UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 1
                        5 Post Office Square, Suite 100
                            Boston, MA  02109-3912

Memorandum

Date: 		August 31, 2017
	
Subject: 	Technical Support Document for Approval of the Rhode Island Vehicle Inspection and Maintenance (I/M) Program
	
To: 		David Conroy, Chief
		Air Programs Branch, Office of Ecosystem Protection (OEP)

From: 		Ariel Garcia, Environmental Protection Specialist
		Air Quality Planning Unit, Air Programs Branch, OEP


This Technical Support Document (TSD) was prepared to support a direct final rulemaking action to approve State Implementation Plan (SIP) revisions submitted on January 28, 2009 and February 17, 2017 by the State of Rhode Island.  These SIP revisions include regulations to update the enhanced motor vehicle inspection and maintenance (I/M) programs in Rhode Island.  The Rhode Island I/M program was previously approved into the SIP on February 9, 2001 (66 FR 9661).  The state's program has since been revised.  Most notably the Rhode Island I/M program has evolved to consist of on-board diagnostic (ODB2) testing of 1996 and newer vehicles, and continues to require that 1995 and older vehicles continue to receive a tailpipe exhaust emissions test using a dynamometer.  This TSD supports approval of the revised program because the standards and requirements will strengthen the Rhode Island SIP, and are consistent with EPA I/M requirements at 40 CFR Part 51.

Background

Rhode Island's I/M program was implemented in 2000.  In 2003, Rhode Island implemented OBD2 testing of 1996 and newer vehicles, which consisted of relaxed testing criteria as OBD2 technology was first phased into the motor vehicle fleet.  In 2008, Rhode Island revised the state's I/M regulations to eliminate the relaxed testing criteria established during the early years of OBD2 technology, making the Rhode Island I/M program's OBD2 testing criteria consistent with most other OBD2 testing programs throughout the country. 

The Rhode Island SIP submittal includes the state's legal authority to perform I/M testing, the state regulations to implement the program, MOVES 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 Rhode Island has met those requirements.

Recommended Action:  I recommend that we approve the SIP revisions submitted by the State of Rhode Island on January 28, 2009 and February 17, 2017.  These SIP revisions update the Rhode Island motor vehicle I/M program which is codified in the Rhode Island Air Pollution Control Regulation No. 34 and the Rhode Island Division of Motor Vehicles' "Rhode Island Motor Vehicle Safety and Emissions Control Regulation No. 1."  The Rhode Island motor vehicle I/M program is intended to eliminate excess emissions from motor vehicles in Rhode Island.   I recommend that EPA approve this program because it will help reduce emissions of volatile organic compounds, nitrogen oxides, and carbon monoxide, and will strengthen the Rhode Island SIP.  As shown in the Attachment, the revised programs are consistent with EPA's I/M rule.  Also, Rhode Island has demonstrated via MOVES modeling runs that the revised program meets the federal enhanced performance standard and achieves greater emissions reductions than the previously approved I/M program.  

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 program
_Y_	2.	Does the SIP include legal authority or rules which establish geographic boundaries for the program?   At Rhode Island General Laws Title 31, Chapter 31-47.1.
_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 program
_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 program
___	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 Rhode Island's SIP narrative.
		Rhode Island submitted modeling runs for calendar years 2015. 2016, and 2017.  Rhode Island utilized the MOVES2014 model to generate emissions (see Appendix K of the Rhode Island SIP submittal's narrative).
		Rhode Island meets the required performance standard evaluation for all pollutants and years modeled.	
_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 modeling 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 program 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? Rhode Island entered into a contract for the emissions testing program which includes 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.  Rhode Island has 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 Rhode Island'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 Rhode Island'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).
_Y_	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 Rhode Island'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_	3.	Are provisions made to allow inspection of vehicles registered in other program areas and for issuance of certificates of compliance or waiver?
_NA_	4.	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_	5.	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_	6.	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 and dynamometer testing.
_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.  
_Y_	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? Rhode Island conducts tailpipe emission tests on all vehicles, but vehicles older than 25 model years old are not required to be repaired in order to be in compliance with the Rhode Island I/M program.  That is, testing of vehicles older than 25 model years old is only advisory.
_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?
_Y_	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 Rhode Island'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 Rhode Island'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?
_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?
_Y_	2.	If compliance via diagnostic inspection is allowed, are approvable policies and procedures specified?
_NA_	a.	Is an IM240 test performed on eligible vehicles? Rhode Island's exhaust test resembles and IM240 test.
_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 program.
_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 suspension.
_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 suspension.
_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: Rhode Island 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 Rhode Island 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 Rhode Island'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 Rhode Island'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?
_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 Rhode Island'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 Rhode Island'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)? 
_Y_	u.	For each test mode, standards for HC, CO, CO+CO2, and NOx? OBD2 testing, only indicates proper operation of emission control components. Tailpipe testing includes test standards for relevant pollutants.
_Y_	v.	Results (Pass/Fail/Not Applicable) for the following visual inspections: 
_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 Rhode Island'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 all 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 Rhode Island'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 Rhode Island'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 Rhode Island'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 Rhode Island's SIP narrative.
_Y_	1.	Does the SIP include provisions to ensure vehicles subject to enhanced I/M receive all required recall repairs? 
_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?
_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?
_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
.c.§51.371	On-road Testing
_Y_	A.	Are all required elements present in this portion of the SIP? ? Included as section 21 of Rhode Island'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 program.
_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?


