Massachusetts SIP Revision

310 CMR 60.02, the Massachusetts Motor Vehicle Emissions Inspection and
Maintenance Program

Documentation of IM SIP Revision consistent with 42 USC 

Section 7511a and Section 182 (c)(3)(A) of the Clean Air Act

Table of Contents

  TOC \o "1-3" \u  EXECUTIVE SUMMARY	  PAGEREF _Toc226958336 \h  i 

INTRODUCTION	  PAGEREF _Toc226958337 \h  2 

1.0	Applicability (51.350)	  PAGEREF _Toc226958338 \h  3 

2.0	Enhanced IM Standard (51.351)	  PAGEREF _Toc226958339 \h  3 

3.0	Network Type and Program Evaluation (51.353)	  PAGEREF _Toc226958340
\h  7 

4.0	Adequate Tools and Resources (51.354)	8

5.0	Test Frequency and Convenience (51.355)	  PAGEREF _Toc226958342 \h 
8 

6.0	Vehicle Coverage (51.356)	  PAGEREF _Toc226958343 \h  9 

7.0	Test Procedure and Standards (51.357)	  PAGEREF _Toc226958344 \h  11


8.0	Test Equipment (51.358)	14

9.0	Quality Control (51.359)	  PAGEREF _Toc226958346 \h  14 

10.0	Waivers and Compliance via Diagnostic Inspection (51.360)	  PAGEREF
_Toc226958347 \h  15 

11.0	Motorist Compliance Enforcement (51.361)	  PAGEREF _Toc226958348 \h
 16 

12.0	Motorist Compliance Enforcement Program Oversight (51.362)	 
PAGEREF _Toc226958349 \h  17 

13.0	Quality Assurance (51.363)	  PAGEREF _Toc226958350 \h  18 

14.0	Enforcement against Contractors, Stations and Inspectors (51.364)	 
PAGEREF _Toc226958351 \h  19 

15.0	Data Collection (51.365)	20

16.0	Data Analysis and Reporting (51.366)	  PAGEREF _Toc226958353 \h  20


17.0	Inspector Training and Certification (51.367)	  PAGEREF
_Toc226958354 \h  21 

18.0	Public Information and Consumer Protection (51.368)	  PAGEREF
_Toc226958355 \h  21 

19.0	Improving Repair Effectiveness (51.369)	  PAGEREF _Toc226958356 \h 
22 

20.0	Compliance with Recall Notices (51.370)	  PAGEREF _Toc226958357 \h 
23 

21.0	On-Road Testing (51.371)	24

 

Appendices

Appendix 1..... Contract with Parsons

Appendix 2..... Massachusetts Statutory Authority for IM Program and the


                         Massachusetts IM Regulations (MassDEP/RMV)

Appendix 3..... RMV Regulations 540 CMR 4.0

Appendix 4..... Mobile6 model 4 Input Sources and Files

Appendix 5..... Mobile6 model 4 Output Files

Appendix 6..... Massachusetts IM Motor Vehicle Inspection Trust Fund
Legislation

Appendix 7..... Massachusetts IM Program Budget for Fiscal Years 2008
and 2009

Appendix 8......Tables showing Total Vehicles Tested and Exempt by
Vehicle Class



EXECUTIVE SUMMARY

This State Implementation Plan (SIP) revision is required under the
Clean Air Act Amendments of 1990 and federal regulations, 42 United
States Code section 7511a, section 182(c)(3)(A) and ensures changes to
Massachusetts’ Inspection and Maintenance (IM) program are fully
documented.  The structure of this document is consistent with
requirements that have been established by the United States
Environmental Protection Agency (EPA) for IM programs.  The IM program,
designed to identify vehicles that emit pollutants that exceed
acceptable standards and require such vehicles to get repaired, is an
important part Massachusetts’ strategy to attain and maintain the
National Ambient Air Quality Standard for ozone.  

The Massachusetts IM program, which dates back to 1983, has a history of
effectively reducing vehicle emissions.  The IM program has relied on a
decentralized network of inspection stations that are licensed by the
Massachusetts Registry of Motor Vehicles (RMV) to conduct safety and
emissions tests.  Most Massachusetts vehicles receive their inspections
at local public stations.  The program also allows owners of vehicle
fleets to purchase testing equipment so they can test their own
vehicles. 

The Massachusetts Department of Environmental Protection (MassDEP) has
amended its IM regulations to be consistent with the current IM program
contract, which commenced on October 1, 2008, and to comply with federal
requirements that have been enacted since the regulations were last
amended.



INTRODUCTION

This document outlines the Massachusetts Inspection and Maintenance (IM)
program with each section providing the details on specific elements of
the program, followed by citations to the statutory and regulatory
authority to conduct these specific elements.  

Massachusetts is required to adopt and implement an enhanced inspection
and maintenance program, pursuant to 42 United States Code section
7511a, section 182(c)(3)(A) of the Clean Air Act Amendments of 1990. 
The current Massachusetts IM program was authorized by the Legislature
under Chapter 210 of the Acts of 1997.  The Massachusetts IM program is
jointly administered by the Department of Environmental Protection
(MassDEP) and the Registry of Motor Vehicles (RMV).  MassDEP’s
implementing regulations (310 CMR 60.02) were initially adopted in
January 1999 and amended in 2004.   From 1999 through September 30,
2008, the program was implemented through a contract with Applus+
Technologies, Inc. and, as of October 1, 2008, through a contract with
Parsons Commercial Technology Group, Inc. (Parsons).  MassDEP and the
RMV amended their respective IM regulations to update the program and to
comply with federal requirements that have been enacted since the
regulations were last amended.  These regulations became effective on
September 5, 2008.  Due to this program change, Massachusetts is
revising the state implementation plan (SIP) for submittal to the United
States Environmental Protection Agency (EPA). 

This SIP revision meets the requirements specified in section 182(c)(3)
of the Clean Air Act and the federal regulations promulgated thereunder,
which require any state with an ozone nonattainment area classified as
moderate or above to implement an IM program to reduce emissions of
hydrocarbons (HC) and oxides of nitrogen (NOx) from in-use motor
vehicles.

This SIP revision is being submitted in accordance with regulations from
40 Code of Federal Regulations (CFR) Part 51.  MassDEP and the RMV
entered into a contract with Parsons Commercial Technology Group, Inc.
on January 16, 2008 to implement the current IM program beginning
October 1, 2008.  Under this contract, the IM program continues to
deliver inspections through a decentralized network of local inspection
stations.  All vehicles continue to receive an annual safety inspection.
 However, vehicles are now required to receive an annual emissions test,
rather than the biennial test required under the previous program.  The
emissions test relies primarily on an “on-board diagnostic” (OBD)
test; the previous program’s use of a dynamometer to test tailpipe
emissions has been discontinued.  In addition, a fifteen year rolling
exemption replaces the previous fixed year exemption of 1984.  The OBD
emissions test has also been expanded to include diesel vehicles. Large
diesel trucks and buses not equipped with an OBD system will continue to
receive an opacity test; the amendments to the MassDEP regulation lower
the opacity cut points for these vehicles.  As new medium- and
heavy-duty vehicles become equipped with OBD systems, they will also be
required to obtain an annual OBD emissions test.  A copy of the contract
between MassDEP, the RMV, and Parsons is contained in Appendix 1.

1.0	Applicability (51.350)

1.1 Massachusetts IM Program Meeting Federal SIP Requirements

Massachusetts will continue to implement the enhanced inspection and
maintenance program statewide through a decentralized network of local
inspection stations.  All vehicles will continue to receive an annual
safety test.  However, the amended regulations require an annual
emissions test, rather than the biennial test required under the
previous program.  The emissions test relies primarily on the OBD test
currently used for 1996 and newer vehicles; the previous program’s use
of a dynamometer to test tailpipe emissions has been discontinued.  A
fifteen year rolling exemption replaces the previous fixed year
exemption of 1984.  The OBD emissions test has also been expanded to
include diesel vehicles.  Large diesel trucks and buses not equipped
with an OBD system will continue to receive an opacity test; the revised
regulations lower the opacity cut points for these vehicles.  As new
heavy-duty vehicles become equipped with OBD systems, they will also be
required to obtain an annual OBD emissions test.  

1.2 Applicable Documentation for the Massachusetts IM Program

The legal authority for the implementation of the Massachusetts IM
Program is included in Appendix 2 and contains both the statute and
regulations.  MassDEP and the RMV have adopted regulations for the IM
program.  RMV regulations (540 CMR 4.00) govern the day-to-day
administration and operation of the IM program and the MassDEP
regulations (310 CMR 60.02) establish appropriate emission testing
requirements.

2.0	Enhanced IM Standard (51.351)

2.1 Massachusetts IM Program Meeting Federal SIP Requirements

Section 110(n) of the U.S. Clean Air Act (the “savings clause”)
states that if a program required by the Act is revised, it must
maintain at least the emission benefits demonstrated when it was first
approved into the SIP.  EPA requires Massachusetts to implement an IM
program due to the Commonwealth’s non-attainment status with respect
to ground level ozone.  The revised program maintains level of emission
reductions that were demonstrated for the previous IM program.

MassDEP has modeled the emissions impact of the new program using
EPA’s MOBILE6 (model input and output files) model.  In the model,
MassDEP assumed a program start date of October 2008 and an exemption
for vehicles 15 or more model years old.  Based on this modeling,
MassDEP believes the program will achieve the reductions needed for the
SIP.  

2.2 Applicable Documentation for the Massachusetts IM Program

The emissions benefits of the new program were compared with those
estimated for the previous program with biennial emissions testing
(transient testing for model year 1984-1995 vehicles and OBD testing for
model year 1996 and later vehicles).  The estimated figures for vehicle
miles traveled per day by the Massachusetts fleet as a whole that were
used to determine the emissions figures are shown in Table 1.

Table 1

Estimated Vehicle Miles Traveled Used to Model Air Quality Impacts of
Changes in the Massachusetts IM Program

	2009	2010	2011	2012	2018

Estimated VMT per day	149,228,000	149,962,000	150,694,000	151,427,000
155,700,000



Table 2 and the associated graph, Figure 1, show the results of the
modeling for 2009 through 2012, and for 2018 (the final analysis year
required by EPA for the 8-hour Ozone SIP).  The emission figures show
the tons per summer day (tpsd) of on-road mobile source emissions that
would remain if the previous biennial testing program was continued into
the future, under new annual OBD testing program, and the difference, or
delta, between the two.

Table 2

Comparison of Emissions for Current and Proposed IM Programs

	 Pollutant	2009

(tpsd)	2010

(tpsd)	2011

(tpsd)	2012

(tpsd)	2018

(tpsd)

Previous IM Program	VOC	73.61	67.18	61.60	56.32	38.97

	NOx	224.7	196.5	170.6	147.7	65.0

	CO	1002.1	938.6	885.2	837.8	711.5

New IM 

Program 	VOC	73.78	66.87	61.04	55.86	38.78

	NOx	224.0	195.4	169.2	146.4	64.2

	CO	1003.7	932.0	872.5	824.9	701.3

Delta = 

Previous -New Programs	VOC	-0.17	0.31	0.57	0.46	0.19

	NOx	0.6	1.1	1.5	1.3	0.7

	CO	-1.6	6.6	12.7	12.9	10.2





Figure 1

 

These figures show that an annual OBD program, without transient
testing, will result in slightly more VOC emissions (0.17 tpsd) in 2009
than would be expected if the previous program was continued.  However,
an expected decrease in NOx emissions (0.6 tpsd) leads to a net
reduction in ozone forming pollutants.  While the modeling also shows a
slight increase in CO emissions (1.6 tpsd) in 2009, the pollutants that
are most important for ozone production are NOx and VOCs.

For the following reasons, MassDEP believes the program under the new
regulations meets the requirements of the U.S. Clean Air Act’s savings
clause:  

These results assume no carryover of emission reduction benefits from
the transient testing program that ended on September 30, 2008.  A
carryover effect would recognize that emissions from most of the
vehicles that received a biennial transient test will not automatically
rise to levels that would result in a failing test immediately at the
end of the current program, and would allow these benefits to be
estimated in the modeling as a benefit in the new IM program.  Because
the MOBILE6 model does not recognize any carryover effect, it assumes
the tailpipe testing benefit ends as soon as the program stops.  MassDEP
believes this is unrealistic.  EPA Region 1 has agreed that residual
credit from the tailpipe testing would make up for the small increase in
HC and CO emissions that the model predicts in 2009.

The MOBILE6 model calculates emissions on the basis of complete calendar
years, and does not allow for testing to begin in October of a calendar
year, when annual testing under the new program began.  Therefore, the
model does not account for emission benefits that were earned between
October 1, 2008 and December 31, 2008.

Table 3 below shows that the estimated difference in emissions benefits
between the previous program and the new program are well within the
model’s margin of error.  

MassDEP believes the new program will achieve the reductions needed for
the SIP.  Specifically, in 2009, the 0.17 tpsd difference for VOCs
represents less than 0.3% of VOC emissions modeled; and the 0.6 tpsd
difference for NOx represents an improvement of almost 0.3% of NOx
emissions modeled.  For CO, the 1.6 tpsd difference represents less than
0.2% of CO emissions modeled.  Table 3 shows that the new program will
create very close to 100% of the air quality benefits of the previous
program for VOC and CO in 2009, and more than 100% for NOx.  

Table 3

Detailed Comparison of Emissions for 2009

Emissions from Programs	Benefit from Programs	Differences between
Programs



2009	No IM Program

(tpsd)

	Previous Program

(tpsd)

	New Program

(tpsd)

	Benefit of Previous Program

(tpsd)

	Benefit of 

New

Program

(tpsd)

	Delta

Between

Benefits

(tpsd)

	Delta

vs.

Current Program

	Proposed

vs.

Current Program



VOC	84.57	73.61	73.78	10.96	10.79	-0.17	0.23%	98.4%

NOx	241.1	224.7	224.0	16.4	17.0	0.6	0.27%	103.7%

CO	1224.9	1002.1	1003.7	222.9	221.3	-1.6	0.16%	99.3%



Table 4 shows that the program’s slight increase in VOC emissions
modeled for 2009 over those that would have been expected from
continuing the previous program will disappear beginning in 2010, when
the emissions benefits of the annual OBD program are projected to go
beyond those of the previous program with biennial transient testing.

Table 4

Detailed Comparison of Emissions for 2010

Emissions from Programs	Benefit from Programs	Differences between
Programs



2010	No IM Program

(tpsd)

	Previous Program

(tpsd)

	New Program

(tpsd)

	Benefit Previous Program

(tpsd)

	Benefit 

New

Program

(tpsd)

	Delta

Between

Benefits

(tpsd)

	Delta

vs.

Previous Program

	New 

vs. 

Previous Program



VOC	77.98	67.18	66.87	10.81	11.11	0.31	0.46%	102.8%

NOx	213.0	196.5	195.4	16.5	17.7	1.1	0.56%	106.9%

CO	1160.0	938.6	932.0	221.4	228.0	6.6	0.70%	103.0%



In addition, Table 2 and its associated graph, Figure 1, show that the
emissions of NOx and VOC under the IM program will continue to remain
below the emissions of the previous IM program through 2018, helping
Massachusetts to attain the ozone standard over time.  While the
difference between the two programs decreases somewhat after 2011,
please note that MOBILE6 does not allow for any credit from the OBD
emissions testing of light-, medium-, and heavy-duty diesel vehicles
that has already begun phase-in.

3.0	Network Type and Program Evaluation (51.353)

3.1 Massachusetts’ IM Program Meeting Federal SIP Requirements

Since 1983, the program has relied on a decentralized network of
inspection stations that are licensed by RMV to conduct safety and
emissions tests.  Most Massachusetts vehicles receive their inspections
at local public stations.  The program also allows owners of vehicle
fleets to purchase testing equipment so they can test their own
vehicles.  Under the new regulations, the IM program will continue to
deliver inspections through a decentralized network of local inspection
stations.  

The IM program contract requires Parsons to institute an evaluation
program consistent with EPA regulations.  Data are collected as part of
the regular data collection system during routine testing.  MassDEP and
the RMV will audit this process, analyze the results, and report this
information to EPA, as required.

MassDEP and RMV conduct IM program evaluations through an ongoing
process to quantify emission reduction benefits.  The evaluation is
based on data provided by Parsons and indicates whether the program is
meeting the emission reduction targets.  Program evaluation results have
been reported to EPA on an annual basis, beginning with the year 2000. 
The raw evaluation test data will also be made available to EPA.  The
annual and biennial reports for the Massachusetts Inspection and
Maintenance Program can be found at:    HYPERLINK
"http://massvehiclecheck.state.ma.us/about_publications.html" 
http://massvehiclecheck.state.ma.us/about_publications.html . 

3.2 Applicable Documentation for the Massachusetts IM Program

Authority for the Commissioner of the Department of Environmental
Protection to promulgate 310 CMR 60.02 is found at M.G.L. c.111, §142M
and G.L. c.21A, §§2(28) and 16.   310 CMR 60.02 establishes emissions
inspection requirements for vehicles in the Commonwealth.  As required
by 40 CFR 51.366, the contractor prepares and submits, in a form
satisfactory to the Agencies, data for the annual and biennial program
reports. 

4.0	Adequate Tools and Resources (51.354)

4.1 Massachusetts IM Program Meeting Federal SIP Requirements

States are required to document that adequate fees are collected to
support the IM programs according to 40 CFR 51.354.  The Massachusetts
Motor Vehicle Emissions Inspection and Maintenance Program fee is
currently set at twenty-nine dollars ($29.00) for an annual combined
emission and safety test.  The money collected from the inspection fees
is set aside in a separate Commonwealth fund known as the Motor Vehicle
Inspection Trust Fund (IM Trust).  MGL c.10, section 61 established the
IM Trust to be used solely for the purposes of the administration and
implementation of the IM program.

Under the current IM program, $20.50 of the $29 inspection fee is
retained by the inspection station with the rest deposited by Parsons
into the state’s Motor Vehicle Inspection Trust Fund.  The RMV then
pays Parsons $1.74 from the IM Trust for each inspection and the
remaining money is used to pay for MassDEP and RMV IM program staff and
other IM program needs.  

In FY 08 (under the previous IM program contract), the IM Trust acquired
approximately $39.9 million dollars in revenue from inspection fees
which was utilized to support overall program costs covering necessary
equipment and personnel expenditures.

Massachusetts commits to maintaining an adequate staff dedicated to
overt and covert auditing, data analysis, program administration,
enforcement, and the other necessary program functions.

4.2 Applicable Documentation for the Massachusetts IM Program

MGL c.10, section 61 established the IM Trust to be used solely for the
purposes of the administration and implementation of the IM program. 
Pursuant to MGL c. 90, Section 7A, the Secretary of Administration and
Finance establishes the inspection fee to be charged for the IM program
emission and safety test.  The inspection fee to the motorist is $29.   

Appendix 7 contains budget information for the Massachusetts IM program.
 The budget contains the costs for oversight purposes and demonstrates
that the program will maintain the funds to cover the costs of necessary
administrative resources for several years.  

5.0	Test Frequency and Convenience (51.355)

5.1 Massachusetts IM Program Meeting Federal SIP Requirements

Under the current program, OBD-equipped vehicles in Massachusetts now
receive an annual OBD emissions test.  Vehicles become exempt when they
are 15 years old through a rolling 15 year exemption.  Opacity testing
requirements have been retained for 1984 and newer diesel vehicles over
10,000 pounds GVWR that do not have OBD systems.  Opacity testing is
also required on an annual basis under the new program, however opacity
testing has been delayed until Summer 2009 to ensure proper test
equipment operation.  In addition, emissions tests are also required
upon a change of ownership.

There are approximately 1,600 public inspection stations located
throughout Massachusetts in order to provide motorists convenient
service as required by 40 CFR 51.355.  The contract requires Parsons to
develop a plan to recruit inspection stations to participate in the
program if directed to do so by MassDEP and the RMV.  The purpose of the
plan is to ensure that public inspection stations for all vehicle
classes are sufficiently numerous and dispersed, as determined by
MassDEP and the RMV.  The plan shall include recruiting provisions for
any areas identified by MassDEP and the RMV as underserved.

5.2 Applicable Documentation for the Massachusetts IM Program

310 CMR 60.02 established annual inspections for OBD and opacity
emissions tests.  The contract with Parsons provides additional
documentation on test frequency and convenience.  These documents
demonstrate that the Massachusetts IM program meets the federal
requirements for test frequency and convenience.

6.0	Vehicle Coverage (51.356)

6.1 Massachusetts IM Program Meeting Federal SIP Requirements

As shown in Table 5, OBD-equipped vehicles in Massachusetts will receive
an annual OBD emissions test.  OBD-equipped vehicles become exempt when
they are 15 years old (rolling 15 year exemption).  Opacity testing
requirements have been retained for 1984 and newer diesel vehicles over
10,000 pounds GVWR that do not have OBD systems.

Table 5 below indicates the vehicles in Massachusetts that receive an
OBD emissions test on an annual basis or upon change of ownership under
the current program.

Table 5

Vehicles That Would Receive an OBD Emissions Test

Vehicle Fuel 	Gross Vehicle Weight Rating (GVWR)	OBD Testing Starting
with Model Year

Non-diesel	Light duty: 8,500 pounds or less	1996

Diesel	Light duty: 8,500 pounds or less	1997

Non-diesel	Medium duty: greater than 8,500 and less than or equal to
14,000 pounds	2008

Diesel	Medium duty: greater than 8,500 and less than or equal to 14,000
pounds	2007

All	Heavy duty: greater than 14,000 pounds	Phased in as OBD systems are
required to be installed, starting with model year 2010 



The following requirements also apply to OBD-equipped vehicles: 

Vehicles that fail the emissions test because the malfunction indicator
light (MIL) is commanded on by the OBD system receive a MIL-on bulb
check to verify the MIL is functioning.

When an emissions inspection indicates that a vehicle’s emission
control system has been tampered with or otherwise altered so that a
complete test cannot be performed, the motorist is required to present
their vehicle to a location designated by MassDEP to resolve the issue. 
 

Heavy-duty diesel vehicles not otherwise subject to an OBD test will
continue to be subject to an annual snap acceleration smoke test, based
on the test specified by SAE J1667, as shown in Table 6 below.

Table 6

Vehicles That Would Receive an Opacity Test

Vehicle Fuel 	Gross Vehicle Weight Rating (GVWR)	Opacity Testing
Starting with Model Year

Diesel – registered in MA	Vehicles 10,000 pounds or more	1984

Diesel – registered in any state or country that operate in
Massachusetts	Vehicles 10,000 pounds or more	All vehicles



In addition, the following vehicles are also subject to an annual
emissions test in the Commonwealth if they are of the vehicle types
shown in Tables 5 and 6:

Vehicles that are operated by a federal installation within
Massachusetts for more than sixty (60) days per year;

Vehicles that are registered to a federal employee stationed at a
federal installation within Massachusetts for longer than sixty (60)
days per year regardless of whether the vehicle is registered in
Massachusetts; and

Vehicles that are registered in another state or Canadian province or
territory requiring a reciprocal emissions inspection in Massachusetts. 


Tables showing the total vehicles tested and exempt by vehicle class are
in Appendix 8.  

Provisions governing engine-switching were revised to reflect EPA
requirements, to ensure that replacement engines are appropriate for the
vehicle in which they are installed, and to maintain the vehicle’s
emissions characteristics.  Definitions and other provisions were
revised to address assembled and reconstructed vehicles, gray market
vehicles, specialty import vehicles, and vehicles that have been issued
exemptions by EPA or California Air Resources Board (CARB).

Vehicles registered in the Commonwealth of Massachusetts that are
primarily operated in another IM area are required to document their
status using the “Out of State Verification Emissions” form ( 
HYPERLINK "http://www.mass.gov/rmv/forms/21307.pdf" 
http://www.mass.gov/rmv/forms/21307.pdf ) to certify that the vehicle
has passed the inspection required by the jurisdiction in which the
vehicle is currently domiciled or that the jurisdiction in which the
above vehicle or equipment is currently domiciled lacks an inspection
program or does not inspect vehicles registered in other jurisdictions. 
Within fifteen (15) days of being returned to the Commonwealth of
Massachusetts, the vehicle or equipment identified on this form must
have a vehicle inspection performed by a Massachusetts vehicle
inspection station, as required by law. This requirement holds even if
the vehicle bears an inspection sticker that is still valid in another
state.

6.2 Applicable Documentation for the Massachusetts IM Program

310 CMR 60.02 and the contract with Parsons provide the necessary
documentation to demonstrate that the Massachusetts IM program meets
federal requirements for vehicle coverage.

7.0	Test Procedure and Standards (51.357)

7.1 Massachusetts IM Program Meeting Federal SIP Requirements

All vehicles subject to the OBD test are tested using the procedures
established by 310 CMR 60.02.  These procedures are based on the test
procedures established by EPA for light duty vehicles in 40 CFR 85.222,
and are generally consistent with EPA’s guidance document,
“Performing Onboard Diagnostic System Checks as Part of a Vehicle
Inspection and Maintenance Program” (June 2001).  

The three areas where the MassDEP procedures vary from EPA’s
procedures are the bulb check, readiness, and communication failures. 
For the bulb check, MassDEP’s procedures require the bulb be verified
as illuminated when commanded on by the OBD system (key-on/engine
running, KOER).  This will prevent false failures associated with the
key-on/engine-off (KOEO) bulb check.  Vehicles that fail the KOER bulb
check must pass a KOEO or KOER bulb check when reinspected, as no
waivers are issued for bulb check failures.  

For readiness, MassDEP’s procedures require that a vehicle fail its
initial test if it would otherwise pass but does not meet readiness
criteria.  A vehicle that would otherwise pass but does not meet
readiness criteria will not fail its retest, but will be turned away
from reinspection:  a vehicle that does not meet readiness criteria when
presented for its retest is considered to not have received a retest.  A
vehicle must still pass an emissions test or receive a waiver within 60
days of the initial emissions test failure, even if the initial test
failure was for readiness.  This is necessary to preserve the
motorist’s right to one free retest following the initial inspection
failure, whether for safety, emissions, or both.  

Also, Massachusetts requires that vehicles failing their initial test
due to a diagnostic trouble code (DTC) for catalytic converter
efficiency must have the catalytic converter monitor “Ready” before
allowing a retest.  This requirement was established to verify that
catalytic converter repairs were effective, and to provide consumer
protection against improper or ineffective catalytic converter repairs. 


Massachusetts will use alternative test procedures where routine test
procedures cannot be applied.  The alternative test procedures may
exclude a vehicle from readiness requirements, or may subject the
vehicle to only a visual bulb check.  These alternative test procedures
would only be implemented where a systemic problem with the test
equipment (not a maintenance problem) or with a vehicle or group of
vehicles prevents them from completing the normal emissions test
procedures.  

As part of the IM program evaluation, MassDEP, in partnership with the
RMV, will identify additional vehicle models that are not currently
exempted from readiness by Appendix D of the guidance document but have
20% or greater not ready rates.  Including these vehicles on the EPA
readiness exemption list for OBD testing is consistent with the intent
of Appendix D.  MassDEP will provide EPA with an updated list of
vehicles having readiness issues in subsequent program evaluation
reports.  MassDEP, RMV and EPA recognize the importance of maintaining
an updated list of vehicles identified as having readiness issues as an
important tool to provide the operational flexibility needed in state IM
programs.  Vehicles excluded from readiness would still receive a check
of the OBD system to determine whether the MIL has been commanded on.  

For communication failures, Massachusetts has added a provision to the
testing procedures that requires the inspector to conduct a
“loopback” check of the OBD test equipment.  The inspector inserts
the diagnostic link connector into a receptacle in the test equipment to
check the integrity of the test cable/system.  If there is a problem
with the cable or test system that is preventing the vehicle from
communicating with the workstation, the test is aborted.  This prevents
the vehicle from falsely failing the emissions test due to an
equipment-related problem.  

Where systemic problems with the test equipment prevent the equipment
from completing the emissions test, or where problems with a vehicle or
group of vehicles (e.g., all of one year/make/model, or all of a
manufacturer’s model year) prevent completion of the normal emissions
test procedures, MassDEP will cause the vehicles to receive only a
visual bulb check to determine pass/fail.  

In cases where there is a systemic problem with the test equipment, the
visual bulb check will continue only until the problem with the test
equipment is corrected.  It is anticipated that this would be used
during equipment rollout, or where an upgrade to the equipment or
equipment software caused the equipment to no longer function as
designed.  Once the correction is implemented, normal testing would
resume.  

In cases where there is a problem with a vehicle (e.g., specific
year/make/model) or group of vehicles (e.g., all of one manufacturer’s
model year), including problems subject to recall but the recall has not
been completed, the alternative test would continue until the problem is
corrected by the manufacturer.  

The alternative test procedures are designed to allow quick operational
adjustments to provide MassDEP and its contractor, the vehicle
manufacturer, or the vehicle owner time to resolve unanticipated
problems associated with the emissions test, but still identify vehicles
in need of repair because the MIL is illuminated.  This is particularly
important in Massachusetts because vehicles are subject to emissions
testing when one year old.  As a result, any OBD performance or testing
issues are likely to surface here before any other area, and operational
adjustments to test procedures will be necessary for the program to
remain acceptable to the public.  

Opacity testing procedures established by 310 CMR 60.02 will still be
based on the procedures established by SAE J1667, but are being modified
by MassDEP to permit certain fast-pass algorithms, to address testing
issues where the bandwidth or zero drift requirements of J1667 preclude
completion of testing for a vehicle that obviously meets or exceeds the
standards, and to incorporate new test equipment designed prevent
fraudulent emissions testing.  

Glider kits (vehicles weighing more than 10,000 pounds with a different
vehicle body placed upon the original chassis) are required to have a
visual inspection when they are first registered to verify that they
were assembled consistently with their configuration certified by EPA or
the California Air Resources Board (CARB).  Some glider kits may be
subject to an opacity test, based on the model year of the chassis.  

Kit vehicles (unique or replica vehicles with production volume less
than 500 vehicles per year) are required to have a visual inspection
when they are first registered and upon change of ownership to verify
that they comply with applicable emission control requirements.  This is
consistent with EPA’s policy on kit vehicles.  A list of the
documentation that must be provided for the kit vehicle visual
inspection will be posted on the Enhanced Emissions and Safety Test
Program web site.  If the kit vehicle is constructed using a certified
configuration subject to OBD testing, the kit vehicle will be subject to
OBD testing consistent with the model year of the donor vehicle.  

7.2 Applicable Documentation for the Massachusetts IM Program

The inspector shall perform emissions inspections in accordance with 310
CMR 60.02 and all MassDEP-approved inspection procedures, including all
workstation software prompts, at inspection stations licensed by the
RMV.

8.0	Test Equipment (51.358)

8.1 Massachusetts IM Program Meeting Federal SIP Requirements

The IM contract requires written test equipment specifications.  Each
inspection station is equipped with the necessary equipment for OBD
inspections.  Inspection stations licensed to inspect vehicles over
10,000 GVWR are also equipped to conduct opacity tests.

All test equipment is fully computerized and all processes are automated
to the highest degree possible.  All computerized equipment has lock out
features to prevent tampering by unauthorized personnel.  Parsons’
Field Service Representatives and RMV Field Investigators have
authorization to clear lock-outs or access the hardware locally or
remotely for any purpose other than to perform an emissions test and
shall be required to enter an access code that identifies them
personally in order to do so.  Test equipment is linked on a real-time
basis to a central computer.  All electronic system integrity checks are
performed automatically.  

The Commonwealth or Parsons maintains emissions test equipment to
accommodate new technology and changes to the program.  The test
equipment provides the motorist with a test record, including the
reasons for any test failure, and the name of the inspection station and
the inspector performing the test.  Also, if the vehicle is turned away
from testing, the reason for the turnaway is included in the record. 

8.2 Applicable Documentation for the Massachusetts IM Program

Test equipment standards are included in the contract and meet the
requirements of the OBD and opacity testing procedures. 

9.0	Quality Control (51.359)

9.1 Massachusetts IM Program Meeting Federal SIP Requirements

The Commonwealth has taken all steps necessary to meet the applicable IM
performance standard while ensuring that motorists receive consistent
and accurate test results.  The contract directs Parsons to employ
reliable equipment, accurate and complete maintenance operating
procedures, adequate spare parts provisioning, and a competent
operations and maintenance staff.  

The contract contains the specifications to be used for all testing
equipment approved for use in the IM program.  These specifications
include minimum durability and functional requirements to ensure
accurate measurement, processing, and recording of test samples under a
wide range of adverse ambient conditions.  

Massachusetts has added a provision to the testing procedures that
requires the inspector to conduct a “loopback” check of the OBD test
equipment.  The inspector inserts the diagnostic link connector into a
receptacle in the test equipment to check the integrity of the test
cable/system.  If there is a problem with the cable or test system that
is preventing the vehicle from communicating with the workstation, the
test is aborted.  This prevents the vehicle from falsely failing the
emissions test due to an equipment-related problem.  In addition, the
contract requires the development of performance specifications for the
opacity test equipment.  MassDEP is developing these in conjunction with
Parsons to ensure appropriate equipment calibration requirements.

Measures have been taken to maintain the security of all documents such
as inspection stickers, waiver certificates and hardship extensions. 
Stickers include a unique two-dimensional bar code that contains
relevant vehicle and inspection information.  A strict accounting system
has been created to track all sticker stock including any lost, voided
or stolen stickers.

9.2 Applicable Documentation for the Massachusetts IM Program

310 CMR 60.02, the contract with Parsons, and the OBD test procedures
address quality control by requiring that all equipment and
instrumentation be maintained in accordance with standards provided in
40 CFR 51.358.  In addition, performance specifications are being
developed for the opacity test equipment.  Such equipment is subject to
both scheduled and unscheduled checks for accuracy and condition by
MassDEP and RMV staff.  

Document security mandated by 40 CFR 51.359 is implemented pursuant to
the requirements of the contract with Parsons.  Specific details
concerning document security have been omitted from this submittal to
ensure that such procedures do not become public knowledge.  

10.0	  Waivers and Compliance via Diagnostic Inspection (51.360)

10.1 Massachusetts IM Program Meeting Federal SIP Requirements

The current waiver rate of less than 0.1% of vehicles failing an initial
OBD test demonstrates that the IM program meets the applicable
performance standard of less than one percent of all initially failed
vehicles.  If the waiver rate reported to EPA in the annual report
exceeds this rate, MassDEP will take corrective actions. 

In Massachusetts, Parsons, as a designee of MassDEP and the RMV, is
primarily responsible for issuing waivers.  Parsons, through a network
of Motorist Assistance Centers, will: 

review repair receipts from a certified repair station to verify that
the appropriate expenditures have been made; 

verify that only repairs germane to the test failure have been claimed; 

and verify that repairs have actually been made by visually inspecting
the vehicle and determine whether the vehicle is eligible for warranty
repairs before issuing a waiver. 

MassDEP and the RMV serve as the arbiter for disputes between the
motorist and Parsons regarding waiver eligibility.

The waiver criteria, requirements and expenditure thresholds for waiver
eligibility have been changed to reflect the following: 

The expenditure thresholds for waiver eligibility was increased, based
on increases in the Consumer Price Index since the thresholds were
originally established in 1989;  

A three-tiered waiver cost threshold based on the age of the vehicle
will continue to be used to consider a vehicle for a waiver when repair
costs exceed certain amounts;

Starting in 2010, the new waiver expenditure thresholds will be adjusted
annually, based on the changes in the Consumer Price Index;

Eligibility criteria was updated to reflect factors that the program has
been using to determine waiver eligibility for OBD equipped vehicles;

Costs associated with certain repairs that are in conflict with the
goals of the IM program are ineligible for consideration towards the
waiver cost limit; 

Only private passenger vehicles are eligible for a waiver.

An Economic Hardship Failure Repair Extension allows a one year
extension of the requirement to pass an emissions test, for certain
non-commercial OBD vehicles.  The extension is valid until the
vehicle’s next inspection and will not be eligible for renewal.  A
vehicle receiving an extension is required to pass its next emissions
test.  No extensions will be given for inspections associated with a
change of ownership.

Given the waiver rate commitment, the substantial increase in wavier
cost thresholds, the annual CPI adjustment to waiver cost thresholds,
the prohibition on waivers for commercial vehicles, and the prohibition
on waivers for vehicles with certain high-emitting characteristics, the
proposed waiver provisions are at least as effective as EPA’s
requirements.  

10.2 Applicable Documentation for the Massachusetts IM Program

310 CMR 60.02 provide for emission waivers and economic hardship failure
repair extensions.  This allows MassDEP to grant emissions waivers for
vehicles which fail the emissions inspection and require an
"unreasonable cost of repair" to bring the vehicles into compliance.  

11.0	  Motorist Compliance Enforcement (51.361)

11.1 Massachusetts IM Program Meeting Federal SIP Requirements

The RMV will implement an effective form of motorist compliance through
a registration suspension program.  

In general, the registration suspension enforcement program will work as
follows: 

An "Inspection Required" event will be noted in the Massachusetts
Registry of Motor Vehicles' Automated Licensing and Registration System
(ALARS) for a vehicle for ownership changes or new registrations, a
failure to pass inspection, or when an inspection sticker expires, all
of which trigger a need for an inspection or a reinspection;

Following an “Inspection Required” event, an "Enforcement Event"
will be created in ALARS;

Thirty days after the "Enforcement Event," a "Warning Letter" will be
issued notifying the registered owner that a suspension will be imposed
on the non-compliant vehicle unless compliance with the emissions
inspection requirements are obtained;

Thirty days after the "Warning Letter" is issued, the registration
suspension will be imposed. 

The registration suspension can only be removed after compliance with
the inspection requirements and payment of a reinstatement fee.  

The only variance from the suspension enforcement program will occur if
it is determined that an unreasonable number of registered vehicles are
being misidentified as requiring an inspection, when in fact the
vehicles have met the inspection requirements. To avoid suspending
registrations of compliant vehicles unreasonably and without cause, the
registrar reserves the right to place the enforcement program in
suspension until the problem causing the misidentified vehicles has been
identified and corrected. 

11.2 Applicable Documentation for the Massachusetts IM Program

In Massachusetts, IM registration enforcement is provided for in 540 CMR
4.01.   This allows the Registrar of Motor Vehicles to suspend the
registration of non-complying vehicles failing to meet the requirements
of the safety and emissions test. 

12.0	  Motorist Compliance Enforcement Program Oversight (51.362)

12.1 Massachusetts IM Program Meeting Federal SIP Requirements

MassDEP and the RMV will permit EPA to conduct periodic audits of the
state's IM enforcement program.

12.2 Applicable Documentation for the Massachusetts IM Program

The legal authority for the implementation of the IM program is M.G.L c
111, Section 142 M.  This law provides authority to MassDEP and the RMV
to enter into a contract to provide for program oversight elements.  

The contract meets the extensive and complex data control requirements
required by EPA’s IM program regulations to enable efficient oversight
of the motorist compliance enforcement program.  

13.0	  Quality Assurance (51.363)

13.1 Massachusetts IM Program Meeting Federal SIP Requirements

The program’s quality assurance program consists of overt and covert
performance audits, digital audits on station and inspector performance,
and equipment audits.  

In accordance with 40 CFR 51.363, the Massachusetts program performs
overt and covert performance audits.  Overt and covert audits include
sufficient record keeping to support the imposition of enforcement
actions based on audit findings.  RMV IM program staff will continue to
perform the overt audits on the inspection stations and will also
perform the equipment audit on the workstations.  RMV auditors shall be
familiarized with applicable quality assurance procedures.

Overt audits will include: a check of document security; record keeping
practices, certifications and required display information; observation
and written evaluation of each inspector's ability to perform the test
procedure; and a quality control evaluation of test equipment.  Test
records are reviewed electronically once a month and by workstation to
flag statistically inconsistent or improbable results.

Parsons will perform the covert visual and vehicle audits.  They will
perform 889 covert visual audits during the 12 month period beginning
October 1, 2008 and 1778 covert visual audits per 12 month period for
the subsequent four 12 month periods beginning October 1, 2009, during
times of the year that stations are likely to perform inspections that
can be observed from outside the station.  Parsons will perform 667
covert vehicle audits for the 12 month period beginning October 1, 2008
and 1333 covert vehicle audits per 12 month period for the subsequent
four 12 month periods beginning October 1, 2009.  Parsons will be
responsible for procuring and preparing the covert audit vehicles, and
performing and documenting the audit.  The number and type of vehicles
will be sufficient to cover all OBD communication protocols, and a
variety of weight classes.  Covert auditors will be trained in
accordance with procedures identified in the Covert Operations Manual.

MassDEP, RMV and Parsons will develop a comprehensive set of trigger
reports to identify workstations performing fraudulent or inaccurate
inspections.  Trigger reports focus on finding the types of fraud in an
OBD testing program including Clean Scanning (performing an OBD test on
a fault-free vehicle instead of the vehicle that should be tested) and
other forms of fraud as they are discovered.  These reports will be
generated daily and/or weekly to identify workstations performing
improper inspections.  Results will be shared with MassDEP and the RMV
on a regular schedule.

13.2 Massachusetts IM Program Meeting Federal SIP Requirements

The contract with Parsons addresses quality assurance items mentioned
above.  Document security mandated by 40 CFR 51.359 is implemented
pursuant to the requirements of the contract with Parsons.  Specific
details concerning document security have been omitted from this
submittal to ensure that such procedures do not become public knowledge.
 

14.0	  Enforcement against Contractors, Stations and Inspectors (51.364)

14.1 Massachusetts IM Program Meeting Federal SIP Requirements

MassDEP and the RMV have authority to take enforcement actions against
stations and inspectors.   All records of enforcement activities,
including warnings, fines, suspensions, revocations, and other notices
of violation will be maintained.

The RMV is in charge of station and inspector licensing.  540 CMR 4.00
allows the Registrar to suspend, revoke, deny or refuse to renew a
license to an inspector or station.  Retraining may also be required.

In the case of inspector incompetence, the inspector, if not discharged,
is required to be retrained and must successfully demonstrate the
ability to perform the test procedure prior to the restoration of
testing privileges.  For cases of inspector violations resulting from
factors other than incompetence, the inspector shall, at a minimum, be
suspended from testing for a period of time.  Such suspensions shall
increase with the severity and frequency of violation, leading
ultimately to permanent certification revocation and enforcement action.

Auditors are authorized to temporarily suspend a workstation or test
inspector upon finding a violation of program requirements or equipment
failure.  

14.2 Applicable Documentation for the Massachusetts IM Program

The Department may impose a penalty against an inspection station for
any violation of 310 CMR 60.02 at that inspection station. The
Department may impose a penalty against any person for any violation of
310 CMR 60.02.  Any person who violates any provision of G.L. c.111,
§142M or 310 CMR 60.02 shall be subject to a civil or administrative
penalty or fine or imprisonment pursuant to G.L. c.111, §142M and
c.21A, §16.  Each day or portion thereof on which a violation occurs or
continues shall be deemed a separate violation.   Whenever the
Department seeks to assess a civil administrative penalty pursuant to
G.L. c.21A, §16, G.L. c.111, §142M and 310 CMR 60.02, the person who
would be assessed the penalty shall have the right to an adjudicatory
hearing.  Any request for an adjudicatory hearing thereon shall be made
in accordance with G.L. c.21A, §16, and 310 CMR 5.00.   Appendix 3
contains the full text.

15.0	  Data Collection (51.365)

15.1 Massachusetts IM Program Meeting Federal SIP Requirements

Massachusetts’ IM program data management is collected and managed by
Parsons while the Commonwealth of Massachusetts owns the data.

All data and reporting requirements are collected and retained within
the Vehicle Inspection Database (VID).  VID data collected include, but
are not limited to: test record number; inspection workstation number;
inspector identification number; date of the test; emission test start
time; the time final emission pass/fail is determined; vehicle
identification number; license plate number; test certificate number;
GVWR; model year, make and vehicle type of each vehicle tested; number
of cylinders/engine displacement and transmission type for transient
emission tests; odometer reading; category of test performed, (i.e.,
initial, first or second re-test); vehicle fuel type; type of
preconditioning performed, if applicable; emission test sequences used;
emission malfunction codes; or the results of an alternative test as
approved by the EPA Administrator.

In order to ensure collection of accurate data, the contract directs
Parsons to perform major upgrades in their current VID systems.  This
could include upgrading both hardware and software to state of the art,
if such update is required to maintain the performance and functionality
of the VID system, or any component thereof.

15.2 Applicable Documentation for the Massachusetts IM Program

Pursuant to the contract with Parsons, MassDEP and the RMV are
authorized to require summary reports and documentation regarding
emission inspections and program reporting requirements.  The contract
directs Parsons to meet the requirements of 40 CFR 51.365 and all other
data collection and reporting requirements imposed by EPA.

16.0	  Data Analysis and Reporting (51.366)

16.1 Massachusetts IM Program Meeting Federal SIP Requirements

MassDEP and the RMV, in cooperation with Parsons, will submit to EPA,
reports containing summary data based upon program activities taking
place in the previous test cycles.  These reports will provide
statistics for the testing program, the quality control program, the
quality assurance program, and the enforcement program.

MassDEP and the RMV will report on all changes made in the program
design, funding, personnel levels, procedures, regulations, and legal
authority.  The reports will also detail and discuss any weakness or
problems discovered in the program over the previous year.  In addition
the reports will discuss the steps that were taken to address those
problems, the result of any corrective actions, and any future efforts
planned.  The reports must meet the timeframes and contain all the
information required by 40 CFR 51.366.

16.2 Applicable Documentation for the Massachusetts IM Program

The contract requires data analysis and reporting to allow for
monitoring and evaluation of the program.  This reporting requirement is
the responsibility of Parsons.  The reporting requirement shall be a
component of a QA/QC Plan within the contract.  Parsons is required to
communicate the required data to MassDEP and the RMV.

17.0	  Inspector Training and Certification (51.367)

17.1 Massachusetts IM Program Meeting Federal SIP Requirements

All program inspectors receive MassDEP-approved training.  They are then
certified by MassDEP and licensed by the RMV to perform inspections. 
Inspectors are required to receive recertification training every two
years prior to renewal of certification.  Inspectors must apply annually
to RMV to renew their license to perform inspections.  MassDEP may
require inspectors to obtain additional training and pass additional
exams prior to renewing their certifications if it determines that such
training and examinations are necessary to accommodate changes in the
test equipment, changes in test procedures, or other changes in the IM
program.  

Parsons trains the inspectors and tracks the inspector certifications. 
Training includes all of the elements required by 40 CFR 51.367. 
Inspector candidates will not be certified unless they have passed a
written test.  The contract requires Parsons to prepare and submit an
inspector training plan for MassDEP and RMV review and approval.

17.2 Applicable Documentation for the Massachusetts IM Program

MassDEP and the RMV have adopted administrative regulations for the IM
program that include inspector training and certification requirements
at 310 CMR 60.02 and 540 CMR 4.00.  The contract requires Parsons to
prepare and submit an inspector training plan for MassDEP and RMV review
and approval.

18.0	  Public Information and Consumer Protection (51.368)

18.1 Massachusetts IM Program Meeting Federal SIP Requirements

Communication with motorists will occur throughout the duration of the
program to ensure that vehicle owners have the information they need to
comply with program requirements and to address their questions and
complaints effectively and efficiently.  

The program web site is designed to provide basic program information to
motorists, the general public, inspectors, and repair technicians.  It
also provides specific information to inspectors and repair technicians
that will facilitate their work in the program.  The web site provides
the public and industry audiences with ready access to program
regulations, reports, information on program changes and new components,
and other information deemed useful to its audiences.  Parsons also
maintains an inspection station locator which allows motorists to search
for an inspection station and a ‘vehicle failure trend lookup’ on
the program website.

“Point of Sale” collateral material has been designed, produced, and
distributed to provide motorists with information concerning the
inspection process and registration suspensions.  The Vehicle Inspection
Report (VIR) provided to the motorist at the end of the inspection shows
the possible causes of emissions failures and provides the motorist with
a list of the ten closest registered repair facilities.

Parsons is responsible for responding to motorists' general questions
and concerns regarding the program quickly and effectively through a
telephone hotline and electronically via the website.  All calls and
emails are managed, tracked, and analyzed.  

The Massachusetts IM program also contains a challenge mechanism by
which a vehicle owner can contest the results of an inspection. ( 
HYPERLINK "http://www.mass.gov/rmv/forms/21413.pdf" 
http://www.mass.gov/rmv/forms/21413.pdf )

18.2 Applicable Documentation for the Massachusetts IM Program

The public education and consumer protection program elements outlined
in and implemented by the program contract provided in Appendix 1.  The
Massachusetts IM program website can be found at   HYPERLINK
"http://massvehiclecheck.state.ma.us/" 
http://massvehiclecheck.state.ma.us/ .

19.0	  Improving Repair Effectiveness (51.369)

19.1 Massachusetts IM Program Meeting Federal SIP Requirements

MassDEP agrees that effective repairs are the key to achieving program
goals and will take steps to ensure the capability exists in the repair
industry to repair vehicles that fail IM tests.  The program maintains
an existing list of registered repairers and is working with Parsons to
revise and update the training to meet the requirements of the new
program. 

Parsons is collecting information on emissions repairs made on failed
vehicles prior to (or at the time of) re-inspection.  They are
developing forms that make data entry by registered repairers easy on
line and to help ensure the quality of repair information.  This
information will identify the technician, the shop that performed the
repairs and the cost of repairs (cost information will be for agency use
only).  In those cases where the emissions repair information was not
entered on line prior to re-inspection, the workstation software will
automatically prompt the inspector to enter emissions repair
information, regardless of whether the repairs were performed by a
registered repairer.  The workstation will send the emissions repair
information to the database. 

Parsons is working with the MassDEP to revise and improve an emissions
repair index for the listed repair shops (revisions to the current
five-star rating system).  The index will rate most highly the shops
with the greatest success at repairing vehicles.  The index will be
weighted to emphasize improvement in a repair shop’s success rate over
time.  The index will be updated as repair shops provide updates, and
incorporated into the repair shop information in the database.  

Parsons maintains a directory of the ten closest registered repair shops
to each inspection station, including their emissions repair indices. 
That list is provided to each motorist whose vehicle fails the emissions
test when the workstation automatically generates this directory when
printing an emissions failure report. A motorist, using the program
website is also able to access a directory of registered repair shops in
any queried municipality of the Commonwealth.

Parsons will provide convenient means for registered emissions repair
technicians to bring problems, questions, and suggestions concerning any
aspect of the program to their attention for resolution in a timely
manner. Such means include (but are not limited to): a telephone
hotline; a quarterly newsletter; and the program web site.   Parsons
will take steps to inform inspectors and technicians about the resources
available to them, including training, registration, Motorist Assistance
Centers, the hotline, and the newsletter.

19.2 Applicable Documentation of the Massachusetts IM Program

MassDEP’s IM program regulations include requirements for becoming a
registered repair technician at 310 CMR 60.02.  The contract requires
Parsons to prepare and submit a registered repairer training plan for
MassDEP review and approval.  A current list of registered repair shops
in the Commonwealth can be found on the program’s website.

20.0	  Compliance with Recall Notices (51.370)

20.1 Massachusetts IM Program Meeting Federal SIP Requirements

MassDEP reiterates its commitment to pursue compliance with EPA’s
recall requirements as soon as EPA establishes the national database for
accessing unresolved recall information based on VINs.  It is our
understanding that access to this information will be free of charge to
states and motorists.  In the interim, the program website currently
provides information on emissions and safety recalls of an advisory
nature to inspectors, repair technicians and motorists based on
Technical Service Bulletins and other readily available databases for
information.

20.2 Applicable Documentation for the Massachusetts IM Program

The contract with Parsons and the program’s website provide the
necessary documentation to demonstrate Massachusetts’ commitment to
this requirement.

21.0	  On-Road Testing (51.371)

21.1 Massachusetts IM Program Meeting Federal SIP Requirements

The use of remote sensing or road side emissions measurement is not an
accurate way to determine if OBD systems are operating correctly.  The
contract with Parsons includes the option for pilot testing of remote
emissions testing technologies when these technologies are demonstrated
to be reliable.

21.2 Applicable Documentation for the Massachusetts IM Program

The contract includes the option for pilot testing of remote emissions
testing technologies when these technologies are demonstrated to be
reliable.

 Appendix 1

 Appendix 3

 Appendix 4, submitted in electronic format

 Appendix 5, submitted in electronic format

 Appendix 6

  Appendix 1

 Appendix 3

 The Covert Operations Manual is an enforcement sensitive document and
as such has not been included as an appendix to this submittal.

 http://massvehiclecheck.state.ma.us/find_emissions_repair.html

MA SIP Revision: Table of Contents Item 7 – Documentation of IM SIP
Revision consistent with 42 USC Section 7511a and Section 182 (c)(3)(A)
of the Clean Air Act

 PAGE   

 PAGE   i 

 PAGE  2 

