1. Environmental Quality Board Harrisburg, PA October 16, 2007 Thomas K. Fidler, Deputy Secretary Office of Waste, Air and Radiation Management Feasibility of Modifying the Pennsylvania Vehicle Emissions Inspection Program

2. Background on I/M Programs The Clean Air Act Amendments of 1990 require states to adopt and implement motor vehicle inspection/maintenance (I/M) programs in certain carbon monoxide and ozone nonattainment areas and the Ozone Transport Region. PA’s federally enforceable I/M Program was approved by EPA and codified in the State Implementation Plan (SIP) at 40 CFR Part 52.2020.

3. Background (continued) The I/M Program is mandatory in 25 counties in Pennsylvania; testing and inspection procedures vary by region (Philadelphia, Pittsburgh, Southcentral, and Northern Regions).

4. Section 126.451(3) of the PA Clean Vehicles Program requires : The Department, in conjunction with PennDOT, to study and evaluate the feasibility of modifying the Pennsylvania Vehicle Emission Inspection Program…considering the additional reductions in NOx, VOCs, and other pollutants to be achieved through implementation of the Pennsylvania Clean Vehicles Program. (25 Pa. Code § 126.451(3) )

5. Evaluation of the I/M Program Legal Requirements for program. Requirements of program in broader context of attaining/maintaining health-based national ambient air quality standards. Technical Emissions estimation in future years: 2010 and 2018. Benefits and latitude for modification within I/M requirements.

6. Constraints for modification of Pennsylvania’s I/M Program  I/M programs are mandatory in ozone transport regions established under the Clean Air Act.  Timely attainment/maintenance of the ozone and fine particulate standards.  Compliance with federal “anti-backsliding” requirements in nonattainment or maintenance areas, which require compensating emission reductions.  Compliance with the applicable I/M federal performance standard.  Compliance with the federally prescribed elements of I/M programs.

7. Findings The benefits of the I/M program include VOC and NOx emission reductions needed to achieve and maintain ozone and fine particulate standards. Striped area indicates additional emissions if I/M program were not in place.

8. Technical Evaluation Evaluated PA I/M program by area with all other strategies in place against EPA’s I/M performance standard program with all PA strategies in place. Both sides of comparison must use PA-specific data with only the I/M program varying. “Anti-backsliding” and attainment needs are not part of this analysis.

9. Findings The programs with on-board diagnostics are projected to continue to meet or slightly exceed the applicable EPA performance standard in 2010 and 2018. Cost-effective emission reduction benefits to replace any lost through I/M modifications would be difficult to find. Programs without on-board diagnostics may not produce enough benefits in future years to meet the applicable EPA performance standard as 1996+ vehicles become a larger percentage of fleet.

10. Conclusion The emission reductions achieved under PA’s Clean Vehicles Program can not supplant reductions required under the federally mandated enhanced I/M program. The Clean Vehicles Program, if approved by EPA as a SIP, would be considered a SIP strengthening air quality control measure. Therefore, the Clean Vehicles Program could not be used to modify the stringency of the I/M program. Modifications to PA’s I/M Program are not advisable at this time.

11. Thank You Thomas K. Fidler Deputy Secretary, Office of Waste, Air and Radiation Management Joyce E. Epps Bureau of Air Quality Kristen Campfield Office of Chief Counsel Arleen Shulman Bureau of Air Quality