Priority Area 14:
Clean Air Act (CAA) Inspection & Maintenance (I/M) Program Reporting

 

Vehicle inspection and maintenance (I/M) programs  help improve air quality by identifying high-emitting vehicles in need of repair (through visual inspection, emissions testing, and/or downloading fault codes from a vehicle's onboard computer) and requiring repair as a prerequisite to vehicle registration within a given non-attainment area.  The 1990 Amendments to the Clean Air Act made I/M mandatory for several areas across the country, based upon various criteria, such as air quality classification, population, and/or geographic location.  Approximately 34 states now operate I/M programs.

Five states – Illinois, Maryland, Massachusetts, New Hampshire, and Virginia – requested changes to EPA’s I/M reporting and/or program evaluation requirements.  In general, the states’ recommendations centered on reducing the amount and specificity of data required in the I/M regulations at 40 CFR 51.366 as well as the frequency of the required reports.  Details about each state’s recommendations can be found under Recommendation A10 and Recommendation A21.  

EPA is working with states to introduce more flexibility in I/M reporting.  In 2007, for example, EPA’s Office of Air and Radiation (OAR) provided states with a checklist enumerating the data needed for I/M reports.  This checklist also provided states with an opportunity to direct EPA staff to existing sources of the data, such as Web sites or state databases.  As long as EPA staff can collect necessary data from these existing sources, states need not submit to EPA a reformatted I/M report on the same data.  Also, for the past two years, OAR has hosted a workshop with its Regional I/M contacts to review I/M reports received from the states and discuss program improvements based on states’ submissions.

An EPA-run stakeholder group meets approximately monthly to address I/M implementation issues raised by states.  EPA also co-chairs a Federal Advisory Committee workgroup, formed in 2006, which meets regularly to discuss opportunities for innovation presented by vehicle’s onboard diagnostics (OBD).  Starting with model year 1996, vehicles are able to store emission control status information in their onboard computers, while also alerting the driver when repairs are needed.  As the percentage of the existing vehicle fleet with OBD capabilities increases over time, state I/M programs will become more standardized.  The state-EPA advisory workgroup is discussing how to use OBD to reduce the implementation burden and customer inconvenience associated with I/M programs.  For example, beginning in 2008 and continuing through 2009, EPA will be developing guidance to assist states with implementing and evaluating their OBD-centered programs. Furthermore, in recognition of OBD’s potential to reduce the implementation burden associated with I/M programs while also increasing their cost-effectiveness, EPA amended the I/M regulations in 2001 to allow states to replace traditional tailpipe testing with OBD-based programs.

OAR welcomes further discussions with states on how to make the I/M program more effective and flexible.  All states are welcome to join the monthly EPA-run stakeholder group and raise concerns and questions they may have with their I/M programs.  At this time, however, EPA will not reduce reporting frequency or detail of the I/M reporting requirements.  There are two reasons for maintaining the I/M reporting requirements’ level of detail and frequency. 

First and foremost, the program is important for controlling air pollution.  Pollution from mobile sources contributes to two of our worst urban air pollution problems – smog and carbon monoxide (CO).  On-road mobile source emissions account for approximately 51 percent of the CO, 29 percent of the hydrocarbons (HC), and 34 percent of the nitrogen oxides (NOx) in our nation's air (based on 1999 data, see EPA’s mobile source emissions Web page). For on-road mobile sources like cars and light-duty trucks, the I/M program is a principal method used to address mobile source pollution in severely polluted major urban areas.  Detailed reports allow EPA to ensure that I/M programs are being implemented in compliance with approved State Implementation Plans.  They also help EPA (and the states) identify recurring problems with specific vehicle makes or models, or with specific diagnostic equipment and can also help identify other implementation challenges that may prevent states from meeting their emission reduction goals.

The second reason EPA will not reduce reporting frequency or details right now is because the Agency has committed to a number of corrective actions for the I/M program with EPA’s Office of the Inspector General (OIG).  In October 2006, the OIG issued a report entitled EPA’s Oversight of the Vehicle Inspection and Maintenance Program Needs Improvement.  It found that EPA needs to improve its ability to determine whether I/M programs are achieving the emission reductions claimed by making sure that states comply with existing I/M reporting requirements.  EPA’s ability to reduce the reporting burden at this time is therefore limited by both the Clean Air Act’s statutory requirements (in the case of mandatory program evaluation requirements) and the Agency’s commitment to improve reporting compliance made in response to the IG’s report.  Please note, however, that part of the Agency’s corrective action commitments is to comply with Office of Management and Budget recommendations for reducing state burden.  The steps described above illustrate EPA’s commitment to reduce reporting burden, and OAR hopes to continue working with the states to further improve the program.