  SEQ CHAPTER \h \r 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

5 Post Office Square, Suite 100

Boston, MA  02109-3912

Memorandum

Date: 		October 24, 2012

	

Subject: 	Technical Support Document for Approval of the Massachusetts
Vehicle Inspection and Maintenance (I/M) Program and for Approval of the
New Hampshire Vehicle Inspection and Maintenance (I/M) Program

	

To: 		Anne Arnold, Manager

		Air Quality Planning Unit, Office of Ecosystem Protection

From: 		Ariel Garcia, Environmental Engineer

		Air Quality Planning Unit, Office of Ecosystem Protection

This Technical Support Document (TSD) was prepared to support a direct
final rulemaking action to approve State Implementation Plan (SIP)
revisions submitted on June 1, 2009 and November 30, 2009 by the
Commonwealth of Massachusetts and on November 17, 2011 by the State of
New Hampshire.  These SIP revisions include regulations to update the
enhanced motor vehicle inspection and maintenance (I/M) programs in
Massachusetts and New Hampshire.  The Massachusetts I/M program was
previously approved into the SIP on November 15, 2000 (65 FR 68898) and
the New Hampshire I/M program was previously approved into the SIP on
January 10, 2001 (66 FR 1868).  Both state’s programs have since been
revised several times.  Most notably the Massachusetts and New Hampshire
programs have evolved to consist entirely of on-board diagnostic (ODB2)
testing of 1996 and newer vehicles; and neither program utilizes
dynamometers to physically test tail-pipe exhaust emissions.  This TSD
supports approval of the revised programs because the standards and
requirements will strengthen the Massachusetts and New Hampshire SIPs,
and are consistent with EPA I/M requirements at 40 CFR Part 51.

Background

Massachusetts’ I/M program has been in place, in some fashion, since
1983 and consisted of centralized testing facilities.  In 1999,
Massachusetts adopted 310 CMR 60.02, and began testing tailpipe
emissions, on model year 1984 and newer vehicles, by utilizing
dynamometers via a decentralized, mostly, test and repair network, with
some test-only facilities.  In 2004, Massachusetts implemented OBD2
testing of model year 1996 and newer vehicles.  In 2008, Massachusetts
went to an “OBD2-testing only” I/M program, and ceased conducting
tailpipe emissions tests with a dynamometer.  Massachusetts has
implemented a number of changes to its I/M program to ensure the current
program is as effective as the previously implemented program.  The June
1, 2009 SIP revision submitted by Massachusetts demonstrates that the
new “OBD2-testing only” I/M program is more effective than the
pre-existing I/M program.  Another major change in 2008, was
Massachusetts’ shift to emissions testing on an annual basis, where
previously emissions testing had been conducted every two years.  The
Massachusetts I/M program operates statewide and includes OBD2 testing
on the following light-duty (less than or equal to 8,500 pounds  Gross
Vehicle Weight Rating (GVWR)) and heavy-duty (a GVWR of 8,501 pounds or
more) vehicles if they are less than 15 years old:

		

Non-diesel light duty vehicles starting with model year 1996,

Diesel light duty vehicles starting with model year 1997,

Non-diesel heavy-duty vehicles less than or equal to 14,000 pounds GVWR
starting with model year 2008,

Diesel heavy-duty vehicles less than or equal to 14,000 pounds GVWR
starting with model year 2007, and

All heavy-duty vehicles greater than 14,000 pounds GVWR phased in as
OBD2 systems are required to be installed starting with model year 2010.

On January 10, 2001, EPA approved a SIP revision submitted by New
Hampshire for its I/M program, which consisted of: state regulations
incorporating an “anti-tampering” program to the existing Safety
Testing Program, state regulations incorporating a smoke opacity testing
program on heavy-duty trucks, and a commitment for statewide
implementation of OBD2 testing on vehicles required to be equipped with
OBD2 systems.  The anti-tampering program, which began in 1999,
consisted of a visual check for proper connection of emissions control
components on 1980 and newer vehicles.   In late 2006, New Hampshire
began a paper-based OBD2 testing program on vehicles of model year 2002
and newer.  In late 2007, OBD2 testing was expanded to all model year
1996 and newer vehicles.  In 2008, New Hampshire amended its regulation
to create an electronic OBD2 testing I/M program which covers light-duty
vehicles that are model year 1996 and newer, and light-duty diesel
vehicles that are model year 1997 and newer.  New Hampshire continues to
operate an anti-tampering program on vehicles up to 20 years old that
are not subject to an OBD2 inspection.

The Massachusetts and New Hampshire SIP submittals include each
state’s legal authority to perform I/M testing, the state regulations
to implement the programs, MOBILE6 modeling runs, narratives describing
the programs in detail and appendices which include a variety of
information including the contracts to implement the program, details
about the composition of the tested fleet, lists of inspection stations,
among other items.

The attached checklist goes through the required elements of EPA’s I/M
regulation by section in 40 CFR Part 51, and indicates if the States
have met those requirements.  If a response to any of the checklist
items varies for one of the states, it will be noted.

Recommended Action:  I recommend that we approve the SIP revisions
submitted by the Commonwealth of Massachusetts on June 1, 2009 and
November 30, 2009, as well as the SIP revision submitted by the State of
New Hampshire on November 17, 2011.  These SIP revisions update: (1) the
Massachusetts motor vehicle I/M program which is codified in the
Massachusetts Department of Environmental Protection Regulations at 310
CMR 60.02 and the Massachusetts Registry of Motor Vehicle Regulations at
540 CMR 4.00; and (2) the New Hampshire motor vehicle I/M program which
is codified in the New Hampshire Department of Safety Regulations at
Saf-C 3200 and Saf-C 5800.  These motor vehicle I/M programs are
intended to eliminate excess emissions from motor vehicles in
Massachusetts and New Hampshire.     SEQ CHAPTER \h \r 1 I recommend
that EPA approve these programs because they will help reduce emissions
of volatile organic compounds, nitrogen oxides, and carbon monoxide, and
will strengthen the Massachusetts and New Hampshire SIPs.  As shown in
the Attachment, the revised programs are consistent with EPA’s I/M
rule.  Also, Massachusetts and New Hampshire have demonstrated via
MOBILE6 runs that the revised programs meet the federal enhanced
performance standard and achieve greater emission reductions than the
previously approved I/M programs.  

Attachment

Attachment 

.c.§51.350	Applicability

__Y___	A.	Are all required elements present in this portion of the SIP? 


__Y____	1.	Does the SIP describe the areas that are required to
implement I/M? Statewide programs

__Y_______	2.	Does the SIP include legal authority or rules which
establish geographic boundaries for the program?   For Massachusetts at
M.G.L. c.111, sec. 142M and for New Hampshire at RSA 266:1 and RSA
266:59-b.

__Y__	B.	Is this portion of the SIP approvable?

__Y_	1.	Are subject areas required to implement enhanced I/M?  Statewide

__ __	a.	Is enhanced I/M required in all MSAs with a 1990 population of
100,000 or more in an ozone transport region?

__ __	b.	Is enhanced I/M required in all serious or worse ozone areas
with a 1980 urban population of 200,000 or more?

_ ___	c.	Is enhanced I/M required in all carbon monoxide nonattainment
areas with a design value 12.7 ppm or greater and a 1980 urban
population of 200,000 or more?

__ __	d.	Is enhanced I/M required in urban portions of 50,000 or more as
defined by the 1990 Census that are part of a multi-state urbanized area
subject to enhanced I/M?

__NA__	2.	Are subject areas required to implement basic I/M? Not
applicable – Statewide enhanced programs

__NA__	a.	Is basic I/M required in marginal ozone areas and carbon
monoxide areas that were either required to be or actually were in the
SIP on 11/15/90?

__NA__	b.	Is basic I/M is required in all moderate ozone areas that
contain one or more urbanized areas?

__NA__	c.	Is basic I/M is required in all serious or worse ozone area
with a 1980 urban population of less than 200,000?

__NA__	d.	Is basic I/M required in urban portions of 50,000 or more as
defined by the 1990 Census that are part of a multi-state urbanized area
subject to basic I/M?

__Y__	3.	Does the program include sufficient geographic coverage?
Statewide programs

_ ___	a.	Is enhanced I/M required in the entirety of each MSA county
with a population density of 200 persons per square mile or more, based
on the 1990 Census in areas required as part of an ozone transport
region?

__ __	b.	If counties within the MSA with population densities of less
than 200 persons per square mile are excluded, is at least 50% of the
MSA included in the program?  

__ __	c.	Does the I/M program cover at least the number of people in the
subject urbanized area(s) based on the 1990 Census, in areas required
not as part of an ozone transport region?

_Y___	4.	Does the SIP include legal authority requiring or allowing
operation of the I/M program through the applicable attainment date?

_Y___	5.	Does the SIP include a list of the ZIP codes of all areas
covered by I/M?

.c.§51.351	Enhanced I/M Performance Standard

__Y__	A.	Are all elements present in this portion of the SIP?

__Y__	1.	Does the SIP include a modeling demonstration that the I/M
program meets the performance standard for the pollutant(s) which caused
it to be subject to the program?

__Y__	2.	Does the SIP include an on-road testing program?

__Y__	B.	Is this portion of the SIP approvable?

___Y_	1.	Does the I/M program meet or exceed the enhanced I/M
performance standard for each pollutant which caused the area(s) to be
subject to the requirement?

__Y__	a.	Does the SIP contain model input and output files showing the
assumptions and results used in demonstrating the program meets the
performance standard?

___Y_	b.	Was the modeling performed using the most current version of
EPA's mobile source emission model (or approved alternative)?

__Y__	c.	For each applicable pollutant and milestone, including the
attainment deadline, enter below the emission factor for the local
performance standard and the program target and indicate, whether the
performance standard is met for each pollutant in the left column (enter
NA for not applicable).  If multiple runs are submitted, use tons, or
attach a description of your analysis and indicate "okay" below.  See
section 2 of each state’s SIP narrative.

		Massachusetts submitted modeling runs for calendar years 2009. 2010,
2011, 2012, and 2018.  Massachusetts utilized the MOBILE6.2 model to
generate emission factors (see Appendix 4 of the Massachusetts SIP
submittal’s narrative).

		New Hampshire submitted modeling runs for calendar years 2007, 2009,
and 2015.  New Hampshire utilized the MOBILE6.2 model to generate
emission factors (see Attachment VII to the New Hampshire SIP submittal
package).

		Both Massachusetts and New Hampshire meet the required performance
standard evaluations for all pollutants and years modeled except for the
first modeled year (2009 for Massachusetts and 2007 for New Hampshire);
Massachusetts’ modeling of the new program in 2009 shows a slight
increase in VOC and CO emissions.  New Hampshire’s modeling of the new
program in 2007 shows a slight increase in CO emissions.  Both cases can
be attributed to the limitations of the MOBILE6.2 model when modeling
the new program in each state; specifically, not enough program criteria
inputs are allowed in MOBILE6.2, when modeling the new programs, to
specify that there was an existing program in place prior to the new
program start date.	

__Y__	d.	Are the assumptions used to model the performance standard
targets consistent with those listed below?

____	Network:	Centralized

____	Start date:	1983 for existing programs; 1995 for areas newly
subject under 1990 CAA

____	Frequency:	Annual

____	Model years:	1968+

____	Vehicle types:	LDV, LDT1, LDT2

____	Emission test:	IM240 on 1986+

____	Emission test:	Two speed on 1981-1985

____	Emission test:	Idle on 1968-1980

____	Emission standards:	0.8/20/2.0 grams per mile (IM240)

____	Emission standards:	1.2% CO, 220 ppm HC (steady-state)

____	Visual check:	Catalyst and Inlet checks on 1984+

____	Functional test:	Pressure test on 1983+

____	Functional test:	Purge test on 1986+

____	Pre-1981 stringency:	20% 

____	Pre-1981 waiver rate:	3%

____	Post-1980 waiver rate:	3%

____	Compliance rate:	96%

__NA__	e.	Are the correct local characteristics used for the following?

EPA provides a Low Enhanced Performance Standard input

file where the state would just plug in their respective I/M

program components, thus an apples-to-apples comparison

is conducted against the performance standard.

___	Registration distribution

___	VMT Mix 

___	Min/Max temperature

___	Vehicle speed

___	ASTM class

___	RVP

___	Altitude

Note:  All applicable mobile source programs for which MOBILE specifies
parameters should be included in the modeling for both the performance
standard and for evaluating the state program, e.g. Stage II.  

_NA___	2.	If alternative approaches, such as vehicle scrappage, have
been used to contribute to meeting the performance standard, are the
benefits estimated from alternatives consistent with guidance
established for making such calculations?

_NA___	3.	If the administrator has found that NOx reductions are not
beneficial for this particular ozone area, has the program been designed
to offset NOx increases resulting from the repair of HC and CO failures?

.c.§51.352	Basic I/M Performance Standard

_NA___	A.	Are all elements present in this portion of the SIP?

_NA___	1.	Does the SIP include a modeling demonstration that the I/M
program meets the performance standard for the pollutant(s) which caused
either the program or the area to be subject to the program?

_NA___	2.	Does the SIP include a modeling demonstration that, in ozone
nonattainment areas, no increase in NOx will occur as a result of the
program?

_NA___	B.	Is this portion of the SIP approvable?

_NA___	1.	Does the I/M program meet or exceed the basic I/M performance
standard for each pollutant which caused them to be subject to the
requirement?

_NA___	a.	Does the SIP contain model input and output files showing the
assumptions and results used in demonstrating the program meets the
performance standard?

_NA___	b.	Was the modeling performed using the most current version of
EPA's mobile source emission model (or approved alternative)?

_NA__	c.	For each applicable pollutant and milestone, including the
attainment deadline, enter below the emission factor for the local
performance standard and the program target and indicate, whether the
performance standard is met for each pollutant in the left column (enter
N/A for not applicable).  If multiple runs are submitted, use tons, or
attach a description of your analysis and indicate "okay" below.  

	January 1:	1997	2000	2003	

VOC

	Performance Standard	______	______	______	

	Program Target	______	______	______	

NOx 

	No I/M Factor	______	______	______	

	Program Target	______	______	______	

CO		1996	2000

	Performance Standard	______	______

	Program Target	______	______

__NA__	d.	Are the assumptions used to model the performance standard
targets consistent with those listed below?

____	Network:	Centralized

____	Start date:	1983 for existing areas; 1994 for areas 	newly subject
under 1990 CAA

____	Frequency:	Annual

____	Model years:	1968+

____	Vehicle types:	LDV

____	Emission test:	Idle on 1968+

____	Emission standards:	1.2% CO, 220 ppm HC

____	Pre-1981 stringency:	20%

____	Pre-1981 waiver rate:	0%

____	Post-1980 waiver rate:	0%

____	Compliance rate:	100%

_NA__	e.	Are the correct local characteristics used for the following?

___	Registration distribution 

___	VMT Mix

___	Min/Max temperature

___	Vehicle speed

___	ASTM class

___	RVP

___	Altitude

Note:  All applicable mobile source programs for which MOBILE5 specifies
parameters should be included in the modeling for both the performance
standard and for evaluating the state program, e.g. Stage II.  

.c.§51.353	Network Type and Program Evaluation 

_Y___	A.	Are all required elements present in this portion of the SIP?

_Y__	1.	Does the SIP describe the network type for each I/M area? Test
and repair I/M programs in decentralized testing stations.

_Y___	2.	Does the SIP include legal authority which allows for this
network type to be implemented in the subject areas? 

_Y___	3.	Does the SIP include a description of the biennial program
evaluation?

_Y__	a.	Is a schedule for the program evaluation included? 

_Y__	b.	Is a methodology for the program evaluation included? 

_Y__	4.	Does the SIP include legal authority which enables the State to
conduct testing (each year) to provide data for the biennial evaluation
program? States entered into contracts for emission testing programs
which include data reporting and evaluation.

_Y___	B.	Is this portion of the SIP approvable? (Test and repair)

	1.	Network Type

_NA___	a.	If an enhanced program is required for the subject area, do
the regulations in the SIP specify that the program be operated in a
centralized, test-only format?

__NA__	b.	If not  (and an enhanced program is required), does the SIP
specify a decentralized, test-only program?

_NA___	1.	Is the only function of the test station in this I/M program
to perform official emissions testing (with the possible exceptions of
conducting state safety-related inspections, renewing vehicle
registrations/drivers licenses, collecting fees/taxes, or engaging in
the sale of refreshments to employees/waiting customers)?

__NA__	2.	Do the I/M regulations in the SIP contain a stipulation that
owners and employees of an official I/M test station are contractually
or legally barred from engaging (either directly or indirectly) in motor
vehicle repair or service, motor vehicle parts sales or motor vehicle
sale or leasing?

__NA__	3.	Do the I/M program regulations in the SIP bar owners and/or
employees of official I/M testing stations from referring vehicle owners
to particular repair service providers?

__Y__	c.	If not (and an enhanced program is required), does the SIP
specify a test-and-repair program, with an accompanying demonstration
which includes a smaller credit reduction than would normally be
assigned to the various test protocols of such a test-and-repair
program? Same credit/equally effective.  States have put in place
substantial oversight and monitoring efforts to guard against fraud, or
incorrect testing.  Stations are also audited on a regular basis.

__NA__	1.	Is the demonstration provided based upon past performance of
an existing test-and-repair program that utilized the specific
test-type, inspection standards and waiver criteria to be employed? 

__NA__	2.	Does the demonstration include, at a minimum:

__NA__	i.	Repair effectiveness surveys performed on vehicles that failed
the tailpipe and evaporative emissions system tests? 

__NA__	ii.	In programs with visual checks, measurement of actual
tampering rates, their change over time, and the change attributable to
finding/fixing tampering as opposed to the deterrence effect associated
with having a visual check?

_NA___	iii.	Results of covert auditing of inspector effectiveness?

_Y___	3.	If 1 and 2 above are not satisfied, are there program features
which provide complete assurance that the credit loss from the
test-and-repair portion of the program will not exceed the margin by
which a test-only system with the otherwise equivalent features would
exceed the performance standard?, i.e. can the program still meet the
performance standard?  (Assertions that this is the case should be
discussed with OMS immediately).  

_NA___	d.	If a basic program is required, does the SIP specify that the
program be operated using a test-and-repair or hybrid network?  If so:

_NA___	1.	In demonstrating equivalence with the performance standard, is
full emission reduction credit claimed only for that portion of the
fleet passing an initial or subsequent test at a test-only facility, or
for that portion of the fleet failing a test-and-repair initial test,
but subsequently passing a test-only retest? 

_NA___	2.	Are appropriate credit loss assumptions assigned for portions
of the fleet initially passing at a test-and-repair facility and to the
portion initially failing at a test-only facility, but subsequently
passing a retest at a test-and-repair facility? 

	2.	Program Evaluation Included as section 3 (Network Type and Program
Evaluation) and section 16 (Data Analysis and Reporting) of each
state’s SIP narrative.

_Y___	a.	Does the SIP provide that the first biennial evaluation be
reported to EPA by July of 1997 in enhanced I/M areas?

_Y__	b.	Does the SIP include a description of:

_Y__	1.	The evaluation schedule and protocol?

_Y___	2.	The sampling methodology?

_Y__	3.	The data collection and analysis system?

_Y__	4.	The resources and personnel for the evaluation program, and
related details of the evaluation program?

_Y__	c.	Do the measures included in the evaluation program (as described
in the SIP) include, at a minimum:

_Y__	1.	Surveys assessing the effectiveness of repairs performed on
vehicles failing the tailpipe or the evaporative emissions portions of
the test (as applicable)?

__Y__	2.	In programs with visual checks, measurement of actual tampering
rates, their change over time, and the change attributable to
finding/fixing tampering as opposed to deterrence effects?

__Y__	3.	The results of undercover surveys of inspector effectiveness
related to identifying vehicles in need of repair?

__Y__	4.	The results of mass emissions testing and evaporative emissions
checks on a sample of subject vehicles, including assurance that: 

__Y__	i.	The sampling methodology results in a representative, random
sample (at time of initial inspection - before repair) of at least  0.1%
of the vehicles tested in a given year?

_Y___	ii.	The test data is submitted to EPA?

__Y__	iii.	The test data is used to calculate local fleet emission
factors and to assess the actual effectiveness of the I/M program?

.c.§51.354	Adequate Tools and Resources

__Y__	A.	Are all required elements present in this portion of the SIP? 
See section 4 of each state’s SIP narrative

  _Y___	1.	Does the SIP describe the resources to be used for program
operation?

__Y__	2.	Does the SIP describe how the emission reduction targets will
be met?

__Y__	3.	Does the SIP include a detailed budget plan?

__Y__	4.	Does the SIP include a description of personnel resources?

__Y__	5.	Does the SIP include a description of equipment resources?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Does the SIP demonstrate adequate resources to perform and
maintain all program functions?

__Y__	2.	Does the SIP have a mechanism to insure future funding of
program operations?

__Y__	a.	Is a portion of the test fee or a separately assessed per
vehicle fee collected and placed in a dedicated fund?  Or,

_NA___	b.	Does the SIP demonstrate a suitable alternative funding
mechanism?

_Y___	3.	Does the program provide for sufficient staff to carry program
duties, e.g., inspection and enforcement oversight; program evaluation
and oversight; data analysis; and public education and training?

_Y__	4.	Does the program have equipment necessary to achieve the
objective of the program and meet  program requirements?

.c.§51.355	Test Frequency and Convenience

_Y___	A.	Are all required elements present in this portion of the SIP?

_Y___	1.	Does the SIP describe the test frequency in detail?

_NA___	2.	Does the SIP require and include a definition of acceptably
short waiting times and driving distances?  (Test and repair at many
stations).

_NA___	3.	Does the SIP include the legal authority, rules, or contract
provisions necessary to implement and enforce the test frequency and
convenience requirements?

_Y___	B.	Is this portion of the SIP approvable?

_Y___	1.	Do the test frequency requirements in the program rules insure
that vehicles are tested at the assumed frequency?

_Y___	a.	Does the plan describe how the test date is assigned for
vehicles that change ownership?  Are such vehicles kept on the required
test schedule?

_Y___	b.	Does the plan describe how the test date for newly registered
used vehicles is assigned?  Are such vehicles be kept on the required
test schedule?

__Y__	c.	Does the SIP explain how the test frequency will be integrated
into the enforcement process?

__Y__	d.	Have sufficient safeguards been built into the enforcement
system to ensure that vehicles will be tested according to schedule?

__NA__	2.	For enhanced I/M areas does the SIP describe mechanisms to
insure short wait times during actual operation?  (Test and repair at
many stations).

__NA__	3.	Does the SIP describe the test network and demonstrate that
stations are conveniently located?  

__NA__	4.	For basic and enhanced programs, does the SIP define and
require adherence to regular testing hours by the test stations?

__NA__	5.	For basic and enhanced programs, does the SIP require testing
stations to test any subject vehicle presented for a test during a
station's operating hours?

.c.§51.356	Vehicle Coverage

__Y__	A.	Are all required elements present in this portion of the SIP?

__Y__	1.	Does the SIP include a description of the number (as of a date
specified in the SIP) and types (broken down by model year, fuel type,
vehicle class, and weight class) of vehicles in the program, and a plan
for how those vehicles will be identified?  Described in section 6 of
each state’s SIP narrative.

__Y__	2.	Does the SIP include a description of special exemptions, if
any, allowed by the program?

__Y__	3.	Does the SIP include legal authority or rules necessary to
implement and enforce the vehicle coverage requirement?

__Y__	B.	Is this portion of the SIP approvable? (Statewide)

_Y___	1.	Does the number of vehicles account for vehicles registered or
required to be registered in the program area (i.e., does the SIP
provide an estimate of unregistered vehicles)? 

_Y___	2.	If fleet vehicles are subject to the I/M program, then: 

_Y___	a.	Are fleets inspected by independent test-only facilities
subject to the same test requirements as the primary program using the
same quality control standards?

_NA___	b.	If fleets are not tested by independent, test-only facilities,
is one of the following criteria met?  

_NA___	i.	Is there no emission reduction benefit assigned for the all
vehicles (including non-fleet vehicles) within the model year class that
dealers and fleets are allowed to self-test?

_NA___	ii.	If credit is assumed for some fraction of the model years
that dealers and fleets are self-testing, is the credit assumed only for
vehicles that are not resold through a dealership or fleet in a given
test cycle, is this percentage documented, and are the requirements for
receiving any credit for the affected model years including requiring
test-only certificates for title transfer and not allowing two
self-tests in a row met?  

_NA___	4.	Are provisions made to allow inspection of vehicles registered
in other program areas and for issuance of certificates of compliance or
waiver?

_NA___	5.	Are subject vehicles registered in the program area but
primarily operated in another I/M area required to be tested in the
program or by the program in the area the subject vehicle is primarily
operated?

_NA__	6.	Does the plan include a description of the Federal fleet
inspection program?

_NA___	a.	Are Federal installation managers required to show proof of
inspection for all Federal employee-owned vehicles operated on the
installation?

_NA___	b.	Are all Federally owned vehicles (other than tactical military
vehicles) required to be inspected?

_Y___	7.	Does the description of special exemptions include an estimate
of the number of vehicles exempted and the percentage of the subject
fleet, and are the exemptions accounted for in the emission reduction
analysis?

.c.§51.357	Test Procedures and Standards

_Y___	A.	Are all required elements present in this portion of the SIP?

_Y__	1.	Does the SIP include detailed procedures for each test and the
pass/fail standards for each applicable model year for each test?

_Y__	2.	Does the SIP include the rule, ordinance or law establishing the
test procedures?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Do the test procedures in the SIP correspond exactly to
approved EPA test procedures or official EPA test procedures pending
approval? OBD2 testing in each state.

__Y__	2.	Are initial tests performed without prior repair or adjustment
at the test facility (except as necessary to perform functional tests)?

__Y__	3.	Is there a provision for the vehicle operator to have access to
the test area to observe the entire inspection?

__Y__	4.	Is there a provision for rejection of vehicles with missing or
leaking exhausts or other unsafe conditions?

__Y__	5.	Are there pass/fail standards for all test procedures for all
applicable model years?

__Y__	6.	To the extent that repair of a failure on one part of a test
can lead to failure on another part, does the test procedure provide for
a retest on the originally failed component and the second component?   

_Y___	a.	Is an exhaust emission retest required along with a retest of
the evaporative system following an evaporative system failure and
repair?

__Y__	b.	Are all criteria pollutants measured on retest after failure of
a given pollutant?

_Y___	7.	Do the pass/fail standards correspond to those used in modeling
emission reduction benefits of the program?

__Y__	a.	Are standards established for both HC and CO in basic I/M
areas, and also for NOx in enhanced areas?

__Y__	b.	Are evaporative test standards, if any, equal to or more
stringent than EPA established standards?

__NA__	Note:  EPA encourages states to structure their regulations to
allow quick response adjustment to cutpoints in case actual failure
rates at start-up are not as expected.  

__N__	8.	Does the SIP have a commitment to maintain tailpipe emission
test pass/fail standards for pre-81 vehicles so as to produce the
stringency rate used in modeling emission reduction benefits? (No
tailpipe testing.  OBD2 testing of 1996 and newer vehicles)

__Y__	9.	For vehicles with switched engines, are all test procedures and
standards for the chassis model year and type applied, or for the engine
model year if it is newer?

__Y__	10.	For vehicles that are switched to a fuel type for which there
is no certified configuration, are vehicles tested according to the most
stringent emission standards established for that vehicle type and model
year?  

.c.§51.358	Test Equipment

__Y__	A.	Are all required elements present in this portion of the SIP?

__Y__	1.	Does the SIP contain written technical specifications for all
test equipment to be used in the program?

__NA_	2.	Does the SIP describe equipment acceptance testing criteria and
procedures?

_Y___	B.	Is this portion of the SIP approvable?

__Y__	1.	Are computerized test systems required for all measurements
performed on subject vehicles?

__Y__	2.	Are there provisions for the equipment to be:

__Y__	a.	Automated to the highest degree commercially available to
minimize the potential for intentional fraud and/or human error?

_Y___	b.	Secure from abuse and/or tampering?

_Y__	c.	Based upon written specifications?

_Y__	d.	Capable of simultaneously sampling dual exhaust vehicles?

_Y___	3.	Does the test system automatically:

_Y__	a.	Make a pass/fail decision for all measurements?

_Y__	b.	Record test data to an electronic medium?

_Y___	c.	Conduct regular self testing of recording accuracy?

_Y__	d.	Perform electrical calibration and system integrity tests before
each test, as applicable?

_Y___	e.	Initiate system lockouts for the following:

_ Y___	1.	Tampering with security aspects of the test system?

__Y__	2.	Failing to conduct or pass periodic calibration or leak checks?

_NA__	3.	Failing to conduct or pass the constant volume sampler flow
rate check, if applicable?

_NA__	4.	Failing to conduct or pass any of the dynamometer checks
including coast-down, roll speed and roll distance, power absorption
capability and inertia weight selection checks?

_NA___	5.	Failing to conduct the pressure monitoring device check, if
applicable?

_NA___	6.	Failing to conduct or pass the purge flow metering check, if
applicable?

_NA___	7.	Having a full data recording medium or one that does not pass
the cyclical redundancy check?

__Y__	4.	Is the emission test equipment capable of testing all subject
vehicles?  

__NA__	5.	Does the SIP commit to updating emission test equipment to
accommodate new technology vehicles and changes to the program?  

__Y__	6.	In enhanced programs, does the SIP require that test systems be
connected by a real-time data link to a host computer that prevents
unauthorized multiple initial tests on the same vehicle and ensures data
accuracy?

.c.§51.359	Quality Control

__Y__        A.	Are all the required elements present in this portion of
the SIP?   Included as section 9 of each state’s SIP narrative.

__Y_	1.	Does the SIP include a description of quality control measures
for emission measurement equipment?

__Y__	2.	Does the SIP include a description of record keeping procedures
and other measures taken to ensure document security?

__Y_	3.	Does the SIP include the procedure manual, rule, ordinance or
law which describes and establishes quality control and record keeping
requirements?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Will these measures insure that the equipment is calibrated and
properly maintained?

__Y__	2.	Will these measures insure that inspection, calibration
records, and control charts are accurately created, recorded, and
maintained?

__NA__	3.	Does the SIP include alternative quality control measures not
included under §51.359 or Appendix A of the I/M rule?

_NA_	a 	If so, have these measures been approved by the Administrator?

__Y__	5.	Does the SIP include periodic preventive maintenance of all
inspection equipment?

__Y__	6.	Does the SIP include a provision for computerized analyzers to
automatically record quality control check information, lockouts,
attempted tampering, and other recordable circumstances that impact
quality control?

__Y__	7.	For steady-state testing equipment, does the SIP:

__Y__	a.	Include a description of the maintenance procedures?

__Y__	b.	Do these procedures follow good engineering practices to ensure
test accuracy?

__Y__	c.	Include calibration and adjustment requirements complying with
those described in Appendix A of the I/M rule?

__Y__	d.	Have equipment specifications including:

__Y__	1.	Minimum housing construction requirements to protect the
analyzer bench and electrical components from ambient temperature and
humidity fluctuations exceeding the range of the analyzer's design
specifications?

_NA___	2.	A requirement that analyzers be designed to automatically
purge the analytical system after each test?

_NA___	3.	For analyzers that use ambient air as zero air, have
provisions been made to draw air from outside the inspection bay or
lane? 

_NA___	8.	For transient exhaust emission test equipment, does the SIP:

_NA___	a.	Include a description of the maintenance procedures?

_NA___	b.	Do these procedures follow good engineering practices to
ensure test accuracy?

_NA___	c.	Require the use of computer controlled quality assurance
checks and quality control charts whenever possible?

_NA___	d.	Provide exceptions to the procedures and the frequency of the
checks described in Appendix A of the I/M rule?

__NA__	i.	If so, have these exceptions been approved by the
Administrator?

_NA___	9.	For evaporative system functional test equipment, does the
SIP:

_NA___	a.	Include a description of the maintenance procedures?

_NA___	b.	Do these procedures follow good engineering practices to
ensure test accuracy?

_NA___	c.	Require the use of computer-controlled quality assurance
checks and quality control charts whenever possible?

_NA__	d.	Provide exceptions to the procedures and the frequency of the
checks described in Appendix A of the I/M rule?

_NA__	i.	If so, have these exceptions been approved by the
Administrator?

_Y__	10.	Does the SIP include measures to maintain the security of all
documents by which compliance with the inspection requirement is
established?

_Y___	a.	Are such documents required to be counterfeit-resistant?

_Y___	b.	Do such documents include unique serial numbers and an official
seal?

__Y__	c.	Does the SIP include measures to ensure that compliance
documents cannot be stolen or removed without being damaged?

.c.§51.360	Waivers and Compliance Via Diagnostic Inspection

_Y___         A.	Are all required elements present in this portion of
the SIP? Included as section 10 in each state’s SIP narrative.

__Y__	1.	Does the SIP include a maximum waiver rate for estimating
emission reduction benefit?

__Y__	2.	Does the SIP include a commitment to:

__Y__	a.	Take corrective action to reduce the waiver rate to equal or
below the maximum waiver rate used for estimating benefits, or: 

__Y__	b.	revise the SIP and emission reductions claimed based on the
actual waiver rate?  

__Y__	3.	Does the SIP include specific criteria and procedures for the
issuance of waivers?

__Y__	4.	Does the SIP include the necessary legal authority, rules, or
ordinance to issue waivers, set and adjust cost limits, and administer
the waiver system?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Are approvable waiver issuance criteria included?

__Y__	a.	Are waivers allowed only after failing a retest and after all
qualifying repairs are completed?

__Y__	b.	Is available warranty coverage required to be used before
expenditures are counted for waivers?

__Y__	c.	Is repair of tampering not applicable towards the waiver limit?

__Y__	d 	Is performance and appropriateness of repairs confirmed by
visual inspection and review of receipts?

_Y___	e.	Must repairs be performed by recognized repair technicians
(except for pre-1980 models)?

__Y__	f.	Are minimum expenditures required before waivers are issued?
New Hampshire does not issue conventional repair expenditure waivers.

__NA__	1.	Is the minimum expenditure at least $75 for pre-81 vehicles
and at least $200 for 1981 and newer vehicles in basic programs?

__Y__	2.	In enhanced I/M areas, is the minimum expenditure based on $450
and adjusted annually using the Consumer Price Index, with a base year
of 1990, according to established procedures described in the I/M rule?

_NA___	g.	If lower minimum waiver limits are established, are vehicles
that do not pass the retest and have not received $450 in repair
required to be scrapped?  

_Y___	h.	If time extensions are granted:

_NA___	1.	Are criteria (beyond vehicle model year or value) specified
that establish that economic hardship exists?

_Y___	2.	Is the extension granted only once for the life of a vehicle?

_Y___	3.	Is there a mechanism for tracking that will insure vehicles can
be identified as having gotten an extension?

_NA___	2.	If compliance via diagnostic inspection is allowed, are
approvable policies and procedures specified?

_NA__	a.	Is an IM240 test performed on eligible vehicles?

_NA___	b.	Are cutpoints established in 51.351(a)(7) (or more stringent)
in force for eligible vehicles?

_NA___	c.	Is a complete, documented physical and functional diagnosis
performed by the I/M agency or its contractor?

_Y___	3.	Is the quality control of waiver issuance approvable?

_Y__	a.	In enhanced areas, are waivers to be issued only by the agency
or a single contractor (no inspector issuance)?

__NA__	b.	In basic areas, if inspectors are allowed to issue waivers,
are comprehensive reviews of waiver issuance conducted during overt
audits?

__NA__	c.	Is a program described to alert vehicle owners to warranty
coverage and ways to obtain repairs?

__Y__	d.	Are procedures described to authenticate repairs receipts and
prevent their reuse?

__Y__	e.	Are procedures established to limit a waiver to one test cycle?

__Y_	f.	Are procedures established to track waivers and time extensions
and prevent their improper issuance?

.c.§51.361	Motorist Compliance Enforcement

__Y__	A.	Are all required elements present in this portion of the SIP?

__Y__	1.	Does the SIP provide a detailed description of the motorist
compliance enforcement mechanism to be used in implementing the I/M
program?

__Y_	2.	Does the SIP identify all agencies responsible for implementing
the motorist compliance enforcement program?

__Y__	3.	Does the SIP provide a description of and accounting for all
classes of exempt vehicles?

__Y__	4.	Does the SIP include a description of the plan for testing
fleet vehicles, rental car fleets, leased vehicles, federal fleet
vehicles, state and local government vehicles, and other subject
vehicles which are operated in, but not necessarily registered in, the
I/M area?

__Y__	5.	Does the SIP include an estimate of the current compliance
rate, including an assessment of the noncompliance due to loopholes,
counterfeiting, and unregistered vehicles?

_NA__	6.	Does the SIP include estimates of the effect of closing the
above loopholes and otherwise improving the enforcement mechanism, if
improved compliance is assumed for modeling purposes?

__NA__	7.	Are the required estimates of compliance losses and the impact
of fixes based upon a detailed analysis of actual data?

__Y__	8.	Does the SIP include the legal authority and/or rules which
establish the enforcement program?

__Y__	9.	Does the SIP include a commitment to an enforcement level to be
used in modeling and to be maintained, at a minimum, in practice?

__Y__	B.	Is this portion of the SIP approvable?

__NA__	1.	If the enforcement mechanism is based upon registration
denial, does the program ensure that an application for initial
registration or reregistration of a subject vehicle is rejected without
proof that the vehicle has complied with the testing requirement and
been passed or waived? Based on registration suspension.

__NA__	2.	If the enforcement mechanism is based upon registration
denial, does the design of this program include:

__NA__	a.	An external, readily visible means of determining a vehicle's
compliance with the registration requirement?

__NA__	b.	A schedule of testing (annual, biennial, or a mix) that
clearly determines when a vehicle must be tested?

__NA__	c.	A mechanism for certifying that a vehicle has met the testing
requirements and has been either passed or waived (and is therefore
eligible for initial registration or reregistration), including:

__NA__	1.	Expiration date of the certification?

__NA_	2.	Unambiguous vehicle identification information?

__NA__	3.	Whether the vehicle was passed or received a waiver?

__NA__	d.	Assurance that this certification is available, checked, and
validated prior to the registration or reregistration of a subject
vehicle?

__Y__	e.	Routine issuance of citations to motorists who fail to comply
with the registration requirement?

__Y__	f.	A penalty schedule including mandatory, minimum, meaningful
fines for noncompliance with the registration requirement?

__Y__	g.	A requirement that noncompliance cases not be closed until
compliance is demonstrated?

__Y__	h.	A mechanism for preventing owners or lessors of vehicles from
avoiding the testing program through manipulation of the registration or
titling requirement?  Statewide programs.

__Y__	i.	The requirement that all applications for exemption-triggering
changes to a vehicle's registration information be confirmed through a
physical examination of the vehicle or the provision of some valid form
of documentation (in the case of address changes)?

__Y__	j.	A means for tracking and limiting the use of time extensions
and out-of-state exemptions?

__Y__	k.	A mechanism for encouraging the enforcement of vehicle transfer
requirements when vehicle owners move into the I/M area?

__Y__	3.	If the program is in an enhanced area and is to be enforced by
some means other than registration denial: Registration suspsension.

__NA__	a.	Was the alternative mechanism part of an approved I/M SIP
prior to enactment of the 1990 Amendments to the Clean Air Act?

_NA___	b.	Were the I/M program and alternative mechanism in question
actually in place and operating prior to enactment of the 1990
Amendments to the Clean Air Act?

__Y__	c.	Does the SIP include a demonstration that this alternative
enforcement mechanism is more effective than registration denial?
Registration suspsension.

_NA___	d.	Is this demonstration based upon a determination (and
comparison) of the relative compliance numbers and percentages for both
the registration program and the I/M program?

_NA___	i.	Is this comparison based upon data for at least one full test
cycle?

_NA___	ii.	Does this comparison show that the fraction of vehicles
complying with the I/M program is higher than the fraction of vehicles
complying with the registration requirement?

_NA___	4.	If the program is in a basic area and is to be enforced by an
alternative mechanism:

_NA___	a.	Does the SIP include a demonstration that this alternative
enforcement mechanism is as effective as registration denial?

_NA__	b.	Is this demonstration based upon a determination (and
comparison) of the relative compliance numbers and percentages for both
the registration program and the I/M program?

_NA__	i.	Is this comparison based upon data covering at least 1 full
test cycle?

_ NA___	ii.	Does this comparison show that the fraction of vehicles
complying with the I/M program is at least equal to the fraction of
vehicles complying with the registration requirement?

_ Y___	5.	If a program is using sticker-based enforcement: Massachusetts
also includes electronic database vehicle registration analysis to
identify non-compliance with emissions testing requirements.

_ Y___	a.	Does the SIP include a demonstration that this enforcement
mechanism (in addition to meeting the general requirements for
alternative enforcement mechanisms) will swiftly and effectively prevent
operation of noncomplying subject vehicles?

__Y___	b.	Does the demonstration required of sticker-based programs in
item (B)(4)(a) above include an assessment of the following forms of
noncompliance and a means for limiting each:

_Y___	1.	Use of stolen, counterfeit or fraudulently obtained stickers?

_Y___	2.	In states with safety inspections, the use of "Safety
Inspection Only" stickers on vehicles subject to the emission test ?

_Y__	3.	Operation of vehicles with expired stickers, including a
breakdown by length of noncompliance and model year? Ability to
electronically audit vehicles with no known final outcome.

_Y___	c.	Does the program require external, easily visible and
unambiguous identification of vehicles as subject to the I/M
requirement?

_Y___	d.	Does the program require external, easily visible and
unambiguous identification of a subject vehicle's compliance status?

_Y__	e.	Does the program include fines which make the cost of
noncompliance greater than the upper limit cost of compliance?

_Y___	f.	Are the external identifiers used or planned by the program:

_Y___	1.	Counterfeit resistant?

_Y___	2.	Difficult to remove without destroying?

_Y___	3.	Durable enough to last until the next inspection cycle without
fading, peeling, or otherwise deteriorating?

_Y___	g.	Does the program require the performance of compliance surveys
involving at least 10% or 10,000 (whichever is less) of the subject
vehicle population?

__Y__	h.	Are all external compliance identifiers tracked and accounted
for?

_Y___	i.	Are meaningful fines assessed against test stations for all
unaccounted for identifiers?

_Y___	6.	If a program is using computer-matching enforcement, either as
a supplement to registration denial or in lieu of registration denial:
Used by Massachusetts to enforce registration suspension as a supplement
to sticker-based program.

__Y__	a.	Does the SIP include a demonstration that this enforcement
mechanism (in addition to meeting the general requirements for
alternative enforcement mechanisms in the case of areas using computer
matching in lieu of registration denial) will swiftly and effectively
prevent operation of noncomplying subject vehicles?

_Y___	b.	Does the demonstration required of computer-matching programs
in item (B)(6)(a) above include requirements that ensure that:

__Y__	1.	90% of subject vehicles are in compliance within 4 months of
the compliance deadline?

_Y___	2.	Subsequent compliance deadlines are based upon the date of
scheduled compliance (not the date of actual compliance)?

_Y___	3.	Fines for noncompliance are at least as great as the upper
limit cost of compliance?

_Y___	4.	Registration suspension and denial of reregistration for
continued noncompliance?

_Y___	5.	Demonstration of the current computer system's adequacy to
store and manipulate the I/M vehicle database?

_NA___	6.	Provisions for periodic system backup and auxiliary storage?

_Y___	c.	Does the computer-matching program track each vehicle through
the steps taken to ensure compliance, including:

_Y___	1.	The compliance deadline?

_Y___	2.	The date of initial notification?

_Y___	3.	The dates warning letters are sent?

_Y___	4.	The dates notices of violation and other penalty notices are
sent?

_Y__	5.	The dates and outcomes of other steps in the process?

_Y___	6.	The final compliance date?

_Y___	d.	Does the SIP commit to compiling and reporting monthly
summaries including statistics on the percentage of vehicles at each
stage in the enforcement process? Real time, snapshot, of program data
is available.

_NA___	e.	Does the SIP commit to tracking the number and percentage of
vehicles which are never tested as a result of being junked, sold
outside the I/M area, or for other reasons? 

.c.§51.362	Motorist Compliance Enforcement Program Oversight

__Y__	A.	Are all required elements present in this portion of the SIP?
See sections 11 and 12 of each state’s SIP narrative.

__Y__	1.	Does the SIP include a description of how the motorist
compliance enforcement program is quality controlled and quality
assured?

__Y__	2.	Does the SIP include a description of the program's information
management activities?

__Y_	3.	Does the SIP include the legal authority and/or regulations
necessary to implement this aspect of the program?)

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Does the oversight program included in the SIP quality assure
its information base by:

__Y__	a.	Verification of exempt vehicle status through inspection?

__Y__	b.	Data accuracy assurance through automatic or redundant data
entry?

__Y__	c.	Establishment and maintenance of an audit trail for all program
documentation so that all such documentation can be controlled and
tracked?

__Y__	d.	The assessment of fines against stations for missing or
unaccounted for program documents reflecting the "street value" of those
documents (i.e., test fee plus minimum waiver expenditure)?

__Y__	e.	Analysis of the registration database to target
exemption-triggering changes in registration data?

__Y__	f.	Follow-up and confirmation of exemption-triggering registration
changes?

__Y_	g.	Periodic audits of test records and other program documentation
to assess program effectiveness?

__Y_	2.	Are the activities of enforcement personnel quality controlled
through:

__Y_	a.	Written procedures to be followed by personnel directly involved
in the enforcement of the I/M program?

__Y__	b.	Written procedures for personnel involved in handling or
processing of program documentation, such as registration clerks or
other document distributors?

__Y__	i.	Are these personnel to be audited using written procedures?

__Y__	c.	Are all enforcement personnel (direct and indirect) covered by
enforcement procedures including disciplining, retraining, or removing
such personnel who deviate from established procedures?

__Y__	3.	Are evaluations of actual or projected program effectiveness
based upon a quality assured information base that includes:

__Y_	a.	An accurate determination of the subject vehicle population?

__Y__	b.	Quality assurance of the registration and other program
documentation databases?

__Y__	c.	Periodic auditing and analysis of the testing database?

__Y__	d.	Comparison of the testing and enforcement databases to
determine program effectiveness and to trigger additional enforcement
activities?

__Y__	e.	The use of parking lot surveys, road-side pullovers, and other
strategies to assess the compliance status of the in-use fleet (and to
quality assure the enforcement database)?

__Y__	f.	Does the SIP permit EPA audits of the enforcement process?  

.c.§51.363 	Quality Assurance

__Y__	A.	Are all required elements present in this portion of the SIP?
Included as section 13 of each state’s SIP narrative.

__Y__	1.	Does the SIP include a description of the quality assurance
program?

__Y__	2.	Does the SIP include legal authority or rules necessary to
implement the quality assurance requirements?

__Y_	B.	Is this portion of the SIP approvable?

__Y__	1.	Are performance audits (overt and covert) based on written
procedures?

__Y__	a.	Are audit results recorded and retained in station and
inspector files?

__Y__	b.	Are records of sufficient detail to support administrative or
civil hearings required to be maintained?

__Y__	2.	Are stations and inspectors suspected of violating regulations
as a result of data analysis or consumer complaints audited at a greater
frequency?

__Y__	3.	Are overt performance audits conducted at least twice a year
for each lane or test bay?

__Y__	a.	Are auditors required to check for document security?

__Y__	b.	Are auditors required to check to see that required records are
being kept?

__Y__	c.	Are auditors required to check for proper licenses or
certificates along with other required display information?

__Y__	d.	Do auditors observe and produce written evaluations of each
inspector's ability to properly perform testing procedures?

___Y_	4.	Are covert audits included in the quality assurance program?

__Y__	a.	Are auditors required to remotely observe inspector performance
one per year per inspector for high volume stations  (i.e., those
performing more than 4,000 tests per year)?

__Y__	b.	Is the number of covert audits performed annually at least
equal to the number of inspectors in the program?

__Y__	c.	Are covert vehicles set to fail in some fashion? New Hampshire
does not currently utilize vehicles set to fail.

__Y__	d.	In addition to the above covert audits, are test-and-repair
stations covertly audited at least once per year, including the purchase
of repairs and retest if the vehicle is initially failed for tailpipe
emissions?

__Y__	e.	Is the required audit documentation sufficient for building a
legal case and ongoing performance evaluation?

__Y__	f.	Does the fleet of covert vehicles used cover the range of
vehicle technology groups and include a full range of malfunctions?

__Y__	g.	Are there a sufficient number of covert vehicles and auditors
to allow for rotation to avoid detection?

__NA__	h.	Are auditors (or other designated agents) able to access the
inspection database to permit the creation and maintenance of covert
vehicle records?

___Y_	5.	Are station and inspector records reviewed at least monthly to
assess station performance and identify potential problems?

__Y_	a.	Does the review use software-based, computerized analysis to
identify statistically inconsistent information?

__NA__	b.	Does the review require visits to stations to review records
not covered in an electronic analysis?

__NA__	c.	Does the review require comprehensive accountability for all
forms that can be used to demonstrate compliance with the program?

__Y__	6.	Are auditors required to conduct quality control evaluations of
testing equipment during overt site visits?  Does the equipment audit
include:

__NA__	a.	A gas audit using gases of known concentration at least as
accurate as those used for routine quality control checks?

__NA__	b.	A check for tampering and general serviceability of the
equipment?

__NA__	c.	A check for critical flow in the Constant Volume Sampler
(CVS)?

__NA__	d.	A check for CVS flow calibration?

__NA__	e.	A check for the optimization of FID fuel-air ratio using
methane?

__NA__	f.	A leak check?

__NA__	g.	A check to determine that station gas bottles used for
calibration are properly labelled and within relevant tolerances?

__NA__	h.	A functional check of the dynamometer addressing coast-down,
roll speed and roll distance, inertia weight selection, and power
absorption?

__NA__	i.	A check of the system's ability to detect background pollutant
levels?

__NA__	j.	A check of the pressure monitoring devices used to perform the
evaporative canister pressure test?

__NA__	k.	A check of the purge flow metering system?

__Y__	7.	Is completion of a formal training program required for
auditors?  Does this training address

__Y__	a.	The use of analyzers?

__Y__	b.	The program rules and regulations?

__Y__	c.	The basics of air pollution control?

__Y__	d.	The basics principles of engine repair related to emission
performance?

__Y__	e.	The basics principles of motor vehicle emission control
systems?

__Y__	f.	Evidence gathering?

__Y__	g.	State administrative procedures?

__Y__	h.	Quality assurance practices?

__Y__	i.	Covert audit procedures?

___NA_	8.	Are auditors themselves audited at least once per year?

.c.§51.364	Enforcement Against Contractors, Stations and Inspectors

_Y___	A.	Are all the required elements present in this portion of the
SIP? Included as section 14 of each state’s SIP narrative.

_Y__	1.	Does the SIP include a penalty schedule and the legal authority
to enforce it?

__NA__	2.	Does the SIP include an official opinion from the state
Attorney General to support all claims of state constitutional
impediments to the requirements under this section of the I/M rule?

__Y__	3.	Does the SIP provide descriptions of:

__Y__	a.	The administrative and judicial procedures and responsibilities
relevant to the enforcement process?

__Y__	b.	A listing by area of responsibility the agencies, courts, and
jurisdictions involved in the above procedures?

__Y__	c.	Identification of the body responsible for prosecuting and
adjudicating cases?

__Y__	d.	A description of the resources to be allocated to this function
and their source(s)?

__NA__	4.	If state does not have the authority to immediately suspend
station/inspectors, does the SIP demonstrate that sufficient resources,
personnel, and systems are in place to process cases directly impacting
emission reductions within three days?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1	Does the penalty schedule include categories and lists of
violations with minimum penalties to be imposed for the first, second,
and subsequent violations and are those penalties adequate?

__Y__	2.	For test-and-repair programs, is there a provision for
suspension of inspector and station licenses for at least 6 months?

__NA__	3.	For test-only programs, is there a provision for removal of an
inspector for at least 6 months, or a retainage penalty equivalent to an
inspector's salary for at least 6 months?

__Y__	4.	Do cases of gross neglect result in a penalty for the first
offense of no less than $100 or 5 times of inspection fee (whichever is
greater) for the contractor or the station and the inspector (if
involved)?

__Y_	5.	In cases of inspector incompetence, retraining required before
restoration of privileges?

__Y__	6.	Does the license or certification suspension process include
provisions that effectively bar the individual from any involvement,
direct or indirect, in the inspection operation during the full term of
the suspension?

__Y_	7.	Does the auditor have authority to temporarily suspend station
and inspector licenses or certificates immediately upon finding a
violation or equipment failure?  If not:

__NA__	a.	Has the state demonstrated that its enforcement system has
adequate resources to hold a hearing to suspend or revoke the station or
inspector license within three business days?

__NA__	b.	Has the state demonstrated that such authority is prohibited
by the state's constitution?

__Y__	8.	Does the oversight agency have the authority to impose
penalties against licensed stations or contractors, as well as the
inspector, even if the licensee or contractor had no direct knowledge of
the violation?

__Y__	9.	Is the oversight agency specifically required to maintain
records of all enforcement activities, including all warnings, civil
fines, suspensions, revocations, and violations?

__Y__	10.	Does the SIP commit to compiling and reporting statistics on
the above enforcement activities on an annual basis?

.c.§51.365	Data Collection

__Y__	A.	Is data collection included as part of the I/M program? See
sections 15 and 16 of each state’s SIP narrative.

__Y__	1.	Does the SIP describe the type of data to be collected?

__Y__	2.	Does the SIP describe how the collected data shall be used?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Is the following data collected with respect to all vehicles
tested?

__Y__	a.	Test record number?

__Y__	b.	Inspection station number?

__Y__	c.	Inspector number?

__Y__	d.	Test system number?

__Y__	e.	Date of the test?

__Y__	f.	Emission test start time?

__Y__	g.	The time final emission scores are determined?

__Y__	h.	Vehicle identification number?

__Y__	i.	License plate number?

__Y__	j.	Test certificate number?

__Y__	k.	Gross vehicle weight rating (GVWR)?

__Y__	l.	For each vehicle:

__Y__	1.	Model year?

__Y__	2.	Make?

__Y__	3.	Vehicle type?

__NA__	m.	Number of cylinders or engine displacement?

__NA__	n.	Transmission type?

__Y__	o.	Odometer reading?

__Y__	p.	Category of test performed (i.e., initial, first retest, or
subsequent retest)?

__Y__	q.	Fuel type of the vehicle (i.e., gas, diesel, or other fuel)?

__NA__	r.	Type of vehicle preconditioning performed (if any)?

__Y__	s.	Emission test sequence(s) used?

__NA__	t.	Emission scores for HC, CO, CO2, and NOx (in enhanced areas)?
OBD2 testing, only indicates proper operation of emission control
components.

__Y__	u.	For each test mode, standards for HC, CO, CO+CO2, and NOx? OBD2
testing conducted by each state..

__Y__	v.	Results (Pass/Fail/Not Applicable) for the following visual
inspections: Responses are for the anti-tampering program in New
Hampshire. (NA for the Massachusetts program)

__Y__	1.	Catalytic converter?

__Y__	2.	Air system?

__N__	3.	Gas cap?

__N__	4.	Evaporative system?

__Y__	5.	Positive crankcase ventilation (PCV) valve?

__Y_	6.	Fuel inlet restrictor?

__Y__	7.	Other visual inspection for which emission reduction credit is
claimed?

__NA__	w.	Pass/fail results for:

__N__	1.	Evaporative system pressure test?

__N__	2.	Evaporative system purge test?

__N__	x.	Total purge flow in liters achieved during the test?

__Y__	2.	Does the SIP include a commitment to gather and report the
results of the quality control checks described in §51.359?

__Y__	a.	Will each check be identified by:

__Y_	1.	Station number?

__Y__	2.	System number?

__Y__	3.	Date?

__Y__	4.	Start time?

__Y__	b.	Will the data reports contain the concentration values of the
calibration gases used to perform the gas characterization portion of
the quality control checks?

.c.§51.366	Data Analysis and Reporting

__Y__	A.	Is data analysis and reporting included as part of the I/M
program? See sections 15 and 16 of each state’s SIP narrative.

__Y__		1.	Does the SIP include a commitment to submit annual reports?

__Y_		2.	Does the SIP include a commitment to submit biennial
evaluations?

__Y__	B.	Is this portion of the SIP approvable?

__NA__	1.	Is the first annual report scheduled to be submitted within 18
months of initial program implementation?

__Y__	2 	Does the SIP commit to submit a report each July, for January
through December of the previous year, which provides statistics on the
testing element of the program? Will this report cover the following
program statistics:  

	a.	The number of vehicles tested by:

__Y__	1.	Model year?

__Y__	2.	Vehicle type?

__Y__	b.	By model year and vehicle type, the number and percentage of
vehicles: Data for OBD2 testing is collected, analyzed, and reported.

__Y__	1.	Failing the emissions test initially?

__Y__	2.	Failing each emission control component check initially?

__Y__	3.	Failing the evaporative system functional and integrity checks
initially?

__Y__	4.	Failing the first retest for tailpipe emissions?

__Y__	5.	Passing the first retest for tailpipe emissions?

__Y__	6.	Initially failed vehicles passing the second or subsequent
retest for tailpipe emissions? 

__Y__	7.	Initially failed vehicles passing each emission control
component check on the first or subsequent retest by component?

__Y__	8.	Initially failed vehicles passing the evaporative system
functional and integrity checks on the first or subsequent retest by
component?

__Y__	9.	Initially failed vehicles receiving a waiver?

__Y__	10. Vehicles with no known final outcome (regardless of reason)?

__Y__	c.	The initial test volume by model year and test station?

__Y__	d.	The initial test failure rate by model year and test station?

__N__	e.	The average increase or decrease in after repair tailpipe
emission levels for HC, CO, and NOx by model year and vehicle type, for
vehicles receiving a mass emissions test or approved alternative?

__Y__	3.	Does the SIP commit to submit a report each July, for January
through December of the previous year, which provides statistics on the
quality assurance program?  Will this report cover the following program
statistics:

	a.	The number of inspection stations and lanes which are in operation:

__Y__	1.	Throughout the year?

__Y__	2.	Only part of the year?

	b.	The number of stations and lanes operating throughout the year:

__Y__	1.	Receiving overt performance audits in the year?

__Y__	2.	Not receiving overt performance audits in the year?

__Y__	3.	Receiving covert performance audits in the year?

__Y__	4.	Not receiving covert performance audits in the year?

__Y__	5.	That have been shut down as a result of overt performance
audits?

	c.	The number of covert audits:

__Y__	1.	Conducted with the vehicle set to fail the emission test?

__Y__	2.	Conducted with the vehicle set to fail the component check?

__Y__	3.	Conducted with the vehicle set to fail the evaporative system
checks?

__Y__	4.	Conducted with the vehicle set to fail two or more checks?

__Y__	5.	Resulting in a false pass for emissions?

__Y__	6.	Resulting in a false pass for component checks?

__Y__	7.	Resulting in a false pass for the evaporative system check?

__Y__	8.	Resulting in a false pass for two or more checks?

	d.	The number of inspectors:

__Y__	1.	Suspended, fired, or prohibited from testing because of covert
audits?

__Y__	2.	Suspended, fired, or prohibited from testing for other causes?

__Y__	3.	Fined for any reason?

	e.	The number of stations:

__Y__	1.	Suspended, fired, or prohibited from testing because of covert
audits?

__Y__	2.	Suspended, fired, or prohibited from testing for other causes?

__Y__	3.	Fined for any reason?

__Y__	f.	The number of inspectors licensed or certified to conduct
testing?

	g.	The number of hearings:

__Y__	1.	Held to consider adverse actions against inspectors and
stations?

__Y__	2.	Resulting in adverse actions against inspectors and stations?

__Y__	h.	The total amount collected in fines from inspectors and
stations by type of violation?

__Y__	i.	The total number of covert vehicles available for undercover
audits over the year?

_Y__	j.	The number of covert auditors available for undercover audits?

_Y___	4.	Does the SIP commit to submit a report each July, for January
through December of the previous year, which provides statistics on the
quality control program?  Will this report cover the following program
statistics:

_Y___	a.	The number of emission testing sites and lanes in use in the
program?

_Y___	b.	The number of equipment audits by station and lane?

_Y___	c.	The number and percentage of stations that have failed
equipment audits?

_Y___	d.	Number and percentage of stations and lanes shut down as a
result of equipment audits?

_Y___	5.	Does the SIP commit to submit a report each July, for January
through December of the previous year, which provides statistics on the
enforcement program?

	a.	For all varieties of enforcement programs, will this report cover
the following program statistics?

__Y__	1.	An estimate of the number of vehicles subject to the program,
including the results of an analysis of the registration data base?

__Y__	2.	The percentage of motorist compliance based upon a comparison
of the number of valid final tests with the number of subject vehicles?

__Y__	3.	The total number of compliance documents issued to stations?

__Y__	4.	The number of missing compliance documents?

__Y__	5.	The number of time extensions and exemptions granted to
motorists?

__Y__	6.	The number of compliance surveys conducted, number of vehicles
surveyed in each, and the compliance rates found?

	b.	For registration denial enforcement programs, will this report cover
the following program statistics?

__Y__	1.	An assessment of the program's efforts and actions to prevent
motorists from falsely registering vehicles out of the program area or
falsely changing fuel type or weight class on the vehicle registration?

__Y__	2.	The results of special studies to investigate these activities?

__Y__	3.	The number of registration file audits, including

__Y__	i.	The number of registrations reviewed?

__Y__	ii.	Compliance rates found?

	c.	For computer-matching based enforcement programs, will this report
cover the following program statistics?

__NA__	1.	The number and percentage of subject vehicles that were tested
by the initial deadline, and by other milestones in the cycle?

__NA__	2.	An assessment of the program's efforts to detect and enforce
against motorists falsely changing vehicle classifications to circumvent
program requirements, and the frequency of this type of activity?

__NA__	3.	The number of enforcement system audits, and the error rate
found during those audits?

	d.	For sticker-based enforcement systems, will this report cover the
following program statistics?

__Y__	1.	An assessment of efforts to prevent, detect, and enforce
against sticker theft and counterfeiting, and the frequency of such
activity?

__Y__	2.	A report on efforts to detect and enforce against motorists
falsely changing vehicle classifications to circumvent program
requirements, and the frequency of this type of activity?

__NA__	3.	The number of parking lot sticker audits conducted, the number
of vehicles surveyed in each, and the noncompliance rate found during
those audits?

__Y__	5.	Does the SIP commit to submit the first biennial report by July
1996 (in basic I/M programs) or July 1997 (in enhanced programs)?  Will
the report include:

__Y__	a.	Changes made in program design, funding, personnel levels,
procedures, regulations, and legal authority, with detailed discussion
and evaluation of the impact on the program of all such changes?

__Y__	b.	Any weaknesses or problems identified in the program?

__Y__	c.	Steps taken to correct those problems, the result, and any
future efforts planned?

.c.§51.367	Inspector Training and Licensing or Certification

__Y__	A.	Are all required elements present in this portion of the SIP?
See section 17 of each state’s SIP narrative.

__Y__	1.	Evidence that the state has the authority to require mandatory
inspector training?

__Y_	2.	Does the SIP contain a description of inspector training
program?

__Y__	3.	Does the SIP contain a description of the written and hands-on
tests?

__Y__	4.	Does the SIP contain a description of the licensing or
certification process?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Are inspectors required to receive formal training?

__Y__	a.	Does the training program at a minimum cover the following
areas:

__Y__	1.	Air pollution problems (causes and effects)?

__Y__	2.	Purpose, function and goal of state inspection program?

__Y__	3.	State inspection regulations?

__Y__	4.	Test procedures and rationale for their design?

__Y__	5.	Emission control devices, configuration and inspection?

__Y__	6.	Test equipment operation, calibration and maintenance?

__Y__	7.	Quality control procedures?

__Y__	8.	Public relations?

__Y__	9.	Safety and health issues related in the inspection process?

__Y__	b.	Does the state commit to monitoring and evaluating the training
program delivery, if the training is not administered by the program?  

__Y__	2.	Are inspectors required to be licensed or certified?

__Y_	a.	Must inspectors pass a written test covering the elements
required in the training program above?

__Y__	c.	Is a correct score of at least 80%  (or lower if an
occupational analysis justifies) required to pass the test?

__Y__	d.	Does the inspector have to demonstrate the ability to, without
assistance, conduct a proper inspection, properly use equipment, and
follow other procedures in order to pass the training course?

__NA__	e.	In test-only programs, is the certification or licensing
administered by a state agency or contractor other than the testing
department or testing contractor?

__Y__	3.	Are inspectors required to be relicensed or recertified?

__Y__	a.	Is there a requirement that the license or certification
expires within 2 years?

__Y__	b.	Is there a requirement that upon expiration of the license or
certification, the inspector undergoes either a refresher training
course prior to license or certification renewable or a comprehensive
skill examination and determination of inspector competency?

.c.§51.368	Public Information and Consumer Protection

__Y__	A.	Are all required elements present in this portion of the SIP? ?
See section 18 of each state’s SIP narrative.

__Y__	1.	Does the SIP include a plan for informing the public on an
ongoing basis throughout the life of the I/M program?

__Y__	2.	Does the SIP include a plan to offer motorists that fail the
test repair facility performance data and diagnostic information in
enhanced areas?

__Y__	4.	Does the SIP include provisions to protect the public from
fraud and abuse by inspectors, mechanics, and others involved in the I/M
program?

__Y__	B.	Is this portion of the SIP approvable?

	1.	Does the public awareness plan include strategies to educate the
public on the:

__Y__	a.	The air quality problem?

__Y__	b.	The requirements of federal and state law?

__Y_	c.	The role of motor vehicles in the air quality problem?

__Y__	d.	The need for and benefits of an inspection program?

__Y__	e.	The ways to maintain a vehicle in a low-emission condition?

__Y__	f.	How to find a qualified repair technician? 

__Y__	g.	The requirements of the I/M program?

__Y__	2.	For motorists that fail the test in enhanced areas, will the
information offered to motorists include:

__Y__	a.	A list of repair facilities in the area and statistics on:

__Y__	1.	The number of vehicles submitted for a retest after repair?

__Y__	2.	The percentage of vehicles passing on first retest?

__Y__	3.	The percentage of vehicles requiring more than one trip to
comply?

__Y__	4.	The percentage of vehicles receiving a waiver?

__Y__	b.	Software-generated, interpretive diagnostic information based
on the particular portions of the test that were failed?

__Y__	3.	Does the consumer protection provisions include:

__Y__	a.	A challenge mechanism to contest the result of an inspection?

__Y__	b.	Protection of whistle blowers and following up on complaints by
the public or others involved in the process?

__Y__	c.	A program to assist owners in obtaining warranty covered
repairs for eligible vehicles that fail a test?

.c.§51.369	Improving Repair Effectiveness

___Y_	A.	Are all required elements present in this portion of the SIP?
Included as section 19 of each state’s SIP narrative.

___Y_	1.	Does the SIP include legal authority, rules or procedures
necessary to conduct performance monitoring, provide technical
assistance, and insure training is available?

___Y_	B.	Is this portion of the SIP approvable?

___Y_	1.	Does the SIP provide for technical assistance related to
diagnosis and repair of vehicles that fail the I/M test to the repair
industry?

___Y_	a.	Is there a mechanism to regularly inform repair facilities of
changes in the inspection program, training program, common problems
being found with particular engine families, diagnostic type and the
like?

___Y_	b.	Does the SIP provide for the establishment of an ongoing hot
line service to assist technicians with specific repair problems, and
answer legal and technical questions?

___Y_	2.	In enhanced areas, is there a system of repair facility
performance monitoring?

___Y_	a.	Does this system include gathering statistics, by repair
facility, on:  

___Y_	1.	The number of vehicles submitted for a retest after repair?

___Y_	2.	The percentage of vehicles passing on first retest?

__Y__	3.	The percentage of vehicles requiring more than one trip to
comply?

__Y__	4.	The percentage of vehicles receiving a waiver?

__Y__	b.	Is a summary of the performance of individual motor vehicle
repair facilities, that conveys information on the relative ability of
repair facilities in providing effective and convenient repair, provided
to the public at the time of initial failure?

__Y__	c.	Does the system provide feedback to individual repair
facilities on a regular basis (at least annually)?

__Y__	d.	Is a completed repair form indicating which repairs were
performed, any recommended additional repairs, and identification of the
facility that performed the repairs required as a prerequisite for
retest? 

__Y__	3.	Is repair technician training available which includes the four
areas listed below or are there provisions to make such training
available?

__Y__	a.	Diagnosis and repair of malfunctions in computer controlled,
closed-loop vehicles?

__Y__	b.	Application of emission control theory and diagnostic data to
the diagnosis and repair of failures on the transient emissions test and
the evaporative system functional test?

__Y__	c.	Utilization of diagnostic information on systematic or repeated
failures observed in the transient test and the evaporative system
function test?

__Y__	d.	General training on the various subsystems related to engine
emissions control?

.c.§51.370	Compliance with Recall Notices

__Y__	A.	Are all required elements present in this portion of the SIP? 
? See section 20 of each state’s SIP narrative.

__Y__	1.	Does the SIP include provisions to ensure vehicles subject to
enhanced I/M receive all required recall repairs? Once EPA makes
available.

__Y__	2.	Does the SIP include legal authority to require owners or
lessees of vehicles with unresolved recalls to show proof of compliance
with recall in order to complete the inspection or registration cycle?  

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Are motorists required by regulations to obtain recall repairs
in order to complete the inspection process or before obtaining a
vehicle registration?

__Y__	a.	Is there a process for notifying motorists of a specific recall
requirement prior to the test deadline? Awaiting EPA action.

__Y__	b.	If so, is compliance required on the next registration or
inspection date after state notification of recall was received by the
vehicle owner?

__Y__	c.	If not, are motorists required to comply when notified at the
station of the outstanding recall, prior to completing the inspection or
registration requirement?  

__Y__	2.	Are quality control methods used to insure recall repairs are
properly documented and tracked?

__N__	a.	Are vehicles with unresolved recalls automatically identified
as noncomplying when they show up for testing or registration?

__N__	b.	Does the SIP commit to updating the list of unresolved recalls
at least quarterly? Awaiting EPA action.

__Y__	c.	Is there a means to document repairs on vehicles that have
received repairs but remain on the recall list?

__N__	d.	Does the data system include the recall campaign numbers for
vehicles with unresolved recalls?  

__N_	3.	Does the SIP commit to submitting an annual report providing
information on recall compliance including 

.c.§51.371	On-road Testing

__Y__	A.	Are all required elements present in this portion of the SIP? ?
Included as section 21 of each state’s SIP narrative.

__Y__	1.	In enhanced areas, does the SIP include an on-road testing
program?

__Y__	2.	In enhanced areas, does the SIP include the legal authority
necessary to implement the on-road testing program?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Does the SIP include a detailed description of the on-road
testing program, including:

__Y__	a.	Types of testing to be used?

__Y__	b.	Test limits and criteria?

__Y__	c.	The number of vehicles (percentage of the fleet) to be tested?

__Y__	d.	The budget dedicated to the on-road testing effort?

__Y__	e.	The methods for collecting and reporting the results of on-road
testing?

__Y__	f.	The methods for analyzing and utilizing the results of on-road
testing?

__Y__	g.	The number of employees dedicated to the on-road testing
effort?

__Y__	2.	Are motorists that fail the on-road test required to get an
off-cycle inspection and bring the vehicle into compliance?

.c.§51.372	State Implementation Plan Submissions

__Y__	A.	Are all required elements present in this portion of the SIP?

__Y__	1.	Does the SIP include a schedule of implementation of the
program?

__Y__	B.	Is this portion of the SIP approvable?

__Y__	1.	Does the schedule include milestones for the following:

__Y__	a.	Obtaining enabling or statutory authority?

__Y__	b.	Proposal of draft regulations and final promulgation?

__Y__	c.	Issuance of final specifications and procedures, including
RFPs?

__Y__	d.	Licensing or certification of stations and inspectors?

__Y__	e.	The start of mandatory testing

__Y__	f.	The date full-stringency cutpoints take effect?

__Y__	2.	Does the analysis of emission level targets use current EPA
mobile source emission model meet the performance standards described in
§51.351 or §51.352 of the regulation subpart?

__NA__	a.	If an alternative model approved by the Administrator is used,
does it also meet the same performance standard?

___NA_	3.	If the program is not county wide, does the SIP include a list
of the ZIP codes of areas covered by the program? Statewide programs.

___NA_	4.	Is there a discussion of the required design elements,
including provisions for federal facility compliance?

___Y_	5.	Does the SIP include legal authority requiring or allowing
operation of the I/M program through the applicable attainment date?

___Y_	6.	Is there evidence of adequate funding, resources, implementing
regulations, interagency agreements, and memorandum of understanding?

___Y_	7.	Does the SIP include a description of personnel resources?

.c.§51.373	Implementation Deadlines

___Y_	A.	Are all required scheduling elements present in this portion of
the SIP?

___Y_	1.	Does the SIP include deadlines for implementing the program?

___Y_	B.	Is this portion of the SIP approvable?

___NA_	1.	If the program is a basic, decentralized system, is it
scheduled to be fully implemented by January 1, 1994?

___NA_	2.	If the program is a basic, centralized system, is it scheduled
to be fully implemented by July 1, 1994?

___Y_	3.	If the program is enhanced, are all enhanced features scheduled
to be implemented by January 1, 1995 with the following exceptions?

___NA_	a.	In an area switching from an existing test-and-repair network
to a test-only network, is at least 30% of the subject vehicle
population (statewide) scheduled to be tested starting January 1, 1995?

___NA_	c.	In areas starting new test-only programs and those with
existing test-only programs, does the SIP include a phase-in of new test
procedures between January 1, 1995 and January 1, 1996?

___NA_	b.	Are all subject vehicles scheduled to be tested starting
January 1, 1996?

___NA_	4.	In areas newly required to implement I/M (not subject as of
November 15, 1992)

___NA_	a.	Does the SIP include implementation:

___NA_	i.	In enhanced areas, within 2 years of obtaining legal
authority?

___NA_	ii.	In basic decentralized areas, within 1 year of obtaining
legal authority?

___NA_	iii.	In basic centralized areas, within 2 years of obtaining
legal authority?

___NA_	b.	Has the legal authority for the program been obtained during
the first applicable legislative session?

