1. Michael St. Denis, Robert Budd, Revecorp Inc. I/M Solutions 2014 April 27 – 30, 2014 Salt Lake City, Utah

2.  40 CFR 51.363 requires equipment audits be performed twice annually per lane or test bay as part of the overt audit of inspector performance  EPA guidance at www.epa.gov/otaq/regs/im/auditgd.pdfwww.epa.gov/otaq/regs/im/auditgd.pdf  The goal is to ensure motorists get quality inspections and the proper data is collected  Auditors shall be audited once per year each  Due to 40 CFR 51.364(e) I/M Programs can have alternate audit procedures if they can be proven effective  We believe OBDII is such that you can electronically audit the equipment  We have suggestions for improvement in data collection to improve the quality and accuracy of OBDII inspections – and - which should allow for better fraud identification Revecorp Inc.

3.  Second Generation On-Board Diagnostics (OBDII) was required on gasoline and bi-fuel vehicles up to 8,500 pounds GVWR starting 1996  CA up to 14,000 GVWR  Federal OBDII for vehicles up to 14,000 GVWR 2005  Diesel vehicles were required to have OBDII in 1997  Alternative fueled in 2005  Common connector and communications  Five communications protocols (languages) allowed  Only CAN allowed starting MY 2008 (there are exceptions)  11 Readiness monitors – Six may or may not be used on a particular vehicle (supported)

4. Continuous (Always ready) Non-Continuous (Ready, not ready or unsupported) Not Supported Comprehensive component CatalystAir Conditioning MisfireEvaporativeHeated Catalyst Fuel systemOxygen sensor Oxygen sensor heater Exhaust gas re-circulation (EGR) Secondary Air

5.  Second Generation On-Board Diagnostics (OBDII) was required on gasoline and bi-fuel vehicles up to 8,500 pounds GVWR starting 1996  CA up to 14,000 GVWR  Federal OBDII for vehicles up to 14,000 GVWR 2005  Diesel vehicles were required to have OBDII in 1997  Alternative fueled in 2005  Common connector and communications  Five communications protocols (languages) allowed  Only CAN allowed starting MY 2008 (there are exceptions)  11 Readiness monitors – Six may or may not be used on a particular vehicle (supported)  Electronic VIN started being supported in 2000, required in all vehicles starting 2005

6.  OBDII tests more than hot running emissions – it tests cold start and evaporative control systems  Detects emissions changes lower than tailpipe (BAR97 or IM240) analyzers can measure  OBDII checks that the emissions controls are working properly  Malfunction Indicator Light (“MIL” or “Check Engine” light) illuminated only for emissions problems  Problems identified by “Diagnostic Trouble Codes”: P0420 - Catalyst System Efficiency Below Threshold  The test is NOT dependent on external standards, technician skill, equipment less expensive and a motorist can easily determine if repairs were successful  Education about check engine light being a potential air pollution indicator is the single most effective emissions control program – It will save the children and $ to fix it!

7.  Proper auditing starts with good test procedures, data and equipment specifications prior to program implementation  Must completely identify all data to be collected and how collected:  Different programs calculated PID count differently  Different programs identify communications protocol differently: ▪ Key Word versus Key Word fast or slow initialization ▪ Can versus CAN11 bit or CAN 29 bit  Must perform detailed acceptance testing: SAE J1966-2  Must have sufficient time for proper beta testing as OBDII anomalies can only be found in the field  Must have the ability to visualize OBDII in analyzers  Audit data should be collected electronically and stored Revecorp Inc.

8.  Generally two failure modes:  OBDII scan tool dies – no data – very obvious – infrequent  Bend a pin in the connector or break a single wire in the cable – causes only one or two protocols to stop working (no communications)  Traditional audits require a visit with an OBDII simulator which can test all communication protocols – and therefore test all wires in the cable  Check the ability of the system to obtain the following over any communication protocol:  Readiness monitor status  If the MIL is commanded on  DTCs set  Common to use an EASE Diagnostics OBDII Simulator Revecorp Inc.

10.  Data should be captured electronically  If there is a failure, auditor should be able to lock out the analyzer  Have equipment service reps repeat audit after service and remove lockout if passed Revecorp Inc.

11.  Programs can perform the audits since they must go on site twice year to perform other overt audit functions  Although an OBDII audit is quick, it still takes time and equipment = $... and everyone has budget limitations  The audit interrupts the operation of the station which shops dislike  We believe it is better to simply use the inspection data to audit the OBDII equipment – saves cost and shops time  If the equipment dies – this will be obvious  If you are checking for communications problems, use a truth table of what the expected protocol should be and if you see two test in a row which have the same communications protocol and do not communicate, invalidate the second test, lock out the analyzer and have them call a tech Revecorp Inc.

12. Inspections may be improper if the vehicle data is entered incorrectly:  VIN should be decoded for every test because the previous test record could have be fraudulent  VIN validation should be required using:  Check digit  Comparison to table of all known VIN “stems” Revecorp Inc.

13.  Since 1981 US vehicles have 17 digit VINs  Generally:  Places 1 – 3 the manufacturer (World Manufacturer Index)  Places 4 – 8 describe the vehicle characteristics  Place 9 is the check digit – calculated based on other digits  Place 10 is model year  Place 11 is usually factory of manufacture  Places 12 – 17 are usually the serial number of the vehicle  Example: 2001 Dodge Stratus - 4B3AG52H81E144029  Example: 4B3 - AG52H – 8 – 1 – E – 144029  VIN Stem: 4B3AG52H*1E  Revecorp has a table of all VIN stems in the US to 1981 Revecorp Inc.

14. Inspections may be improper if the vehicle data is entered incorrectly:  VIN should be decoded for every test because the previous test record could have be fraudulent  VIN validation should be required using:  Check digit  Comparison to table of all known VIN “stems”  VIN decoding should provide year, make and model but also fuel type and GVWR because these impact test type selection – Only VINterpreter has GVWR data  If an inspector changes any of these parameters, the data should be flagged for review Revecorp Inc.

15.  Inspection data can be checked against reference VIN Decoded data  Real time  Add the reference data to the test record to make auditing easier  In batch  Real time test blocking versus after the fact  Centralized ▪ Real time should be required – Halt the test and get a manager to review the vehicle, etc. before continuing  Decentralized ▪ Most programs cannot tolerate stopping inspections ▪ Could refer motorists to “referee” stations to clear up discrepancy ▪ Could mark data in real time with a flag for review – go visit station ▪ Could do in batch after the fact Revecorp Inc.

16.  This should be done by VIN due to problems with naming conventions (RAV4 = RAV 4 = RAV/4 = RAV-4). Data entry fields should be pre-populated lists or “other” – No Free Form!  Fraud triggers should include:  Changes to fuel type or GVWR provided by VIN decoding  For MY 2000 to 2004 vehicles, if the vehicle supports e-VIN, if e-VIN is unsupported or if the VIN should be provided but invalid ▪ Ford E-150s respond with 1f1f1f1f1f1f1f1f1  Communications protocol  Readiness monitor support  Fraud triggers should NOT include:  PCM ID, PID count, CALID or CVN  Station and inspector rankings work well Revecorp Inc.

17.  Proper auditing must be designed into the program starting with the RFP  This should include the proper data for performing triggers analyses  OBDII auditing should be performed remotely electronically  The remote OBDII guidance document has suggestions as to how the data should be recorded – it would be great if all programs used this as a guide  A large obstacle to using reference data is naming conventions - use of VIN based reference data solve this  Use of a VIN decoder which can provide reference data such as GVWR and fuel type can prevent fraud  A few limited triggers will catch most fraud (not simulators, etc.) Revecorp Inc.

18.  To solve the naming convention issue we recommend NCIC  We have been discussing distribution of recall data with NHTSA and they would like IM programs to provide this data to motorists. Many times the second or later owner does not receive important safety recall data. VINterpreter has recall data, both emissions and safety data, by VIN stem, which is updated daily that can be provided.  We have a database of hundreds of million of data records. The data are used to improve vehicle fingerprints to prevent fraud. Please consider sharing you IM data with us  We have an Android version of the VINterpreter VIN decoder available for free to anyone interested, just stop by our booth Revecorp Inc.

19. Contacts: Revecorp Inc. Michael St. Denis, Robert Budd 5732 Lonetree Blvd Rocklin CA 95765 (916) 786-1006 Revecorp Inc.