(I hope this gets out - I haven't received a digest in two days :-()
Here is my summary of the proposed new emissions inspection rules from EPA.
I should say up front that I'm not a lawyer or an expert in air pollution.
I've simply read the document and am attempting to provide a neutral
summary. You won't find my opinions here, I hope. If anyone is really
interested, I may pontificate in a separate posting. I've tried to emphasize
those provisions relevant to older cars, but in fact there aren't very many.
If there's anything you want to know that isn't covered here, send me mail
and I'll try to answer your questions.
The document is entitled "Vehicle Inspection and Maintenance Requirements
for State Implementation Plans." It is a Notice of Proposed Rulemaking,
*not* a final rule. It proposes requirements for basic and enhanced
vehicle inspection and maintenance (I/M) programs as required by the
Clean Air Act. Written comments will be accepted until August 27, 1992
at the following address: Environmental Protection Agency, The Air
Docket, Room M-1500 (LE-131), Waterside Mall, Attention: Docket No.
A-91-75, 401 M Street S.W., Washington, D.C. 20460.
I got my copy of the preamble (143 pages) by calling the regional EPA
office.
Ten to 30 percent of cars cause the majority of the pollution. The EPA
estimates that good I/M programs in the most polluted cities would cut
vehicle emissions 28 percent. The Act requires that the most polluted
cities cut overall emissions by 24 percent by 2000.
The EPA recommends and certifies state programs. States can create I/M
programs different from the EPA recommendations if they show that the
program is more effective in reducing emissions. Therefore, the program
that affects you may be different from what I summarize here. Greater
reductions of mobile-source emissions than those required can be traded
off against fixed-source (industrial) emissions in achieving the 24 percent
overall goal.
The areas to be covered by I/M programs are not specified directly in
the document I have. They are classified as "marginal", "moderate",
"serious", "severe", and "extreme" ozone nonattainment areas. You
probably know if you live in such an area.
I/M program come in two flavors in this proposal. The "basic" program
is identical to what currently exists in a number of areas. All moderate
nonattainment areas will be required to implement basic I/M. Those
marginal areas which currently have I/M will be required to continue it.
The "enhanced" I/M program is the one that has been in the news. All
severe and worse nonattainment areas will be required to implement
enhanced I/M. The enhanced I/M program is proposed because the current
idle and 2500 RPM tests are not effective for newer vehicles and because
audits show that improper testing is very common (50%). Existing tests
also don't measure evaporative emissions, which are a greater source
of hydrocarbons than tailpipe emissions.
The EPA is recommending that cars be tested every two years because the
results are nearly as good and the cost and hassle are halved.
There is a good deal of discussion in the document about centralized
vs. decentralized testing, that is, emissions centers vs. gas stations.
The proposal requires centralized testing unless the state shows that
it can provide equivalent quality control. The document discusses
motorist convenience at some length.
The enhanced I/M proposal is justified on the basis that it is the most
cost effective way to reduce emissions. It is 7 times more effective
than stronger new car standards and 10 times more effective than
stronger controls on industrial sources per dollar spent, if convenience
costs are not accounted for. Even if convenience costs are included,
it is still 2x and 3x more cost effective, respectively.
To boil it down, the enhanced test proposed is a dynamometer test. It
measures emissions during acceleration and deceleration. This allows
NOx emissions to be measured and precludes most test-defeating strategies
(you didn't really think they didn't know about those, did you?) It also
includes tests of the evaporative emissions control system. Alternative
tests proposed by states must be shown to have a similar low false
failure rate and be similarly resistant to defeat.
Here's the meat of it from our point of view: If your car is older
than 1968, no testing is required. 1968-1980 cars get idle tests only.
1981-1982 cars get two-speed tests. 1983-1985 cars get two-speed tests
plus pressure testing of the fuel system. 1986 and later cars get the
dyno test and full evaporative tests.
The document doesn't specify the "cutpoints", that is, the numerical
standards. It says they have been chosen to fail vehicles emitting
more than twice their design standard amounts.
Another new feature of enhanced I/M is the requirement that all recalls
related to emissions equipment must have been completed.
Waivers and the cost of repairs required to get one are another topic.
Here's an interesting quote from the legislative history of the Act:
"...poorly maintained vehicles that pollute, no matter how old, should
be required, at a minimum, to meet the standards applicable to them
when they were manufactured. If repairs are needed, they should be made."
In line with this, the new limit in enhanced I/M areas is $450, to be
adjusted annually for inflation. In basic I/M areas, the proposed limits
are $75 for pre-1981 and $200 for 1981 and later vehicles.
States are required to have these programs authorized by November 1993.
Basic I/M programs must be implemented by July 1993 if decentralized
or January 1994 if centralized. Enhanced programs may be phased in
starting no later than July 1994, and must be testing all affected vehicles
by January 1, 1996. Cutpoints may also be phased in, but by January 1,
1998 the whole program must be in place.
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