Vehicle Inspection and Maintenance (I/M) Programs: The Road Ahead

1. Vehicle Inspection and Maintenance (I/M) Programs: The Road Ahead AAMVA Region II Conference, June 9, 2010 Presenter: David Sosnowski Office of Transportation and Air Quality, USEPA

2. I/M & the new ozone standard • In January, EPA proposed a primary 8-hour ozone standard in the range of 0.060 to 0.070 ppm • The proposal is scheduled to be finalized in August 2010 with areas designated and classified by August 2011 • Revised ozone standard will trigger new I/M programs • Level of standard, classification method, and 2008-2010 air quality data will determine the final number of new I/M programs • Some states with no prior experience with I/M may be pulled in • Others states with prior, negative histories will likely be pulled in • I/M SIPs are due 1 year after classifications, in August 2012 • New I/M programs must be fully implemented 4 years after classification, in August 2015

3. Implementation rule • An implementation rule for the new ozone standard is scheduled to be proposed later this year & finalized by April 2011 • The proposal (and final rule) will address such implementation issues as how designated nonattainment areas are to be classified, whether or not the previous standard will be revoked, and how the Clean Air Act’s antibacksliding provisions will be addressed • Like the proposal for the implementation rule for the 1997 ozone standard, the new implementation rule proposal is likely to include several classification options • The issue of how areas are classified – which will be marginal, moderate, serious, severe, or extreme – will help determine how many new I/M programs will be required under the new ozone standard • The two other determining factors are the level of the standard, whether or not a given nonattainment area already has I/M, and the given area’s urbanized population under the 1980 Census (for enhanced I/M areas) or the 1990 Census (for basic I/M areas)

4. Current status of I/M • For comparison: Currently, there are 50 I/M programs in 33 states (including DC) • Depending on the standard and classification method used, the number of new I/M programs could be significant • When new I/M programs were required in the ’80s and ’90s, there was a great deal of resistance on the parts of several states and sanctions were threatened several times • The I/M landscape has changed a lot since then • I/M rule revised 10 times to provide states greater flexibility • Testing through the vehicle’s onboard diagnostic (OBD) system is replacing tailpipe tests on model year 1996 and newer vehicles • OBD testing makes I/M cheaper, quicker, more reliable, and more protective of consumers by targeting and confirming specific repairs • But at the same time, I/M programs are getting fewer reductions credit because new cars are staying cleaner, longer • Emission reduction needs have replaced the performance standard as the driving force behind program design choices

5. On-Board Diagnostic: a closer look • In addition to numerous I/M rule changes and less overall benefits, the most noticeable change to I/M is the introduction of OBD-based testing • OBD testing reduces the difference between basic and enhanced I/M to a few administrative requirements • As OBD vehicles begin to dominate fleets, more programs are switching to OBD-only testing • Nationally, 80% of the fleet is currently OBD-equipped • By 2012, 90% will be OBD-equipped, accounting for 95% of VMT • The timing of the switch to OBD-only among existing programs is largely driven by contracts, attainment needs, the age of the local fleet, and whether there is a safety inspection • Given the timing of the 2010 standard (which will require that new I/M programs begin operation by late 2015), we believe most new I/M programs will be OBD-only programs • The trend toward OBD-only testing provides us the opportunity to make I/M more palatable than it has been historically

6. Onboard Diagnostics (OBD = ) An OBD scan tool can cost a few $100 to a few $1000, vs. an IM240 set up which cost $75-$150K A typical OBD test takes roughly 5-10 minutes from the time the vehicle enters the test bay to the time it leaves

7. Kinder, gentler I/M through OBD • Communications/outreach • Rebranding: OBD is not your father’s I/M • It’s cheaper, quicker, more consumer-friendly, and offers many paths to increasing owner convenience (such as…) • Passive I/M options (made possible by OBD) • Self-serve testing kiosks • Remote OBD • OBD data loggers

8. Innovative OBD options Remote OBD Data loggers Kiosks And there’s an app for that…

9. Passive I/M options • Remote OBD • Install or use pre-existing telematic device (like GM Onstar) to monitor OBD system remotely • Vehicle fixed soon after light comes on • Pro: More credit than traditional I/M; Con: “Big Brother” issues • Self-serve testing kiosk • Makes testing as convenient as using an ATM • Open 24/7 and can be placed in mall parking lots, gas stations, etc. • Pro: No “Big Brother” issues or hardware installation; Con: motorist safety and vandalism • Data loggers • Owner plugs in device before registration to confirm vehicle passes OBD test • Proof of compliance transmitted to state by email or snail mail • Pro: No “Big Brother” or safety issues; Con: no state interest so far • Shared traits • Cheaper, more convenient than traditional I/M • Available to states now

10. Conclusion • I/M has never been a popular program and getting new programs adopted and implemented will not be easy for either EPA or the states required to adopt them • Based on past experience, significant resources will be required to meet this challenge • Nevertheless, EPA believes it has laid the groundwork to make the best of the opportunities that technological advances like OBD afford existing and future I/M programs • Stay tuned and make sure your I/M staff stay connected via EPA’s bimonthly OBD stakeholder calls • If you are not currently on the mailing list for that call, please send your email information to klavon.patty@epa.gov

11. Region 4 I/M Contacts • Dale Aspy (404) 562-9041 • aspy.dale@epa.gov • Amanetta Somerville (404) 562-9025 • somerville.amanetta@epa.gov • Scott Davis (404) 562-9127 • davis.scottr@epa.gov