Emissions Deterioration Study Mobile Sources Program Air Pollution Control Division

 Emissions testing contract expired December 31,  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.

 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/ Vehicle IM Program Review and Evaluation Part 2

 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/ Vehicle IM Program Review and Evaluation Part 2

 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/ Vehicle IM Program Review and Evaluation Part 2

12/9/ ,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

 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

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

 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

TrucksCars 10

3/08/ Vehicle IM Program Review and Evaluation Part 2

 Average incoming FTP emissions by certification category and recruitment group (grams/mile). CERT BIN Failed Recruit GroupCount AvgOfFTP CO AvgOfFTP NOx AvgOfFTP THC Tier IBoth Tier I Emissions Only Tier IOBD Only Tier IIBoth Tier II Emissions Only Tier IIOBD Only

 Costs Projected for One Program Cycle (Two Years) 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

 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

 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

 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.

 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

 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

 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

Row Labels Grand Total ACURA 12 3 AUDI 1 1 BMW 1 1 BUICK 1 1 CHEVY FORD 1 1 HONDA HYUNDAI KIA MAZDA111 3 MITSUBISHI111 3 NISSAN PONTIAC SATURN 12 3 SUZUKI 1 1 TOYOTA VOLKSWAGEN 14 5 Grand Total

Grand Total MIL OFF Passed FTP Failed FTP MIL ON Passed FTP Failed FTP Grand Total

Grand Total MIL OFF Passed FTP Failed FTP MIL ON Passed FTP Failed FTP Grand Total Caveat: No attempt has been made yet to analyze/explain these results.

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