EPA's basic I/M program. Based on 

this methodology, the number of vehicles estimated to have received exemptions in 1995 

are as follows:

Type of Exemption MOA Total FNSB Total

1968-1974 models -0- 6,000

Seasonal exemption -0- 4,000

The exemption of pre-1975 models has been incorporated into the 1996 FNSB 

MOBILE5a runs for comparison to the basic I/M performance standard. As noted above, 

this estimate of 6,000 vehicles would be in addition to the 51,000 vehicles estimated to be 

subject to the FNSB I/M program. The vehicles obtaining seasonal exemptions are 

subject to the program; however, they are prohibited from being driven during the winter 

CO season. For this reason, they are assumed to not operate during the CO inventory and 

nonattainment period; thus, no discounting of those vehicles has been incorporated into 

the 1996 MOA or FNSB MOBILE5a runs. The seasonal waiver program began in MOA 

in 1995. Therefore, an estimate of the number of vehicles that would be exempted each 

year was not included in the 1996 comparison to the basic I/M performance standard 

since it was not available at that time. It is also noted that several categories of vehicles 

(i.e., LDGT1s, LDGT2s and HDGVs) not subject to the basic performance standard have 

been included in both the MOA and FNSB I/M programs.

In addition to the vehicle registration counts for MOA and FNSB, there are a number of 

vehicles that are registered outside the program areas but are primarily operated within 

them. Out-of-area commuter vehicles have been previously estimated by ADEC at 

between 3,900 and 7,400 in MOA. These vehicles are now subject to the commuter I/M 

Program.

MOA also estimated previously that an additional 5,000 vehicles were being used in the 

MOA but were illegally registered outside of the area, in order to evade I/M program 
Adopted August 20th, 2010

III.A.2-24

requirements. Increased enforcement efforts by the MOA has reduced the number of 

program evaders. The total number of noncomplying vehicles in the MOA is estimated 

at roughly 8,000 (5%). A 95% compliance rate was conservatively estimated for the 

1996 MOA MOBILE5a runs.

In Fairbanks, a much lower number of out-of-area commuter and program evader 

vehicles is estimated, due to the absence of a significant center of population within 

reasonable daily driving distance of the FNSB. Increased enforcement efforts by FNSB 

and the State are expected to reduce this number even further. A conservative estimate of 

2,000 noncomplying vehicles (equivalent to a compliance rate of 96%) was assumed for 

the 1996 FNSB MOBILE5a runs.

As of September 2001, the following updated information is available with regards to 

vehicle coverage, exemptions, and waivers. Vehicle coverage remained essentially the 

same as in 1996. Table III.A.2-4 presents the estimated number of vehicles subject to the 

I/M programs in the MOA, Mat-Su Valley, and FNSB along with the number of vehicles 

that are seasonally exempted, an estimate of the number of evaders, and the compliance 

rate. 

Table A.2-4 I/M Program Coverage 2000-2001

MOA FNSB

Estimated Number of Vehicles 

Subject to the Program

163,000 51,000

Estimated Number of Seasonal 

Exemptions

6,908 6,674

Estimated Number of Evaders 8,000 2,000

Estimated Compliance Rate 90% 93%

The estimated number of vehicles subject to the I/M programs is based on the 1993 

estimates discussed previously. The estimated number of seasonal waivers for the MOA 

is based on the 18-month period from January 2000 through July 2001, which had 5,181 

seasonal waivers. By assuming that this is only three-quarters of the total number of 

seasonal waivers, the total estimate came to 6,908 vehicles. The estimated number of 

seasonal waivers for the FNSB is based on the 16 month period from April 2000 through 

July 2001, which had 4,449 seasonal waivers. By assuming that this is only two-thirds of 

the total number of seasonal waivers, the total estimate came to 6,674 vehicles. 

The estimated number of evaders for each program is based on the estimates used in the 

1996 comparison to the basic I/M performance standard. The 2001 compliance rate for 

Fairbanks and Anchorage are lower than in previous SIP submittals. In 1995, ADEC

began to conduct license plate surveys of local parking lots to track the I/M compliance 

rate of vehicles being operated in Fairbanks. Based on the survey results, the 2001 
Adopted August 20th, 2010

III.A.2-25

compliance rate for FNSB is estimated to be 93% and for MOA is 90%, as shown in the 

table. 6

Comparing this 2001 value to the 95-96% rates that have historically been used in 

developing SIP-related emissions inventories for the area shows an apparent 3-5% 

decrease in the compliance rate since the previous SIP revision in 1996. This is 

inconsistent with the improvements in vehicle enforcement, which is most likely due to 

an inaccuracy in the previous estimate. The 95-96% rate was originally developed more 

than 10 years ago, and was not rechecked until the initiation of the above surveys. It is 

therefore considered likely that the I/M compliance rate actually declined over the last 

decade, a trend that was reversed due to the recent increase in vehicle enforcementrelated efforts. It is also expected that increased enforcement efforts will produce further 

improvement in the future compliance rate.

Since 2001, regulation and SIP revisions have resulted in exemptions for new vehicles for 

the first six years. In 2010, the FNSB I/M program was suspended following EPA 

approval of a revised CO maintenance plan.

40 C.F.R. 51.357 Test Procedures and Standards - Written test procedures (using a 2-

speed idle test) and pass/fail standards that must be followed for all vehicles have been 

established for each of the I/M programs. State I/M regulations (18 AAC 52), local I/M 

ordinances and State and local program design documents include requirements related 

to this effort. 

18 AAC 52 does not require certified I/M stations to allow the motorist to have access to 

the test area to observe the entire I/M test. The federal requirement for access to the test 

area appears focussed on a centralized test-only environment where adequate space and 

safety requirements can be maintained. ADEC's position is that imposing such a 

requirement on Alaska’s test-and-repair stations could affect test station insurance 

requirements/rates and exposes the state to unacceptable liability issues. However, the 

Alaska I/M programs work cooperatively with the certified stations to ensure that 

motorists are given adequate opportunity, if desired, to observe I/M testing. In addition, 

18 AAC 52 requires certified stations to fully inform motorists regarding the cost of the 

I/M test and the services to be provided in the test. 

18 AAC 52 and each of the program design documents require that an official test, once 

initiated, be performed in its entirety, except in the case of invalid test conditions or 

unsafe conditions. This requirement is reinforced by the test procedures and EIS 

software logic required to be used in all Alaska I/M programs. Unsafe vehicles, 

including vehicles with leaking exhaust systems, must be rejected from testing, and 

vehicles must be completely retested after repairs are performed. 

 6: FNSB 1995-1999 Winter Parking Lot Sweep Summaries, provided by Joan Kassel, Alaska 

Department of Environmental Conservation, February 18, 2000. 
Adopted August 20th, 2010

III.A.2-26

The Alaska2000 EIS specifications, included in each of the local program design 

documents, incorporate the quality procedures contained in 40 C.F.R. 51, Appendix A, 

and the test procedures specified in 40 C.F.R. 51, Appendix B. All vehicles are subject to 

the hydrocarbon (HC) and CO emission cutpoints as set forth in 18 AAC 52.050. Repairs 

must be made if a vehicle fails any of these cutpoints. The cutpoints contained in 

18 AAC 52.050 vary by model year, vehicle type, and number of cylinders. As a result, 

some of the 1981 and newer LDGVs, LDGT1s, and LDGT2s have emission cutpoints in 

excess of 220 ppm and 1.2 percent CO. The 220 ppm HC cutpoints do not take effect for 

all vehicles until the 1994 model year. Some post-1980 LDGVs, LDGT1s, and LDGT2s 

(those equipped either with no catalyst or with oxidation catalysts, as opposed to those 

equipped with three-way catalysts) have to meet a less stringent CO cutpoint than 1.2 

percent. Cutpoints as strict as the federal 1.2 percent CO warranty limit do not take effect 

for all LDGVs, LDGT1s and LDGT2s models until the 1984 model year.

Beginning with the 1994 model year, 18 AAC 52.050 includes a 0.5% CO cutpoint for 

LDGV and LDGT models covered by the I/M programs. This standard is more stringent 

than the federal warranty limit of 1.2% CO. ADEC's position is that the overall benefits 

of the cutpoints contained in 18 AAC 52.050 meet those that would be achieved using the 

prescribed federal warranty limits of 1.2% CO and 220 ppm HC for all 1981 and later 

models. ADEC is aware of the warranty implications of having a CO cutpoint more 

stringent than the federal warranty coverage limit of 1.2%. The Alaska I/M programs 

have maintained a CO cutpoint of 1.0% for several years with minimal warranty issues.

Emission control devices that are neither original equipment manufactured (OEM) nor 

approved aftermarket parts are cause for underhood failures. Vehicles with replacement 

engines are subject to emission standards for the chassis type and model year, including 

visual inspection for all parts in the original certified configuration. 18 AAC 52 also 

requires the resulting engine-chassis configuration to have been certified by either EPA 

or the California Air Resources Board (CARB) as having the same or lower emissions as 

the engine-chassis configuration originally installed in the vehicle. Vehicles that have 

been switched from an engine of one fuel type to another fuel type subject to the program 

(e.g., from a diesel engine to a gasoline engine) must meet the standards for the current 

fuel type. 

40 C.F.R. 51.358 Test Equipment – A computerized EIS meeting the specifications 

contained in the program manuals (in Appendices III.A, III.B.5, and III.C.5) is required 

for all emissions measurements. To be certified for use in Alaska, each EIS is required 

by 18 AAC 52 to meet Alaska2000 equipment specifications that comply with those 

listed in 40 C.F.R. 51, Appendix D. Test equipment must be capable of testing all subject 

vehicles. The manufacturers of analyzers certified for use in Alaska must update the EIS 

from time to time, as requested by the State, to accommodate new technology vehicles 

and program changes. 

The EIS are automated to the highest degree commercially available to minimize the 

potential for intentional fraud or human error. Detailed requirements that meet or exceed 

those listed in 40 C.F.R. 51.358 and 40 C.F.R. Part 85, Subpart W, must also be followed 
Adopted August 20th, 2010

III.A.2-27

in issuing a Vehicle Inspection Report (VIR) to each vehicle owner or motorist who has a 

vehicle I/M tested. The EIS must meet specified functional characteristics that meet or 

exceed those listed in 40 C.F.R. 51.358. Written acceptance criteria and procedures for 

certifying an EIS for use in Alaska are included by reference in the Alaska2000 EIS 

specifications. 

40 C.F.R. 51.359 Quality Control - Each EIS must incorporate detailed quality control 

procedures as specified in the Alaska2000 EIS specification. These procedures are very 

similar, but not identical, to those contained in 40 C.F.R. 51, Appendix A. Alaska 

adopted the following exceptions to the federal quality control procedures:

1. Less frequent calibration requirements - Table III.A.2-5 shows the frequency 

requirements for mandatory emission measurement equipment gas calibrations and 

leak checks contained in 40 C.F.R. 51, Appendix A. In addition, EPA may also 

approve alternate procedures or calibration frequencies under 40 C.F.R. 51.359(a)(1) 

upon a demonstration of equivalent performance. 

Table III.A.2-5

Federal Requirements for Gas Calibrations and Leak Checks

Federal Requirement

Low-Volume Stations

(<4,000 tests/yr.)

High-Volume Stations

(>4,000 tests/yr.)

Leak check within 24 hours before a 

test

within 4 hours

before a test

2-point gas calibration within 72 hours before 

each test

once a day

within 4 hours before the 

test

Multipoint gas calibration every 6 months Monthly

The frequency requirements for gas calibrations and leak checks contained in the 

Alaska2000 EIS are identical to those contained in the California BAR-90 TAS 

specifications. Under these specifications, mandatory 2-point gas calibrations and 

leak checks must be performed within 72 hours of the last gas calibration and leak 

check, or the system is locked out from further testing until the calibration is 

completed. Unlike the federal specification, this requirement is the same regardless 

of the number of inspections performed at the station. In addition, no multi-point 

calibration requirements are programmed into either the California or the Alaska2000 

EIS software. However, the Alaska2000 EIS specifications for allowable tolerance 

limits are identical to those specified in 40 C.F.R. 51 for the multi-point calibrations.
Adopted August 20th, 2010

III.A.2-28

ADEC believes that the more frequent schedule of gas calibrations and leak checks 

contained in 40 C.F.R. 51 is not needed to maintain acceptable accuracy in emissions 

measurements made by the Alaska2000 EIS. This position is based on the following 

factors:

• Review of emissions measurement equipment records - Available FNSB data for 

the period from 7/1/92 to 6/30/93 were analyzed to determine if there were any 

inspection stations in FNSB that would be considered high-volume stations under 

the federal criteria. One certified station conducted 10,996 tests during the yearlong analysis period. However, tests at the station were performed using seven 

different measurement machines. The most tests run on a single machine during 

the year were 2,227, well below the 4,000-tests/year cutoff. No MOA data were 

available to perform a similar analysis, but anecdotal evidence, supplied by local 

I/M staff, indicate that all stations in MOA are most likely below the federal highvolume limit. Given this information and the small size of the Alaska programs, 

along with the 1997 implementation of a biennial test program which should 

reduce the per station test frequency even further, there was no need to include a 

more frequent calibration schedule for high-volume stations in Alaska.

• Discussions with emissions measurement equipment manufacturers—Based on 

informal discussions held between the state's representatives and the 

manufacturers, the manufacturers also supported the position that less frequent 

calibrations are required to maintain test integrity. They have indicated that they 

consider the more frequent federal requirements may be based on old data from 

outdated (BAR-84) emission analyzers.

• Multipoint calibrations - According to one manufacturer, the State of North 

Carolina required the manufacturers to include the federally-mandated multipoint 

calibration criteria in the measurement equipment designed for that state, but a 

high percentage of equipment has been failing the calibration. According to the 

manufacturer, the reason for these failures is that the equipment is required to 

meet an allowable tolerance range of +5% (based on combined tolerance limits of 

+3% for the TAS and +2% for the calibration gas) during the 2-point calibration. 

However, they are being required to meet a tolerance limit of +3% during the 

multipoint calibration. The problems experienced in meeting the calibration 

limits thus appear related to an interpretation of how the tolerance limits are 

calculated, and whether or not an additional +2% tolerance be allowed during the 

multipoint calibrations to account for the tolerance limits of the span gas.

• Absence of past problems - Alaska's experience with the BAR-90 TAS equipment 

since January 1994 has shown little problem with zero drift or other indicators of 

analyzer calibration problems. Alaska’s changeover to the Alaska2000 EIS 

equipment produced equal or superior results. Experience supports the position of 

the manufacturers that less frequent calibrations are required than contained in 

40 C.F.R. 51. 
Adopted August 20th, 2010

III.A.2-29

Due to these factors, ADEC incorporated the alternate calibration schedule (i.e., threeday, two-point calibrations and leak checks) in the Alaska BAR-90 TAS and will 

maintain this schedule under the Alaska2000 EIS specifications. The results of the FNSB 

TAS data analysis and the TAS manufacturers' comments supported the continued use of 

the low-volume federal criteria (i.e., every three days) in the Alaska2000 EIS 

specifications for two-point gas calibrations. The manufacturers also supported a threeday frequency for the required leak checks. Because problems have been experienced 

elsewhere in the country with "on-board" multipoint gas calibrations and I/M mechanics 

performed a quarterly gas audit of the accuracy of all EIS equipment (using a low-range 

audit gas), ADEC requested that EPA continue to waive this requirement for the Alaska 

I/M programs.

As with previous Alaska I/M programs, there is an ongoing statistical process control on 

the calibration data from Alaska2000 analyzers to look for trends indicating that an 

analyzer is out of compliance. In the event that significant drift is detected universally, 

ADEC intends to revise the Alaska2000 EIS specifications to require a mid-point check 

and also to require an increase in the frequency of calibrations. This frequency is roughly 

equivalent to requiring a calibration every 48 hours on emissions measurement 

equipment that performs 4,000 I/M tests per year.

2. Eliminate ambient zero air requirement - 40 C.F.R. 51.359(b)(2) requires analyzers 

that use ambient air as zero calibration air to draw the air from outside the test bay 

where each analyzer is located. 18 AAC 52 does not require ambient zero air to be 

drawn from outside the test bay, because ADEC considers this neither necessary nor 

feasible at private garage inspection stations in Alaska. Drawing air in extremely 

cold ambient temperatures from outside the test facility during the wintertime in 

Alaska would be expected to cause temperature and humidity problems within the test 

equipment. This would lead to increased equipment problems and less reliable test 

results. 

This requirement appears to be aimed primarily at high-volume, centralized test 

facilities that may experience elevated interior ambient pollutant concentrations 

during periods of high volume vehicle testing. That situation is clearly very different 

from the low-volume, decentralized test-and-repair stations operating in the Alaska 

I/M programs. EPA has waived this requirement for the Alaska I/M programs at 

ADEC’s request.

As a result of the implementation of the Alaska2000 program, it was found that the 

new EIS were more sensitive to background pollutant concentrations from within the 

test bay. For this reason, the Alaska2000 EIS specifications were updated to require 

zero air generators. The zero air generators pull air from within the test bay, which is 

then scrubbed of pollutants for use in the analyzer. This provides a good source of 

zero air for the analyzers while avoiding any temperature and humidity problems 

caused by drawing air from outside the test facility.

All other federal quality control requirements are incorporated into the Alaska I/M 

programs. The EIS must record quality control check information, lockouts, 
Adopted August 20th, 2010

III.A.2-30

attempted tampering, service calls, etc., to ensure quality control. The EIS must be 

maintained according to good engineering practices to assure test accuracy. The EIS 

housing is required to protect the analyzer bench and electrical components from 

excessive ambient temperature and humidity fluctuations. The EIS must 

automatically purge the analytical system after each test.

All certificates of inspection are issued through the EIS in order to reduce the 

likelihood of counterfeiting or other document fraud. Each paper certificate contains 

a unique serial number that is also displayed in bar-coded format, and contains the 

seal of the I/M implementing agency (MOA, FNSB, or ADEC). Certificates are 

placed in a locked compartment in the EIS and an electronic "certificate tamper" 

record is created whenever the compartment is accessed. Bar codes are used in 

printing certificates and contain specific vehicle identifiers and information relevant 

to the inspection process.

Beginning on September 1, 2002, the I/M program began providing I/M test 

information to the DMV as an electronic record and no longer issues paper 

certificates to motorists. This means that motorists no longer have to present the 

paper certificate to the Division of Motor Vehicles before the motorist can receive a 

vehicle registration. Motorists continue to receive a windshield sticker that will act as 

the visual proof of the inspection status of their vehicle for field enforcement. This 

eliminates paperwork and the potential for certificate fraud.

40 C.F.R. 51.360 Waivers and Compliance via Diagnostic Inspection –State I/M 

regulations (18 AAC 52), local I/M ordinances, and State and local program design 

documents (Appendices III.A, III.B.5, and III.C.5) include requirements related to this 

effort. Waiver issuance procedures for the programs are also included in Appendices 

III.A, III.B, and III.C. Under 18 AAC 52, waivers may be issued in the Alaska I/M 

programs for the following reasons:

• repair cost exceeds minimum requirement;

• diesel engine;

• seasonal waiver;

• special circumstances that make it impractical to test a vehicle;

• pattern failure;

• modification to the dedicated use of an approved alternate fuel;

• out-of-area use;

• economic hardship; or

• parts unavailability.

Each of these waivers is described in 18 AAC 52 and the applicable design documents 

(not all waivers are issued by each program). Two of the most important of these waiver 

programs are discussed below:

1. Emissions-Related Repair Cost Minimum Waiver - requires the following actions: 
Adopted August 20th, 2010

III.A.2-31

a. The vehicle must fail a retest after repairs have been made;

b. Available warranty and insurance coverage must be used before repair costs can 

be counted toward cost limits;

c. Repairs appropriate to the cause of test failure must have been performed; 

d. A visual check must be made to verify that the repairs were actually performed; 

e. Repairs must be performed by a certified mechanic to qualify for a waiver; and

f. A minimum amount of money must have been spent to qualify for a waiver.

For the state I/M program, the amount of money that must be spent before a repair cost 

waiver may be issued is described in the state I/M regulations at 18 AAC 52.065. The 

requirements for the MOA and FNSB I/M programs may be revised to include repair cost 

waivers, in response to state I/M regulation changes which allow this option. The MOA 

and FNSB I/M program requirements are required to be at least as effective in reducing 

emissions as the state requirements.

ADEC believes that the cost minimum on vehicle repairs in all three programs will have 

the same long-term effect as requiring immediate completion of all emissions-related 

repairs. It will also provide an equitable method for phasing in multiple expensive 

repairs. This is because at least one repair will be required each inspection cycle on a 

vehicle, regardless of cost, but allow deferral of additional repairs when the initial repair 

meets or exceeds the cost minimum. This position is supported by I/M data from the 

MOA I/M program. MOA repair cost waiver requests have dropped to less than 1% of 

the vehicles in the I/M program (which is mostly comprised of non-tampered vehicles). 

This is the result of the phase-in of higher repair cost limits, particularly a one-repairregardless-of-cost requirement. In addition, limiting the tampering-related cost ceilings 

to the modifications occurring before July 1, 1985 has ensured the rapid phaseout of all 

tampering-related repair-cost waivers. For these reasons, Alaska requested EPA approval 

of this exception to the federal I/M regulations.

A repair cost waiver rate of 1% of the vehicles in the MOA and FNSB I/M programs is 

assumed for both waiver categories (pre-1981 models, and 1981 and newer models) in 

the 1996 MOA and FNSB MOBILE5a computer runs, which demonstrate compliance 

with the federal basic performance standard. This waiver rate is based on those achieved 

by the MOA I/M program since the imposition of the one-repair-regardless-of-cost 

provision. ADEC commits to a waiver rate in practice that is equal to or lower than 1% 

of vehicles in either the MOA or the FNSB I/M programs. If the waiver rate for either 

program, as reported to EPA in the annual Alaska I/M report, is higher, ADEC will take 

corrective action to lower the applicable waiver rate. Possible corrective actions may 

include one or more of the following: 

• requiring a motorist who applies for a waiver to reduce initial emissions by a 

specified amount before a waiver may be issued; 

• limiting the model years that are eligible for a waiver; 

• limiting waivers on vehicles to only one inspection cycle; 

• raising the expenditure levels; or 

• other measures determined by ADEC or the local I/M Offices. 
Adopted August 20th, 2010

III.A.2-32

If any of the waiver rates cannot be lowered to the level committed to in the SIP, ADEC

will revise the I/M emission reduction projections in the SIP and will implement other 

program changes as necessary to ensure the performance standard is met.

2. Seasonal Waiver Program - Under 18 AAC 52.060(a)(3), a seasonal waiver may be 

issued by an I/M program if the motorist agrees to not operate the vehicle in either a 

nonattainment or maintenance area during the winter CO season. The seasonal 

waiver program has been an integral part of the FNSB I/M program since its 

inception in 1985 and ADEC supports FNSB's position that this waiver program is an 

essential part of the I/M program. MOA implemented a seasonal waiver program in 

1995. In both MOA and FNSB, vehicles for which seasonal waivers are issued 

receive different colored license tabs to make it easier to identify seasonally waived 

vehicles that are being operated illegally during the winter CO season. 

Additional provisions in 18 AAC 52.060 are also designed to limit the number of 

motorists who attempt to violate the seasonal waiver restrictions. If a motorist is 

proven to have been operating a vehicle in violation of I/M program requirements 

after the vehicle was issued a seasonal waiver, the seasonal waiver immediately 

becomes void. No seasonal waiver may be issued in the future to that vehicle or any 

vehicle owned by that motorist without good cause. If the vehicle is sold, the 

subsequent owner may be issued a seasonal waiver, if all seasonal waiver 

requirements are met. In MOA, a motorist will be subject to fines if found to be in 

violation of I/M regulations. 

All program waivers must be issued by the implementing agency's I/M Office or its 

contractor (e.g., MOA would be allowed to designate its referee facility contractor to 

issue waivers). Certified stations and mechanics are prohibited from issuing waivers. 

Vehicle owners must be informed of potential warranty coverage and ways to obtain 

warranty repairs. The primary mechanism for informing motorists of potential warranty 

coverage is through a message that is printed on all vehicle inspection reports (VIRs) 

issued to failing vehicles. Procedures for the issuance of waivers and other related 

administrative functions in the three programs are contained in Appendices III.A, III.B 

and III.C.

40 C.F.R. 51.361 Motorist Compliance Enforcement – State I/M regulations (18 AAC 

52), local I/M ordinances, and State and local program design documents include 

requirements related to this effort. Appendices III.A, III.B.5, and III.C.5 also contain 

program procedures that describe the methods that will be used to identify and eliminate 

noncomplying vehicles. The primary enforcement mechanism is through the Alaska 

DMV denial of motor vehicle registration. The owner or lessee of a vehicle subject to 

either the MOA or FNSB I/M program must submit proof of passing an I/M test (i.e., a 

certificate of inspection), or a valid I/M waiver, which was issued within a 90-day period 

before the registration renewal date. The owner or lessee of a noncomplying vehicle 

operating illegally in I/M areas will be identified and issued a notice of violation (NOV). 

A motorist that is issued a NOV will have 15 days to provide proof of I/M compliance. 
Adopted August 20th, 2010

III.A.2-33

In cases of continued noncompliance, the I/M programs will request that DMV revoke 

the vehicle's registration. The owner, lessee, or operator of a vehicle found to be operated 

with a revoked or expired registration may be prosecuted under the laws of Alaska.

Responsible agencies - I/M staff from ADEC, MOA and FNSB work with DMV to 

maximize vehicle compliance through the motor vehicle registration system. The Alaska 

State Troopers and local law enforcement agencies (e.g., Anchorage Police Department, 

Anchorage Parking Authority, and Fairbanks Police Department) provide on-road 

enforcement against unregistered vehicles. Law enforcement agencies also cite a 

motorist whose vehicle does not display a valid windshield sticker when a vehicle subject 

to an I/M program is stopped for another reason (e.g., during a traffic enforcement stop). 

18 AAC 52 requires display of a valid windshield sticker on all vehicles subject to I/M in 

Alaska. In both MOA and FNSB, law enforcement agencies enforce seasonal restrictions 

against vehicles obtaining a seasonal waiver from the I/M programs. The differentcolored license tabs issued to the seasonally waived vehicles aid this enforcement effort.

ADEC and local I/M staffs conduct parking-lot surveys in FNSB and MOA to ensure that 

unregistered or seasonally waived vehicles are not being driven illegally in the two 

communities during the winter CO season. Local law enforcement agencies cite 

noncomplying vehicle owners or lessees, and the data from the surveys are used to 

supplement annual program evaluation and reporting efforts.

In addition, ADEC identifies program evaders through searches of several databases. 

The owner or lessee of a vehicle identified in this manner is notified by ADEC of the 

need to obtain an inspection. Database tracking procedures track vehicles to ensure that 

they are brought in for I/M testing after notification or appropriate enforcement actions 

are taken.

Beginning in January 2000, a windshield sticker was added to the I/M programs to assist 

with enforcement efforts. The windshield sticker provides a means for visually 

identifying those vehicles that have taken part in the I/M program. The sticker helps

make it possible to identify non-complying vehicles that may not be caught through the 

DMV registration process, such as the commuter vehicles that travel into MOA as well 

as those that may be evading program requirements. Once identified, appropriate 

enforcement and compliance actions can be taken to bring these vehicles into compliance 

with the requirements. The windshield sticker program became fully effective in January 

2002 upon completion of the first biennial inspection cycle.

Fleet testing - All fleet vehicles, including rental cars, are subject to the same program 

requirements and testing procedures as other vehicles. Fleets may self-test; however, 

such fleet testing facilities must meet the following requirements:

1. they must be certified as official I/M Test Stations;

2. they must use certified I/M mechanics to conduct all I/M tests;

3. all I/M tests and certificate issuance must be conducted using certified 

Alaska2000 EIS specifications; and

4. they must comply with all other I/M program requirements. 
Adopted August 20th, 2010

III.A.2-34

Leased vehicles and other vehicles subject to one of the Alaska I/M programs but not 

necessarily registered in an I/M area must also comply with all applicable program 

requirements. Because Anchorage and Fairbanks are by far the largest cities in Alaska, 

statewide fleets (such as rental car companies) usually have their vehicles registered in 

one or the other of these areas. In many cases, such vehicles may be transferred between 

cities and used in an I/M area different from the one in which they are registered. To 

account for this, certificates issued by one of the I/M programs are considered valid for 

use in all I/M areas in Alaska. 

Compliance rates – In 1996, compliance rates for the MOA and FNSB I/M programs 

were estimated to be 95% and 96%, respectively. These rates were based on 1992 

information that may not reflect increased compliance achieved since that time 

(particularly in MOA) due to increased motorist compliance enforcement efforts. 

Compliance is also expected to increase in the future in both program areas due to an 

increased emphasis on interactive database searches and tracking efforts. The commuter 

I/M Program also has increased the MOA compliance rates. For modeling purposes in 

conducting the comparison to the federal basic I/M performance standard, the 95% and 

96% compliance rates have been assumed to ensure a conservative estimate of I/M 

effectiveness. Table III.A.2-6 provides a breakdown of estimated effect of the factors 

affecting compliance loss in each I/M area.

Table III.A.2-6

Estimated Effect of Factors Affecting I/M Compliance Loss

Noncompliance Factor MOA FNSB

Illegal or unregistered vehicles 2% 2.5%

Out-of-area vehicle registrations 2.5% 1%

Fraud and counterfeiting 0.5% 0.5%

TOTAL COMPLIANCE LOSS 5% 4%

ADEC commits to the level of enforcement needed to ensure compliance rates of no less 

than 95% and 96%, in MOA and FNSB respectively, among vehicles subject to the I/M 

programs. These compliance rates reflect the rates used in the 1996 MOBILE5a runs for 

both I/M areas, which were used for comparison to the federal basic I/M performance 

standard. The enforcement methods described in this section are expected to continue to 

maintain or improve enforcement levels. If it is determined as part of the required annual 

program evaluation that one or both of the I/M programs are not meeting the compliance 

rates committed to in this air quality plan, the following measures will be investigated to 

improve compliance:

• better on-road enforcement of registration requirements;

• revisions to the registration process to remove any identified problem areas;

• higher penalties for non-complying vehicle owners; and
Adopted August 20th, 2010

III.A.2-35

• creation of a telephone hotline for reporting non-complying vehicles.

In 2000 and 2001 serious area CO plans for Anchorage and Fairbanks were developed. 

As a result, the compliance rates shown for the Anchorage and Fairbanks I/M programs 

in Section III.B and III.C are updated values based on an analysis of recently collected 

data. In 1995, ADEC began to conduct license plate surveys of local parking lots to track 

the I/M compliance rate of vehicles being operated in the two communities. Based on the 

survey results7, the compliance rates for Anchorage and Fairbanks are estimated to be 

90% and 93% respectively.

Comparing these 2001 values to the 95% to 96% rates that have historically been used in 

developing SIP-related emissions inventories for the area showed an apparent decrease in 

the compliance rates. This is inconsistent with the improvements in vehicle enforcement 

in each community. It appears that the historical estimates were inaccurate. It is 

therefore considered likely that the I/M compliance rate actually declined over the last 

decade, a trend that was reversed due to the recent increase in vehicle enforcementrelated efforts in both communities. 

40 C.F.R. 51.362 Motorist Compliance Enforcement Program Oversight – State I/M 

regulations (18 AAC 52), local I/M ordinances, and State and local program manuals 

include requirements related to this effort. I/M program procedures governing such 

oversight activities are also included in Appendices to Sections III.A, III.B.5 and III.C.5. 

ADEC audits the active local I/M programs on a regular basis and implements a quality 

assurance program to ensure effective overall performance of the enforcement systems in 

both areas. 

QA/QC program – All agencies and personnel involved in I/M enforcement are required 

to follow quality control and quality assurance procedures, including procedures for I/M 

document handling and processing (both in the local I/M programs and at the Alaska 

DMV). The MOA or FNSB inspect exempt vehicles to confirm their status. Bar code 

readers are used on the EIS and at DMV to facilitate the accurate collection of critical test 

data and vehicle identifier information. An audit trail is maintained to allow for the 

assessment of enforcement effectiveness. Personnel performance is audited, following 

written procedures established by the responsible agencies (e.g., MOA, FNSB, and 

DMV). Retraining or other disciplinary actions may be required for enforcement 

personnel found to be deviating from established requirements.

ADEC and the local I/M programs perform follow-up checks on out-of-area or 

exemption-triggering registration changes. ADEC, the MOA and FNSB use PC-based 

I/M management software and DMV vehicle registration databases to analyze 

registration-change applications, to target potential program evaders, and to perform 

periodic audits of test records and registration files for renewals. 

Certificate tracking - Alaska2000 EIS generated paper and sticker certificates prevent 

fraudulent use of blank certificates. All certificates, except for duplicate or waiver 

 

7: Ibid. 
Adopted August 20th, 2010

III.A.2-36

certificates issued by an I/M Office to specific vehicles, must be issued by the 

Alaska2000 EIS on the basis of information entered into the EIS and recorded in the test 

record file. Certificate numbers identified as damaged, lost, or stolen are recorded in a 

separate EIS file and investigated for verification by each I/M implementing agency. 

Certified stations will be held financially liable for the cost of the certificates that are 

damaged, lost, or stolen, unless such damage was caused by an EIS malfunction or 

another EIS-related error. All certificates are entered into the I/M management software 

upon receipt from the printer and are subsequently tracked throughout the I/M testing and 

vehicle registration process. The software tracks those certificates issued by either a 

certified station or an I/M Office as well as all voided (e.g., damaged, lost, or stolen) 

certificates.

Information management - Sophisticated PC-based I/M software is used to establish an 

information base to characterize, evaluate, and enforce the I/M programs. An EIS record 

database is maintained with an automated test record-cleaning program in order to ensure 

the accuracy of the data. The information management program compares EIS test 

records and the DMV vehicle registration database to determine accurate estimates of the 

subject vehicle populations and assure the accuracy of the registration database and other 

document files. Database comparisons will also be performed to determine program 

effectiveness, establish compliance rates and trigger potential enforcement actions against 

motorists or operators of noncomplying vehicles.

ADEC, MOA and FNSB also perform periodic parking lot surveys to assess the 

compliance rate of the in-use fleet.

40 C.F.R. 51.363 Quality Assurance – State I/M regulations (18 AAC 52) and the 

program design documents (Appendices III.A, III.B.5, and III.C.5) include requirements 

related to this effort. I/M program procedures governing such activities are also included 

in Appendices to Sections III.A, III.B, and III.C. An ongoing quality assurance program 

assures the discovery, correction and prevention of fraud, waste and abuse. The QA 

program determines whether procedures are being followed and are adequate, whether 

equipment is measuring accurately and whether other problems exist that would impede 

program performance. 

Quarterly performance audits - Regularly scheduled performance audits, following 

established written procedures, will be conducted at all Certified I/M Stations on a 

quarterly basis. At a minimum, these audits will include checks for the following items:

• appropriate certificate security;

• required record keeping practices;

• proper display of certified station and mechanic licenses, and other required 

information;

• proper maintenance and calibration of the EIS; and

• ability of the certified mechanic to properly perform an I/M test.

Covert/overt vehicle audits - In addition to the quarterly audits, overt and covert vehicle 

audits are conducted on an unscheduled and as-needed basis. These audits follow 
Adopted August 20th, 2010

III.A.2-37

established written procedures that are designed to provide sufficient legal basis for 

subsequent enforcement actions, if required. Such audits may be performed to 

investigate suspected cases of program violations by certified stations or mechanics, in 

response to consumer complaints or as the result of quarterly audits, data analysis or 

other I/M management activities. Such audits may also be performed on a random basis 

to ensure continued compliance by other certified stations and mechanics. Stations and 

mechanics will not be given any notice of an impending covert vehicle audit. I/M 

inspectors will introduce themselves at the beginning of an overt audit, but will not do so 

in a covert audit. At a minimum, at least one covert audit is conducted per year at each 

certified station, and the total number of annual covert audits conducted by an I/M 

program will at least equal the number of certified mechanics in the program area. 

ADEC previously proposed the following exceptions to the federal performance audit 

requirements provided under 40 C.F.R. 51.363(a):

1. Two overt performance audits per year per test bay - ADEC proposed that EPA 

approve an alternative schedule of one quarterly performance audit per facility (i.e., 

four audits per station per year), plus at least one overt vehicle audit per station per 

year, in Alaska. Since most of the state's test-and-repair stations are relatively small, 

ADEC believes a "per-station" frequency requirement to be more appropriate than a 

"per-test-bay" requirement. In fact, the proposed alternative schedule would actually 

result in a greater frequency of audits at the majority of certified stations. In addition, 

due to other performance tracking and auditing tools (e.g., automated I/M data 

analysis and management software), ADEC believes that the federal per-test-bay 

frequency is not required to maintain effective quality assurance and compliance 

enforcement programs against the certified stations and mechanics. 

2. One remote covert performance audit per year per certified mechanic working at 

high-volume stations - ADEC proposed that EPA approve the elimination of this 

requirement in Alaska. ADEC considers that this requirement is infeasible in Alaska 

due to the state's unique weather conditions, and resultant station design and 

operation. Unlike most other states, inspections in Alaska are conducted in enclosed 

test stations where remote covert observations are usually impossible, particularly 

during the wintertime. The small size of the Alaska I/M areas, particularly in the 

FNSB, also ensures that the I/M industry would learn very quickly of covert 

operations, rendering them ineffective as an audit tool. In addition, ADEC believes 

that other performance tracking and auditing tools (e.g., automated I/M data analysis 

and management software) dramatically reduce the need to use remote covert audits 

to maintain effective quality assurance and compliance enforcement programs against 

certified stations and mechanics. 

Record audits – EIS test records are audited on a monthly basis, using established written 

procedures, to assess individual certified mechanic and station performance. PC-based 

I/M management software identifies statistical inconsistencies, unusual patterns, and 

other discrepancies. The record audit includes a comprehensive accounting of all 

certificates issued to each certified station. In addition, an I/M inspector may conduct an 
Adopted August 20th, 2010

III.A.2-38

on-site audit (in addition to the regularly scheduled quarterly audits) of records not 

covered by electronic analysis (e.g., work orders). 

Equipment audits - Equipment audits are performed during each quarterly performance 

audit, using established written procedures, to ensure the accuracy and reliability of all 

required test equipment. The audit includes an inspection and gas audit of each EIS at 

the certified station. 

Inspector training and proficiency - Each I/M inspector will be formally trained and 

knowledgeable in all aspects of the I/M program, including the following subjects:

• basics of air pollution control; 

• basics of motor vehicle engines and emission control systems;

• motor vehicle engine and emissions performance repair;

• program regulations; 

• use and maintenance of the EIS;

• I/M test and repair procedures; 

• evidence gathering;

• applicable administrative procedures laws and regulations;

• quality assurance practices; and

• covert and overt audit procedures.

Ongoing training will be provided to I/M inspectors to ensure that they maintain an 

adequate level of knowledge regarding new technology vehicles, I/M testing equipment, 

and other relevant subjects. The performance of each I/M inspector will be evaluated at 

least once annually to identify any possible problem areas. 

40 C.F.R. 51.364 Enforcement against Contractors, Station Owners, Operators, and 

Mechanics – State I/M regulations (18 AAC 52), local I/M ordinances, and State and 

local program design documents (Appendices III.A, III.B.5, and III.C.5) include 

requirements related to this effort. I/M program procedures governing such enforcement 

activities are also included in Appendices III.A, III.B.5, and III.C.5.

Under the Administrative Procedure Act (AS 44.62), ADEC or another I/M 

implementing agency must provide notice and opportunity for hearing before suspending, 

revoking, or refusing to renew a station's or mechanic's certification issued under either 

18 AAC 52 or the MOA or FNSB local implementing ordinances. In addition, neither 

ADEC nor the local implementing agencies have civil, administrative citation powers 

under the laws of Alaska. As a result of these factors, the Alaska I/M programs are 

unable to comply with requirements contained in 40 C.F.R. 51.364 for the imposition of 

mandatory minimum administrative penalties (e.g., fines) or the immediate suspension of 

station or mechanic certifications. If ADEC files a civil action under AS 46.03.760, there 

is a statutory minimum court imposed assessment of $500. (The only exception to the 

prohibition against immediate suspensions would be during an ADEC declaration of an 

emergency situation under AS 46.03.820.) In lieu of citation powers, ADEC applies an 

alternative enforcement mechanism, consisting of the following elements:
Adopted August 20th, 2010

III.A.2-39

1. If an I/M program office finds that a certified station or mechanic has violated 

I/M program requirements, the I/M office will immediately issue a notice of violation 

(NOV) to the certified station or mechanic. The I/M program office will provide an 

opportunity for a response within 10 days after receipt of the notice.

2. A hearing will be held after an I/M office finding of such a violation. If the 

hearing results support the I/M office's finding, the corrective action to be taken against a 

mechanic or station will depend on the nature and severity of the violation. If the hearing 

results support a finding that the station or mechanic violated program requirements, 

resulting in a vehicle being improperly passed for any required portion of the I/M test, the 

station or mechanic's certification may be suspended. 

3. If an I/M program office finds that a certified station or mechanic has violated 

an I/M program requirement, and the violation directly affects emission reduction 

benefits, the I/M office will work with ADEC to immediately suspend the certified 

station's or mechanic's certification under ADEC's emergency powers authority, if 

possible. The criteria for declaring an emergency are defined in AS 46.03.820. In the 

case of an immediate suspension, ADEC will provide an opportunity for a hearing within 

three working days of the suspension.

Continued violation of program requirements may result in the permanent revocation of 

certification under 18 AAC 52, after notice and opportunity for hearing, or the filing of a 

civil or criminal action against a certified station or mechanic under AS 46.03.760 or 

46.03.790.

A finding of certified mechanic incompetence will result in mandatory training before 

inspection privileges are restored. A certified station will be held fully responsible under 

this program for the performance of its mechanics. 

The I/M implementing agency maintains records of all documentation related to 

enforcement activities against certified stations and mechanics, and maintains statistics 

on violations and penalties.

40 C.F.R. 51.365 Data Collection - The EIS specifications of 18 AAC 52 include 

detailed requirements for the collection of test data and quality control records. Each 

Alaska I/M program will collect test record and gas calibration record data, that meet the 

requirements of 40 C.F.R. 51.365, from the EIS used in the program. 

40 C.F.R. 51.366 Data Analysis and Reporting - Under 18 AAC 52.037, each Alaska 

I/M program must submit a report described in (b) of this section to the department 

within 30 days of a request as required in (a) of this section that includes the data and 

information requirements of 40 C.F.R. 51.366(a)-(d). The report information includes 

statistics for the I/M test data, quality assurance results, quality control activities, and 

enforcement activities. 
Adopted August 20th, 2010

III.A.2-40

Under 18 AAC 52.037(c), each Alaska I/M program must submit a report to ADEC that 

that describes changes to the program, problems in the program, any steps planned or 

taken to address those problems, and the results of corrective actions taken as required by

40 C.F.R. 51.366(e). The report must address any change in program design, financing, 

personnel level, procedure, regulation, and legal authority. It must also include a detailed 

discussion and evaluation of the impact of any identified changeand any future corrective 

efforts that are planned. ADEC will submit, upon request, a biennial report that meets the 

reporting requirements of 40 C.F.R. 51.366(e) to EPA by July of every other year.

40 C.F.R. 51.367 Inspector Training and Licensing or Certification - Under 18 AAC 

52 and the MOA and FNSB I/M implementing ordinances, formal training and licensing 

is required for all inspectors (certified mechanics). Mechanics receive required training 

covering the following topics:

• causes and effects of air pollution; 

• the role of motor vehicles as sources of air pollution, particularly the problem of 

cold-temperature vehicle operation causing high carbon monoxide emissions;

• motor vehicle engine combustion and emissions;

• function and effect on emissions of all emission control systems;

• symptoms and causes of high CO or HC emissions;

• purpose, function, and goals of the I/M program;

• EIS operation, calibration, and maintenance;

• I/M test and repair procedures and rationale; 

• quality control procedures and their purpose;

• public relations; and

• safety and health issues related to the inspection process.

ADEC certifies training courses meeting the minimum qualifications contained in 18 

AAC 52 for the training of persons applying for certification as certified I/M mechanics, 

and ADEC monitors and evaluates the delivery of the training program. 

Upon successful completion of the training course, an applicant must achieve a score of 

at least 80% on a written competency test covering all aspects of the training. The I/M 

office or its designee administer a one-day rules and regulations course to all applicants 

passing the written competency test. The rules and regulations course covers statutes, 

regulations, and other procedures governing the maintenance and repair of emission 

control systems on motor vehicles in Alaska, with an emphasis on I/M program 

requirements. A hands-on skill test administered by the I/M Office, requires an applicant 

to demonstrate an unassisted ability to properly follow all test procedures, and operate, 

calibrate, and maintain the Alaska2000 EIS.

After an applicant passes all training and testing requirements, the I/M office may license 

the applicant as a certified mechanic. Certification is good for a period of two years, with 

passage of a refresher-training course required for license renewal. The performance of 

all certified mechanics is monitored on a regular basis.
Adopted August 20th, 2010

III.A.2-41

40 C.F.R. 51.368 Public Information and Consumer Protection - ADEC commits to 

operating an ongoing program designed to educate the public about the air quality 

problems in Alaska. Procedures for this program are contained in Appendices III.A, III.B 

and III.C. The program will utilize primarily print and radio media, including paid 

advertisements, newspaper articles, and regularly scheduled wintertime air quality 

forecasts. The public information program meets the requirements of 40 C.F.R. 

51.368(a). 

A motorist whose vehicle fails the I/M test, will be given a Vehicle Inspection Report 

(VIR) printed by the EIS, which includes software-generated diagnostic information 

based on the particular portions of the test that were failed. 

Each I/M program maintains a referee facility to provide a mechanism for motorists to 

challenge inspection results, and to assist owners, if needed, in obtaining warranty 

coverage for failed vehicles. Protection to the extent allowed by Alaska law will also be 

provided to any "whistleblowers" who uncover fraud, waste, or abuse in the I/M program. 

Procedures for this program are contained in Appendices III.A, III.B, and III.C.

40 C.F.R. 51.369 Improving Repair Effectiveness - ADEC believes that effective 

repairs are the critical link to maximizing the effectiveness of the Alaska I/M program. 

Accordingly, it is imperative that ADEC work with MOA and FNSB to assist the motor 

vehicle industry in properly diagnosing and repairing emissions-related defects. 

Procedures for providing technical assistance in this area to the motor vehicle repair 

industry are contained in Appendices III.A, III.B and III.C. This assistance will include 

each program's establishment of a telephone hotline service to assist certified mechanics 

and other qualified technicians with specific repair problems. Mechanics’ newsletters 

will also be distributed to all certified mechanics on an as-needed basis, to inform them of 

program changes, training course schedules, common problems being experienced in the 

I/M program, and diagnostic tips. 

Based on ADEC's assessment of the availability of adequate repair technician (certified 

mechanic) training in I/M areas, the State's Alaska Vocational Training Center (AVTEC) 

in Seward will continue to ensure that training is made available to all interested 

individuals. AVTEC has been certified by ADEC to present on-site Alaska2000 EIS 

mechanic training courses in both Fairbanks and Anchorage.

40 C.F.R. 51.370 Compliance with Recall Notices - Not applicable to Alaska.

40 C.F.R. 51.371 On-Road Testing - Not applicable to Alaska. 

40 C.F.R. 51.372 State Implementation Plan Submissions- An analysis and 

demonstration that the MOA and FNSB I/M programs meet the federal basic 

performance standard under 40 C.F.R. 51.352 is contained in this plan. A description of 

the geographic coverage, under 40 C.F.R. 51.350, of the three Alaska programs and the 

program manuals are contained in Appendices III.A, III.B.5 and III.C.5 to this SIP. 

Required design elements for the Alaska I/M programs are discussed in detail throughout 
Adopted August 20th, 2010

III.A.2-42

this section. Provisions for federal facility compliance under 40 C.F.R. 51.356 are 

included. Evidence of adequate funding and resources to implement all aspects of the 

Alaska I/M program under 49 C.F.R. 51.354 is contained in this plan. 

2.3.3 Alaska’s Oxygenated Fuels Program

Section 211(m) of the CAAA (42 U.S.C. 7545 (m)) mandates the use of oxygenates in all 

CO nonattainment areas. Beginning November 1, 1992, all gasoline used in a CO 

nonattainment area, during the period of the year in which the area is prone to high CO 

concentrations, must contain at least 2.7% oxygen by weight. For MOA and FNSB, EPA 

originally set the applicable oxygenated fuels control period from November 1 to March 

1 of each winter. ADEC initially adopted oxygenated fuels regulations on September 25, 

1992, which meet the provisions of Section 211(m) (42 U.S.C. 7545 (m)). 

ADEC suspended the oxygenated fuels program in the MOA in 2004 when EPA 

redesignated the MOA to attainment, concurrent with its maintenance plan approval. 

Congress exempted the FNSB from the oxygenated fuels program in the 1990s and the 

FNSB also was redesignated to attainment in 2004 without the use of oxygenated fuels. 

Oxygenated fuels remain as a contingency control measure in the MOA maintenance plan 

that would be reimplemented if a new CO violation occurs. The regulations for this 

control measure, 18 AAC 53, Fuel Requirements for Motor Vehicles, are found in the 

Appendix to Section III.A.

The blending of gasoline with oxygenates such as alcohols or ethers has been found to 

greatly reduce exhaust emissions of carbon monoxide from both catalyst- and noncatalyst-equipped vehicles. Oxygenated fuels also affect hydrocarbon (HC) emissions 

and oxides of nitrogen (NOx) as well as CO emissions. The effects, however, depend on 

the type of oxygenate employed and the age and maintenance of the vehicle fleet.

Fuel metering systems generally supply a fixed volume of fuel per unit of engine airflow. 

Thus, when an engine is running on a fuel that contains an oxygenate, it will have more 

oxygen than when it is running on straight gasoline. The extra oxygen leads to more 

complete combustion of the extra fuel used during the cold start, and thus reduces the 

level of CO and HC emitted.

To help communities evaluate the benefits of alternative oxygenates, EPA has 

incorporated oxygenated fuels credits into its mobile source emissions factor model, 

MOBILE. The model allows the input of any oxygen level up to the limit allowed by 

EPA regulation (i.e., 3.5% oxygen by weight, which is the level equivalent to a blend of 

10% ethanol/90% gasoline). As EPA has updated the MOBILE model, the level of 

emission reduction credit for oxygenated fuels has also evolved. As a result of research 

into the benefits of oxygenated gasoline and adaptive memory features on late-model 

vehicles, EPA has updated the MOBILE model to reflect less benefit for oxygenated 

fuels in newer vehicles. MOBILE6 reflects this change. 
Adopted August 20th, 2010

III.A.2-43

2001 Evaluation of Municipality of Anchorage Ethanol Program 

In 2001, MOA evaluated the emission reduction benefits of wintertime use of ethanolblended gasoline in MOA, as part of its serious area CO control plan. The elements of 

the ethanol-fuel program have not changed, however the updated MOBILE Cold CO 

model was used to prepare these estimates.

The MOBILE Cold CO Model was run to estimate the CO reduction benefit of using 

ethanol-blended gasoline in Anchorage during the year 2000 attainment year. According 

to the model, on-road CO emissions are reduced by 13.6%. The impact of the ethanolblended fuel program on warm-up idle emissions is unknown. If ethanol is assumed to 

have the same percentage benefit on idle emissions as it does on on-road emissions, the 

total CO reduction from the program is computed to be 7.61 tons per day.

Health-Related Concerns 

Under the oxygenated fuels regulations adopted by ADEC, local refiners and distributors 

may choose the type of oxygenate (e.g., MTBE, ethanol, ETBE, TAME, etc.) used to 

meet the minimum-required oxygen content. During the first winter of the program, 

operational and supply considerations led all marketers to choose MTBE for use in both 

MOA and FNSB. The program was implemented as scheduled on November 1, 1992; 

however, within a short period of time, ADEC began to receive a high volume of healthrelated complaints from the general public regarding the use of MTBE-blended gasoline 

in the two communities. In particular, a large number of individuals allegedly suffered 

adverse effects from the use of the MTBE blend in FNSB.

As a result of these complaints, ADEC worked with EPA and the federal Centers for 

Disease Control (CDC) to conduct a detailed analysis of the human health effects of the 

wintertime use of MTBE in FNSB. This included both the distribution of a detailed 

health-related questionnaire and the analysis of blood samples of local residents exposed 

to the MTBE blends. Based on the preliminary results of these studies, ADEC decided to 

suspend the oxygenated fuels program in FNSB until further analyses of the potential 

health effects of MTBE use in cold climates could be completed. 

Because of possible health concerns, ADEC chose to suspend the oxygenated fuels 

program in both FNSB and MOA pending the results of further studies conducted in 

cooperation with EPA. The FNSB program was initially suspended by emergency 

regulation in December 1992. Subsequent regulatory amendments were adopted on 

September 8, 1993, in accordance with all applicable federal and State public notice and 

comment requirements. These amendments required ADEC, if it decided to resume the 

program, to publish a notice of intent to do so no less than 75 days before its resumption. 

In 1996, based on public comment, the oxygenated fuels regulation were amended so that 

if ADEC decided to resume the program, it is required to publish a notice of intent to do 

so no less than 180 days before its resumption.
Adopted August 20th, 2010

III.A.2-44

In support of ADEC’s position, Congress approved a one-year exemption for Alaska 

from the federal oxygenated fuel requirements as a rider to the 1994 federal funding 

appropriations bill. Under this exemption, EPA was precluded from enforcing the 

provisions of the CAAA related to oxygenated fuels in Alaska during federal fiscal year 

1994. In the report accompanying the appropriations bill, Congress further stated its 

intent that Alaska and EPA jointly finance, with the assistance of the refiners and 

producers, studies by the EPA to resolve health concerns related to the use of MTBE in 

Alaska. FNSB was again exempted from the oxygenated fuel requirements as a rider to 

the 1996 federal funding appropriations bill.

ADEC and EPA held several discussions in 1993 and 1994 regarding the results of 

additional studies conducted on the use of MTBE at low temperatures. ADEC worked 

together with CDC to develop a coordinated approach to studying the use of other 

oxygenated-fuel blends in Alaska, as an alternative to MTBE use. These studies involved 

both technical (e.g., fuel blend distribution and vehicle driveability) and health-related 

concerns pertaining to the use of oxygenated-fuel blends at the temperatures commonly 

experienced in FNSB and MOA during the winter months, which can be as low as -60° 

Fahrenheit.

Based on the preliminary results of these studies, and at the request of MOA, an ethanolbased oxygenated-fuels program was implemented in the MOA from January 1, 1995 to 

March 1, 2003. The maintenance plan adopted in 2004 no longer relies on oxygenated 

fules as a primary control strategy, due to its diminishing effectiveness shown in 

MOBILE 6 modeling.