1. Emissions Deterioration Study Mobile Sources Program Air Pollution Control Division

2.  Emissions testing contract expired December 31, 2014.  In 2011 Colorado Air Quality Control Commission (AQCC) requested a fresh look at mobile source control strategies.  Problem: Lack of contemporary information on control strategy effectiveness.

3.  National Academies of Science Report: “Evaluating Emissions Inspection and Maintenance Programs” (2001)  On-Board Diagnostics Policy Work Group report (2002)  EPA: “High Mileage Study of On-Board Diagnostics Emissions” (2005)  Gardetto and Lawson: response to “High Mileage Study of On-Board Diagnostics Emissions” (2006)  CARB: “Transitioning Away from Smog Check Tailpipe Emissions Testing in California for OBDII Equipped Vehicles” (2009)  Georgia Tech Research Institute:“Estimated Validity and Reliability of On- Board Diagnostics for Older Vehicles: Comparison with Remote Sensing Observations” (2011) 3/08/2012 3 Vehicle IM Program Review and Evaluation Part 2

4.  Tested 153 randomly procured vehicles using FTP, I/M 240 and OBD II  Failing vehicles were repaired and a post-repair FTP was conducted to measure emission reductions  48 total vehicles failed ◦ 40 failed OBDII only ◦ 6 failed OBDII and I/M 240 ◦ 2 failed I/M240  OBDII test achieved greater HC, NOx and CO emission reduction benefit than I/M 240 ◦ I/M240 HC, NOx and CO benefit approximately 88%, 75% and 83% of OBDII benefit 3/08/2012 4 Vehicle IM Program Review and Evaluation Part 2

5.  Analyzed raw data from High Mileage Study  Found same relative benefits of OBDII and IM/240 as reported by EPA but noted: ◦ OBD failed significantly more vehicles ◦ OBD could miss very high emitting vehicles identified by I/M240 ◦ Also notes that 153 vehicles analyzed were part of a larger 300 vehicle dataset  Concluded that utilizing OBDII “…greatly increase[s] the number of failing vehicles with little significant benefit from repairs.” 3/08/2012 5 Vehicle IM Program Review and Evaluation Part 2

6. 12/9/2002 6 1,223 IM240 failures 1,478 OBD failures 92 vehicles (3.4%) failed both 1996 and newer vehicles 116,945 vehicles screened Evaluation of Wisconsin’s data OBD vs. I/M240

7.  Many OBD requirements are more stringent than I/M exhaust failure thresholds.  Traditional I/M exhaust measurements do not account for: ◦ Cold start/running problems; ◦ Most evaporative problems; ◦ High speeds and acceleration rates.  Strategies for on-board system/component failures.  OBD warns of problems early - emissions impact comes later. 7

8.  Aggregate program changes must achieve the same, or more, emission reduction benefit.  Customer convenience must be improved.  Program costs must not increase.

9.  What are the comparative emissions reductions by test type (IM240, OBD, etc.)?  What the comparative costs by test type?  Are there “hidden” emissions reductions that decrease observed benefits? 9

10. TrucksCars 10

11. 3/08/2012 11 Vehicle IM Program Review and Evaluation Part 2

12.  Average incoming FTP emissions by certification category and recruitment group (grams/mile). CERT BIN Failed Recruit GroupCount AvgOfFTP CO AvgOfFTP NOx AvgOfFTP THC Tier IBoth2125.831.631.97 Tier I Emissions Only812.321.950.93 Tier IOBD Only212.360.520.18 Tier IIBoth1519.412.010.84 Tier II Emissions Only622.221.050.99 Tier IIOBD Only222.600.260.20

13.  Costs Projected for One Program Cycle (Two Years) 2017-18 and divided by two for yearly cost  Costs Projected Based on Current Program Structure with Three Different Testing Methodologies for 1996 and Newer Vehicles ◦ I/M 240 ◦ OBDII ◦ Dual Testing  Four Cost Elements ◦ Test Fee ◦ Repair Costs ◦ Fuel Economy Cost Savings ◦ Registration Fees 5/4/2012 Vehicle IM Program Review and Evaluation Part 313

14.  I/M240 Program: $45,296,971 per year  OBDII Program: $71,160,270 per year  Dual Testing Program: $78,062,132 per year 5/4/2012 Vehicle IM Program Review and Evaluation Part 314

15.  Study Goal: ◦ Evaluate the deterioration rates of Tier II vehicles with, and without, the Malfunction Indicator Lamp (MIL) illuminated.  Better understanding of the discontinuity between OBD & IM240 results.  Better understanding of relative costs and benefits of each program. 15

16.  FTP - Federal Test Procedure. Laboratory-grade test used to certify new and in-use vehicles. ◦ 2-3 day test.  US 06 ◦ More aggressive drive profile.

17.  Methodology ◦ Recruit 40 MIL=on, and 40 MIL=off vehicles ◦ Perform an initial laboratory test series ◦ Perform an identical series every four months for two years ◦ Repair vehicle if/as necessary upon completion. 17

18.  Recruitment: ◦ Send out solicitation letters to owners of Tier II vehicles:  Randomly selected MIL=off (40)  Must pass pre-inspection.  Most MIL=on vehicles (40):  Must pass pre-inspection;  Driver does not want to fix MIL condition;  No all-wheel drive;  No evaporative DTCs (SHED substantially increases test time)  No catalyst damaging misfires, some transmission codes, etc. (vehicle must last for 2 years) 18

19.  Test Protocol ◦ Pre-inspection; ◦ Two IM240 series including OBD scan; ◦ LA4 prep cycle; ◦ FTP test cycle; ◦ US06 test cycle; ◦ Return to owner  Repeat approximately every four months. 19

20. Row Labels200420052006200720082009Grand Total ACURA 12 3 AUDI 1 1 BMW 1 1 BUICK 1 1 CHEVY 1 3 4 FORD 1 1 HONDA 232 310 HYUNDAI 3 1 4 KIA 232 7 MAZDA111 3 MITSUBISHI111 3 NISSAN 632 10 PONTIAC 1 4 5 SATURN 12 3 SUZUKI 1 1 TOYOTA11623 13 VOLKSWAGEN 14 5 Grand Total317291014376 20

21. 200420052006200720082009Grand Total MIL OFF271469341 Passed FTP13716220 Failed FTP14753121 MIL ON1101545 35 Passed FTP 7 3 10 Failed FTP110842 25 Grand Total317291014376 21

22. 200420052006200720082009Grand Total MIL OFF271469341 Passed FTP13716220 Failed FTP14753121 MIL ON1101545 35 Passed FTP 7 3 10 Failed FTP110842 25 Grand Total317291014376 22 Caveat: No attempt has been made yet to analyze/explain these results.

23. Colorado Regional Air Quality Council Eastern Research Group US EPA Opus Inspection 23