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Re: Emissions Inspection Proposal

To: angevine@badger.Colorado.EDU (Wayne Angevine)
Subject: Re: Emissions Inspection Proposal
From: plains!pwcs.stpaul.gov!phile@uunet.UU.NET (Philip J Ethier)
Date: Wed, 29 Jul 92 13:23:11 CDT
Wayne Angevine writes> 

>Here is my summary of the proposed new emissions inspection rules from EPA.
>I've simply read the document and am attempting to provide a neutral
>summary.

Thanks are due Wayne for taking the time to research and type this stuff.
It shows that the newspaper reports have been less than accurate.
This proposal has had no coverage at all here in Saint Paul.

>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 am a little paranoid about this.  Its like dealing with the IRS.

>I got my copy of the preamble (143 pages) by calling the regional EPA
>office.

When the *preamble* is 143 pages, it is a sure bet bureaucracy is at work.

>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.

So once again the car owners get the hassle and big business gets off.  
Thank you Reagan and Bush.

>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 think Minnesota is clean enough to be "marginal".  In fact, it has been shown 
that the Minnesota PCA intentionally rigged the numbers to make the feds
 require testing.  No lie.  They admitted it.  But we still have the testing.

>I/M programs 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.

I can live with this.  They do not test either pre-76 cars or those with 
Collector plates.  I am happy to test the Mighty K-wagon, but not the Lotus 
which will be driven less than 1000 miles a year.

>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.

Minnesota should escape under these circumstances.

>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 centralized program here is not too bad.  Short waits.  There are several 
test sites around the suburban areas of the Metro.  Testing is only required 
for cars registered in the 7-county Metro area.  (There is a solution!  Move to 
Duluth!)

>To boil it down, the enhanced test proposed is a dynamometer test.  

The sites in Minnesota were built with dynamometers.  They seem to be something 
to drive over on your way in and out.  I have never seen them used, but then 
again, I have never failed a sniff test.

>1968-1980 cars get idle tests only.

Hmm.  I might be able to pass that with suitable tuning and enough alcohol.
(In the gas tank, not in me!)  If it failed, they might open the hood and look 
around.  Then I am dead meat.  My best hope is they let Minnesota continue to 
not test pre-76 cars.  Also, if the Collector plates are still allowed to 
exist, I could get through because they will require testing to renew your 
plates.  Collector plates do not have to be renewed, so when are they going to 
look for me?

>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.

That does not, of course, include "tampering".  If it cost $5000 to get the 
Lotus legal, they would not care.

>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.

I am still confused about it all, but not as worried as I was before.

Phil Ethier, THE RIGHT LINE, 672 Orleans Street, Saint Paul, MN   55107-2676
h (612) 224-3105     lotus@pnet51.orb.mn.org (infrequent mail checks)
w (612) 298-5324     phile@pwcs.stpaul.gov (lists go here)
"The workingman's GT-40" - Colin Chapman     "It's a Mistake" - Colin Hay


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