The State of New Jersey

Department of Environmental Protection

Proposed Revisions to the Enhanced Inspection and Maintenance (I/M)
Program for the State of New Jersey

Proposed I/M Program Modeling and Revised Performance Standard Modeling 

SIP Revision

December, 2009  TC  Preface tc \l1 "Preface 

This document is a revision to the State of New Jersey’s Inspection
and Maintenance (I/M) program State Implementation Plan (SIP). 
Specifically, this document provides the United States Environmental
Protection Agency (USEPA) with documentation on the emission impacts
that will result from proposed changes to New Jersey’s enhanced I/M
program including a comparison to the USEPA I/M performance standard. 
The proposed changes to New Jersey’s I/M program include: the
establishment of a new exhaust emission test for gasoline fueled
vehicles called the Two Speed Idle (TSI) test that will replace both the
ASM5015 and 2500 RPM tests, the elimination of repair cost waivers, the
increase in the inspection frequency (to annual) for certain classes of
commercial vehicles such as limousines, taxis and jitneys, and the
subjecting of light duty diesel vehicles to emissions testing.  The
primary reason for this SIP revision is to satisfy the USEPA's
requirements for the State to implement the changes to the I/M program.
The State of New Jersey entered into a contract, effective May 6, 2008,
with Parsons Commercial Technology Group Inc. that includes the
transition to the proposed I/M program. 

 

  TC  Acknowledgments tc \l1 "Acknowledgments 

The New Jersey Department of Environmental Protection (NJDEP)
acknowledges the efforts and assistance of the many agencies and
individuals whose contributions were instrumental in the preparation of
this SIP revision.  In particular, the NJDEP wishes to acknowledge the
many individuals within the New Jersey Department of Transportation
(NJDOT), the New Jersey Motor Vehicle Commission (NJMVC), the USEPA
Region II, and the staff within the NJDEP for their assistance and
guidance.

  TC  Table of Contents tc \l1 "Table of Contents :

  TOC \f  Preface	  PAGEREF _Toc17095405 \h  i 

Acknowledgments	  PAGEREF _Toc17095406 \h  i 

Table of Contents	  PAGEREF _Toc17095407 \h  ii 

List of Tables	  PAGEREF _Toc17095408 \h  ii 

List of Appendices	  PAGEREF _Toc17095409 \h  ii 

Acronyms and Abbreviations	  PAGEREF _Toc17095410 \h  ii 

Executive Summary	  PAGEREF _Toc17095411 \h  ii 

I.	Introduction	  PAGEREF _Toc17095412 \h  2 

A.	Background	  PAGEREF _Toc17095413 \h  2 

B.	Purpose	  PAGEREF _Toc17095414 \h  2 

II.	proposed I/M Program Modeling and revised performance standard
modeling	  PAGEREF _Toc17095424 \h  2 

A.	Background 	  PAGEREF _Toc17095425 \h  2 

B.	Modeling Parameters and Assumptions	  PAGEREF _Toc17095427 \h  2 

C.	Modeling Results	  PAGEREF _Toc17095428 \h  2 

III.	Conclusion	..25

 

List of Tables tc \l1 "List of Tables :

  TOC \t "Caption" \c  Table 1: Performance Standard and NJ Enhanced I/M
Program Designs 	  PAGEREF _Toc17003120 \h  2 

Table 2: Various Vehicle Categories and Applicable Emission Tests	 
PAGEREF _Toc17003121 \h  2 

Table 3: Other Modeling Assumptions	  PAGEREF _Toc17003122 \h  2 

Table 4: Modeling Results	25

 

List of Appendices tc \l1 "List of Appendices :

Appendix I: History of New Jersey’s I/M SIP

Appendix II: Documentation of the Emission Benefit Estimates for the
Performance of I/M on Light Duty Diesel Vehicles

Appendix III: MOBILE Input and Output files for 2013 Modeling of the NJ
Existing I/M Program, NJ Proposed I/M Program and USEPA I/M Performance
Standard (available in electronic format)

Appendix IV: Calculation Spreadsheet for 2013 Modeling of the NJ
Existing I/M Program, NJ Proposed I/M Program and USEPA I/M Performance
Standard

Appendix V: Public Participation		

Acronyms and Abbreviations tc \l1 "Acronyms and Abbreviations :

ASM	Acceleration Simulation Mode

CAA				Clean Air Act

CIF	Central Inspection Facility

CO	Carbon Monoxide

EGR	Exhaust Gas Recirculation

Fed. Reg.	Federal Register

gpm	Grams Per Mile

HC	Hydrocarbons

HDGV	Heavy Duty Gasoline Vehicle

I/M	Inspection and Maintenance

LDGT	Light Duty Gasoline Truck

LDGV	Light Duty Gasoline Vehicle

LEV	Low Emission Vehicle

MY	Model Year

NAAQS	National Ambient Air Quality Standards

NHSDA	National Highway System Designation Act

NJDEP	New Jersey Department of Environmental Protection

NJMVC	New Jersey Motor Vehicle Commission

NJDOT	New Jersey Department of Transportation

NOx	Oxides of Nitrogen

OBD	On-Board Diagnostics

OTR	Ozone Transport Region

PCTG	Parsons Commercial Technology Group Inc.

PCV	Positive Crankcase Ventilation

PIF	Private Inspection Facility

ppm	Parts Per Million

psi	Pounds Per Square Inch

ROP	Rate of Progress

RPM	Revolutions Per Minute

SIP	State Implementation Plan

TSI	Two-Speed Idle

USEPA	United States Environmental Protection Agency

VMT	Vehicle Miles Traveled

VOC	Volatile Organic Compounds

ZEV	Zero Emission Vehicle

Executive Summary tc \l1 "Executive Summary 

This document is a revision to the State of New Jersey’s enhanced
Inspection and Maintenance (I/M) State Implementation Plan (SIP) due to
proposed changes to the I/M program.  This SIP revision includes
emission modeling that quantifies the impacts of the proposed program
changes including a comparison to the USEPA performance standard. The
primary reason for this SIP revision is to satisfy the USEPA's
requirements for the State to implement the changes to the I/M program.
It demonstrates that the proposed changes to the I/M program do not
compromise the State’s efforts to meet and/or maintain National
Ambient Air Quality Standards (NAAQSs) for ozone or carbon monoxide.  It
also demonstrates that New Jersey’s I/M  program continues to meet the
USEPA I/M performance standard after the proposed changes to the I/M
program are implemented.  The State of New Jersey entered into a
contract, effective May 6, 2008, with Parsons Commercial Technology
Group Inc. that includes the transition to the proposed enhanced I/M
program.  In addition, the Department of Environmental Protection
(Department) is finalizing new rules and rule amendments, and the Motor
Vehicle Commission is finalizing changes to both regulation and law,
that implement these changes to the I/M program. 

New Jersey has proposed numerous changes to its enhanced I/M program to
be fully implemented by 2012.  These changes include the following:

Emission tests will no longer require the use of a dynamometer. Emission
tests will include On-Board Diagnostics (OBD), gas cap, visible smoke
and two-speed idle (TSI) tailpipe tests. The TSI test replaces both the
ASM5015 and 2500 RPM tests.

Repair cost waiver provisions have been removed.

Gas cap testing is excluded for vehicles of model year 2001 and newer.

Certain classes of commercial vehicles, limousines, taxis and jitneys
will require annual (more frequent) inspection.

Central Inspection Facilities (CIFs) will not conduct any inspections
for vehicles less than four years old, or for any cars at change of
title. If a motorist wants a courtesy inspection, he/she will be
directed to Private Inspection Facilities (PIFs). 

Light duty diesel vehicles will now be subject to emission testing.  

This SIP revision evaluates the emission impacts of the proposed
enhanced I/M program changes by comparing emission factors calculated
using the USEPA MOBILE6 model for the existing and proposed programs. 
The emission factors were estimated for 2013 which follows the expected
implementation of the proposed enhanced I/M program. The model results
indicate that there is no significant difference between emission
factors for the existing and proposed enhanced I/M programs for ozone
precursors (VOCs and NOx).  The proposed enhanced I/M program provides a
small reduction in the predicted carbon monoxide emission factor
relative to the existing program.

This SIP revision also revises the State's enhanced I/M performance
standard modeling to account for the proposed I/M program changes.  This
revision shows that the State's proposed enhanced I/M program meets the
low enhanced performance standard.



I.	Introduction tc \l1 "I.	Introduction :

	  TC  A.	Background tc \l2 "A.	Background 

In accordance with the requirements of the Clean Air Act (CAA), the
State of New Jersey implemented an enhanced Inspection and Maintenance
(I/M) program on December 13, 1999.  The implementation of this program
continues to be an integral part of New Jersey’s plan to attain and
maintain compliance with the health-based National Ambient Air Quality
Standards (NAAQS) for ozone and for carbon monoxide.  Reducing the
emissions of carbon monoxide, as well as emissions of volatile organic
compounds (VOCs) and oxides of nitrogen (NOx) (precursors to ozone
formation), will help the State in its efforts to improve its air
quality and protect the health and welfare of its citizens.  

New Jersey’s enhanced I/M program design is a hybrid network system
that consists of both centralized (test-only) and decentralized
(test-and-repair) facilities. A private contractor to the State operates
the centralized portion of the inspection network.  The decentralized
network is comprised of over 1,300 Private Inspection Facilities (PIFs)
that are privately owned and operated, and licensed by the NJMVC to
perform vehicle inspections on behalf of the State.  This hybrid network
design gives motorists a choice as to where to have their vehicles
inspected. 

 

	B.	Purpose tc \l2 "B.	Purpose 

This document revises the State of New Jersey’s enhanced Inspection
and Maintenance (I/M) State Implementation Plan (SIP) due to proposed
changes to the I/M program.  A complete history of New Jersey’s I/M
SIP is provided in Appendix I.  This SIP revision includes emission
modeling that quantifies the impacts of the proposed program changes
including a comparison to the USEPA performance standard. The primary
reason for this SIP revision is to satisfy the USEPA's requirements for
the State to implement the changes to the I/M program.  It demonstrates
that the proposed changes to the enhanced I/M program do not compromise
the State’s efforts to meet and/or maintain National Ambient Air
Quality Standards (NAAQSs) for ozone or carbon monoxide.  It also
demonstrates that New Jersey’s I/M program continues to meet the USEPA
I/M performance standard after the proposed changes to the I/M program
are implemented.  The State of New Jersey entered into a contract,
effective May 6, 2008, with Parsons Commercial Technology Group Inc.
that includes the transition to the proposed enhanced I/M program.  The
Department of Environmental Protection (Department) is finalizing new
rules and rule amendments to N.J.A.C. 7:27-14, 7:27-15, 7:27B-4 and
7:27B-5 that implement these changes to the I/M program.  In addition,
the Motor Vehicle Commission is finalizing changes to both regulation
and law to implement these changes. 

II.	Proposed I/M Program Modeling and Revised Performance Standard
Modeling tc " III.	Revised Performance Standard Modeling " \l 1 

	A.	Background   tc " A.	Background and History " \l 2 

 

As part of its final rule for Inspection and Maintenance (I/M)
requirements, the USEPA established a “model” program for areas that
were required to implement enhanced I/M programs.  This model program is
termed by the USEPA as the “I/M performance standard” and is defined
by a specific set of program elements.  The purpose of the performance
standard is to provide a gauge by which the USEPA can evaluate the
adequacy and effectiveness of each state’s enhanced I/M program.  As
such, states are required to demonstrate that their enhanced I/M
programs achieve applicable area-wide emission levels for the pollutants
of interest that are equal to, or lower than, those which would be
realized by the implementation of the model program.  The USEPA allows
for a margin of error of +/- 0.02 gpm in determining compliance with the
performance standard.

Originally, the USEPA only designed one enhanced performance standard,
as specified at 40 C.F.R. §51.351, and required all enhanced I/M
program areas to meet or exceed that standard.  However, on September
18, 1995, the USEPA promulgated the “low” enhanced performance
standard.,   The low enhanced performance standard is a less stringent
enhanced I/M performance standard established for those areas that have
an approved SIP for Rate of Progress (ROP) for 1996, and do not have a
disapproved plan for ROP for the period after 1996 or a disapproved plan
for attainment of the air quality standards for ozone or carbon
monoxide.  

New Jersey is currently demonstrating compliance with the Clean Air Act
requirements for ROP and attainment and is therefore now only required
to meet the “low” enhanced performance standard.  The revised
performance standard modeling included as part of this submittal is
designed to show attainment of the low enhanced performance standard.

 

In accordance with the USEPA’s final rule for I/M requirements, a
state must design and implement its enhanced I/M program such that it
meets or exceeds, within +/- 0.02 grams per mile (gpm), a minimum
performance standard.  The performance standard is expressed as average
gpm emission levels from area-wide highway mobile sources as a result of
the enhanced I/M program.  Areas must meet the performance standard for
the pollutants that cause them to be subject to the enhanced I/M
requirements.  New Jersey was required to implement its enhanced I/M
program because of its non-attainment status for two criteria air
pollutants; ozone (of which volatile organic compounds (VOCs) and oxides
of nitrogen (NOx) are precursors) and carbon monoxide.  

The USEPA’s final rule on I/M requirements also requires that the
equivalency of the emission levels achieved by the State’s enhanced
I/M program design compared to those of the performance standard must be
demonstrated using the most current version of USEPA’s mobile source
emission model.   Currently, the latest version is MOBILE 6.2.03 (dated
September 24, 2003), which was used for this analysis.

	B.	Modeling Parameters and Assumptions tc \l2 "C.	Other Modeling
Parameters and Assumptions 

Table 1 outlines the main program parameters of the low enhanced
performance standard model program.  In addition, this table presents
New Jersey’s enhanced I/M program design for both the existing and
proposed programs for evaluation year 2013. The emission factors were
estimated for 2013 because it follows the expected implementation of the
proposed enhanced I/M program.  Although each state must model the
performance standard using the parameters specified in Table 1, the
performance standard emission factor results will vary for each state. 
This variation is the result of the use of state-specific inputs such as
registration distribution and vehicle miles traveled (VMT) mix.  Other
local parameters, such as fuel type, add to state variations in
determining the emission factors for the USEPA’s performance standard
program.

Table 1: Performance Standard and NJ Enhanced I/M Program Designs 

Program Element	

Low Enhanced

Performance Standard	

New Jersey’s Existing Enhanced

I/M Program 	

New Jersey’s Proposed Enhanced

I/M Program 



Network Type	

100% centralized	

hybrid – 70% centralized/30%

decentralized	

hybrid - 70% centralized/30%

decentralized

Credit Assumed for Decentralized Program	

NA	

80%	

80%



Program Start Date	

19831	

1974	

1974



Test Frequency	

annual	

biennial2	

biennial2



Emission Standards	

Those specified at 40 C.F.R. Part 85, Subpart W	

Initial ASM5015 exhaust emission standards	

Two-Speed Idle Standards of 1.2% for carbon monoxide and 220ppm for HC



Model Year (MY) Coverage	

1968 and later MY	

all vehicles not specifically exempt	

all vehicles not specifically exempt



Vehicle Type Coverage	

All light-duty gasoline-fueled vehicles and trucks (up to 8,500 lbs.
GVWR)	

All gasoline-fueled vehicles and trucks (both light and heavy duty
vehicles)	

All gasoline-fueled vehicles and trucks (both light and heavy duty
vehicles)



Exhaust Emission Test	

Idle - 1968-2050 MY

	

OBD  - 1996 and later MY beginning 6/1/03

ASM5015 – 1981-1995 MY amenable to dyno. testing

2500 RPM test – certain exempt vehicles and those 1981 and newer MY
not amenable to dyno. testing

Idle - pre-1981 and HDGVs	

OBD  - 1996 and later MY beginning 6/1/03

Two-Speed Idle – 1981-1995 MY 

Idle - pre-1981 and HDGVs



Visual Inspections	

Positive Crankcase Ventilation (PCV) valve -- 1968 – 1971 MY inclusive

Exhaust Gas Recirculation (EGR) valve – 1972 and newer	

Visual inspection of the catalytic converter, presence of a gas cap, 
and fuel inlet restrictor -- 1975 and newer (beginning calendar 1985)	

Visual inspection of the catalytic converter, presence of a gas cap, 
and fuel inlet restrictor -- 1975 and newer (beginning calendar 1985)



Evaporative System Function Checks	

N/A	

Gas Cap Testing – 1971 and later vehicles3 (beginning calendar year
1998)	

Gas Cap Testing – 1971 – 2000 MY inclusive3 (beginning calendar year
1998)



Pre- 1981 MY Stringency	

20%	

30%	

30%



Waiver Rate	

3%	

3%4	

0%



Compliance Rate	

96%	

98%	

98%



Evaluation Date5	

January 1, 2002	

January 1, 2013	

January 1, 2013



On-Road Testing	

0.5% of the subject vehicle population or 20,000 vehicles (whichever is
less)	

0.5% of the subject vehicle population or 20,000 vehicles (whichever is
less)	

0.5% of the subject vehicle population or 20,000 vehicles (whichever is
less)

1 For programs with existing I/M programs, like New Jersey’s basic I/M
program.

2 Except for new vehicles of model year 2000 or later purchased after
January 1, 2003.  These vehicles are exempt from their first emission
inspection for two inspection cycles (i.e., four years) and thereafter
must be inspected biennially (or once every other year).

3 Only those pre-1981 vehicles that were equipped with sealed gas caps
will be subject to the gas cap check. The State estimates that model
year vehicles prior to 1970 were not equipped with a sealed gas cap.

4 The State assumed a zero percent waiver rate for pre-1981 vehicles as
these vehicles are not eligible for a waiver based on the NJMVC
inspection rules.

5 For all scenarios, summer season and temperatures were used for
VOC/NOx evaluations, while winter season and temperatures were used for
carbon monoxide evaluations. 

The remainder of this section discusses in detail the various New Jersey
program parameters used to model the existing and proposed enhanced I/M
programs.  The State has also included, in Appendices II and III of this
document, the MOBILE6 input and output files and the spreadsheet that
compiles the results.  

 

1.	Network Type:

New Jersey’s enhanced I/M program is comprised of a hybrid network of
both centralized test-only facilities and decentralized test-and-repair
facilities. The State has assumed a 70/30 CIF/PIF split for its enhanced
I/M network (that is, 70 percent of the vehicle owners are expected to
pass inspection at a centralized inspection facility and the remaining
30 percent are expected to pass inspection at a decentralized private
inspection facility). 

New Jersey claimed, in accordance with the flexibility afforded states
by the NHSDA, that the decentralized portion of its enhanced I/M program
would be 80 percent as effective as the centralized portion of its
program. As part of its August 31, 2001 enhanced I/M SIP revision
submittal, New Jersey demonstrated that its private inspection network
is achieving this 80 percent assessment. In fact, this analysis showed
that the State was conservative in its initial 80 percent estimation. 
In addition, the effectiveness of the private inspection network may
have increased further after the introduction of OBD testing. 
Therefore, New Jersey has assumed 80 percent credit for the
decentralized portion of its program.

 

To address the State's inspection facility type split and the 80 percent
credit for the decentralized portion of the program, the NJDEP
calculated an overall I/M effectiveness rate.  The I/M effectiveness
rate was 94 percent (that is, 0.70 * 100 percent + 0.30 * 80 percent). 
This rate was used as an input to the MOBILE6 model to account for New
Jersey’s specific network type.

2.	Start  Date:

The I/M program start date is defined as the date on which vehicles were
first inspected using an evaporative or tailpipe exhaust emission
inspection in the State.  As such, for New Jersey this date is 1974 (all
modeling dates are assumed to be January 1 of the given year), the date
when the State implemented its basic I/M program.  Although this is New
Jersey's start date as outlined in the low enhanced performance standard
requirements, the NJDEP considers other programmatic start dates in
determining the final emission factors associated with New Jersey's
program.  The State implemented its enhanced I/M program on December 13,
1999, which, for modeling purposes, is assumed to be January 1, 2000. 
As such, the January 1, 2000 date is assumed in modeling the enhanced
portion of the State's program, while January 1, 1974 continues to be
assumed for the basic (idle) portion of the State's program.  Finally,
the State assumed a January 1, 2004 start date for OBD implementation.  

3.	Test Frequency:

The current test frequency of New Jersey’s enhanced I/M program is
biennial (that is, vehicle inspections are required once every two
years).  In addition, starting on January 1, 2003, New Jersey
implemented a 4-year new vehicle exemption.  The 4-year new vehicle
exemption was modeling as a grace period with the age of vehicles first
subject to mandatory I/M program requirements set to 4.

4.	Model Year and Vehicle Type Coverage:

Vehicles currently receive different types of emission tests, depending
on the type and model year of the vehicle.  Pre-1981 vehicles are given
an idle exhaust emission test.  Currently, model year 1981-1995 vehicles
which are: 1) classified as light-duty gasoline-fueled motor vehicles
(LDGVs), or light-duty gasoline-fueled trucks 1 and 2 (LDGT1s and
LDGT2s), 2) amenable to dynamometer-based testing, and 2) not
specifically exempted from enhanced testing, are subjected to the
ASM5015 exhaust emission test.  Those model year 1981-1995 vehicles that
are not amenable to dynamometer testing currently receive a 2500 RPM
test.  All 1996 and newer vehicles receive an OBD inspection unless they
are exempt from that test in which case they receive the applicable
exhaust emission test. 

New Jersey has proposed numerous changes to its enhanced I/M program to
be fully implemented by 2012.  These changes include the replacement of
the ASM5015 and 2500 RPM tailpipe tests with the two-speed idle (TSI)
tailpipe test. Also repair cost waiver provisions have been removed and
gas cap testing is excluded for vehicles of model year 2001 and newer.
Another proposed program change requires certain classes of commercial
vehicles, limousines, taxis and jitneys to receive annual (more
frequent) inspection.  In addition, although it is not modeled by
MOBILE6, it is proposed that light duty diesel vehicles will be subject
to emission testing.  As part of the documentation of the rule changes,
the Department estimated emission reduction benefits of 49 tons per year
of VOC + NOX for the extension of the I/M program to light duty diesel
vehicles.  Details regarding these estimated emission reduction benefits
are provided in Appendix II.    

Table 2 (in Section B.5) shows each vehicle category and the applicable
OBD, exhaust and/or evaporative emission tests to which that vehicle
category is subjected for both the existing and proposed enhanced I/M
programs. 

     

5.	Exhaust Emission Test Type:

The majority of gasoline-fueled motor vehicles inspected as part of the
enhanced I/M program currently receive either an OBD inspection or an
ASM5015 exhaust emission test.  Table 2 outlines the different vehicle
categories and the applicable tests for those categories.



Table 2: Various Vehicle Categories and Applicable Emission Tests

Vehicle Category	

Exhaust Emission Test	

Evaporative Emission Test(s)

	NJ Existing Enhanced Program	NJ Proposed Enhanced Program	NJ Existing
Enhanced Program	NJ Proposed Enhanced Program



pre-1981 vehicles 	

idle

	

idle	

gas cap test only1

	

gas cap test only1

1981-1995   	

ASM50152	

TSI	

gas cap test only	

gas cap test only

1981-1995 vehicles not amenable to dynamometer-based testing	

2500 RPM	

TSI	

gas cap test only	

gas cap test only

1981-1995 low mileage vehicles3	

2500 RPM	

TSI	

gas cap test only	

gas cap test only

1996 -2000 low mileage vehicles3	

OBD

	

OBD	

OBD and gas cap test4	

OBD and gas cap test4

2001 and newer low mileage vehicles3	

OBD

	

OBD	

OBD and gas cap test4	

OBD 

1996-2000 vehicles	

OBD	

OBD	

OBD and gas cap test4	

OBD and gas cap test4 

2001 and later vehicles	

OBD	

OBD	

OBD and gas cap test4	

OBD 

collector motor vehicles5	

exempt	

exempt	

exempt	

exempt

historic motor vehicles	

exempt	

exempt	

exempt	

exempt

1981 and newer vehicles registered as school buses6	

OBD	

OBD	

OBD and gas cap test4	

OBD and gas cap test4

1  Only those pre-1981 vehicles that were equipped with sealed gas caps
will be subject to the gas cap check.  The  State estimates that model
year vehicles prior to 1970 were not equipped with a sealed gas cap.

2 Unless the vehicle is not amenable to dynamometer-based testing or is
specifically exempt.

3 The “low mileage vehicle” category, as required by the enhanced
I/M legislation, is defined and discussed at P.L. 1995, Chapter 112,
Section39:8-2b.(1), approved June 2, 1995.  The “low mileage
vehicle” category is being removed in the proposed enhanced I/M
program because there will no longer be a difference in the test
requirements between low mileage and non-low mileage vehicles for each
model year.  

4 The OBD test includes checks for monitored failures of both the
exhaust and evaporative systems, thereby substituting for traditional
tailpipe and evaporative pressure and purge tests.  In addition to these
checks, the State will also perform a traditional gas cap pressurization
inspection on these vehicles.

5 The “collector motor vehicle” category,  as required by the
enhanced I/M legislation, is defined and discussed at P.L. 1995, Chapter
112, Section39:8-1a., approved June 2, 1995.

6 All gasoline-fueled vehicles registered as school buses in the State
are inspected by the NJMVC's School Bus Inspection Unit. If applicable,
these vehicles receive an OBD test.  School buses not amenable to an OBD
test will receive the 2500 RPM tailpipe test instead of the ASM5015
tailpipe test under the proposed program.   

As part of its last performance standard modeling submittal, the State
estimated the number of vehicles that would be exempt from the ASM5015
exhaust emission test because they were not amenable to dynamometer
testing (i.e., either vehicles which employ full-time, four-wheel drive
or which are installed with non-switchable traction control). This
estimation (10%) was then used to determine the loss in credit
attributed to these vehicles receiving a 2500 RPM test in lieu of the
ASM5015 exhaust emission test.  In 2013 the number of vehicles that
would be exempt from the ASM5015 exhaust emission test will be extremely
small because the vast majority of the vehicles will be receiving OBD
testing.  Therefore for the 2013 model runs that represent the existing
program it is no longer necessary to perform a separate set of runs to
model the loss in credit for these vehicles.  This will no longer be an
issue for the model runs that represent the proposed enhanced I/M
program because the ASM5015 test is being eliminated.   

The NJMVC’s regulations and State statute specifically exempt several
types of vehicles that would otherwise be subjected to enhanced I/M
testing from the enhanced tests or from emission testing as a whole. 
These vehicles include: 1) low mileage vehicles, and 2) collector motor
vehicles.  To determine whether or not a vehicle qualifies for either of
these categories, see the NJMVC’s definitions at N.J.A.C. 13:20-43.1.
Note that the low mileage vehicle category is being removed in the
proposed program because there will no longer be a difference in the
test requirements between low mileage and non-low mileage vehicles for
each model year.  

In addition, the NJMVC’s regulations maintain a vehicle category that
exempts applicable vehicles from basic I/M emission testing.  These
vehicles are classified by the NJMVC as historic motor vehicles.  To
determine whether or not a vehicle qualifies as a historic motor
vehicle, see the NJMVC’s definitions at N.J.A.C. 13:20-43.1 and
N.J.S.A. 39:3-27.3. The NJDEP did not include these vehicles as part of
this revised performance standard modeling for two reasons: (1) the
number of vehicles in these categories was so small that their emissions
were not significant enough to impact the modeling, and (2) the vehicles
in the category, by definition, fell well outside the 25 model year
analysis window examined by the MOBILE model. 

6.	Emission Control Device Inspections:

A visual inspection to determine the presence of a catalytic converter
is performed on all 1975 and newer motor vehicles.  This was assumed in
the State’s revised performance standard modeling.  In addition, the
State assumed that all vehicles subject to the gas cap inspection also
receive a visual gas cap inspection for the presence of a cap and to
examine the cap for any cracks, outside damage, etc.  Finally, the State
included in its revised performance standard modeling fuel inlet
restrictor testing for all applicable model years.  The purpose of the
fuel inlet restrictor test is to determine whether or not a leaded
gasoline pump nozzle could fit into the vehicle’s gasoline inlet,
allowing for the possibility of leaded gasoline usage.  Use of leaded
gasoline interferes with effectiveness of the vehicle’s catalytic
converter.   Although the State began fuel inlet restrictor testing as
part of its annual inspections in June 1990, New Jersey stopped
performing inlet restrictor tests in 1994 because it was no longer
possible for New Jersey motorists to obtain leaded gasoline.  However,
according to a USEPA guidance memorandum on highway source modeling,
states that have, in the past, performed fuel inlet tests for at least
one full cycle (and have required catalyst replacement upon failure) may
claim the SIP credit associated with this testing without future
testing.  Since New Jersey meets these requirements, the State took
emission credit for the fuel inlet restrictor test in this revised
performance standard modeling. 

7.	Evaporative System Function Checks:  

In addition to outlining the exhaust emission tests applicable to each
vehicle category, Table 2 also shows which vehicle categories are
currently subject to the State’s evaporative emission tests. Although
OBD monitors a vehicle's evaporative system, and as such has a
"self-contained" evaporative functional check, the USEPA has recommended
that states needing significant hydrocarbon reductions to meet their
attainment goals should supplement OBD-I/M testing with a separate gas
cap inspection.  This recommendation is based on the fact that when the
USEPA compared failure rates for the evaporative portion of the OBD-I/M
test to the failure rate for the stand-alone gas cap test, they found
that the separate gas cap test was able to identify a substantial number
of leaking gas caps that were not identified by the OBD monitors due to
the different failure thresholds.  For the proposed I/M program the gas
cap applicability is amended to exclude vehicles of model year 2001 and
newer.  This is because by model year 2001 the vehicle manufacturers had
refined their OBD systems to more reliably detect evaporative system
malfunctions and tighter evaporative emission tests were imposed by the
USEPA.    

The pressurized gas cap inspection is designed to insure that the gas
cap seals properly and has no leaks.  In the existing I/M program all
gasoline-fueled motor vehicle manufactured with a sealed gas cap are
subject to this pressured gas cap inspection, which the NJDEP determined
is all 1971 and later vehicles. 

8.	Stringency:

For modeling purposes, a 30 percent emission test failure rate was
assumed for pre-1981 vehicles.  

9.	Waiver Rate:

In accordance with 40 C.F. R. 51.360(d)(1), each state’s SIP must
include “a maximum waiver rate expressed as a percentage of initially
failed vehicles.”  The purpose of this waiver rate is to estimate
emission reduction benefits in a modeling analysis.  In the USEPA
enhanced low I/M performance standard, a 3 percent waiver rate was used.
Using this 3 percent assumption as guidance for its own enhanced I/M
program, New Jersey assumed a 3 percent waiver rate for 1981 and newer
vehicles in its enhanced I/M SIP. 

It should be noted here that under New Jersey’s existing enhanced I/M
program, any vehicle that applies for a waiver must show compliance with
the idle test, in addition to meeting the minimum cost expenditure. 
Since all pre-1981 vehicles receive the idle test as their official
inspection test under the enhanced I/M program, these vehicles are not
eligible for a waiver.  Thus, the pre-1981 waiver rate is assumed to be
zero.  In addition, the State extended the waiver option to those
vehicles failing an OBD inspection, in addition to those failing an
ASM5015 exhaust emission test, so long as they meet the minimum cost
expenditure and pass an idle exhaust emission test.  

The proposed enhanced I/M program has removed the option for vehicles to
comply with emission standards by receiving a waiver.  Waiver rates are
zero for all vehicles in the proposed I/M program.

10.	Compliance Rate:

For modeling purposes, a 98 percent compliance rate was assumed for the
overall enhanced I/M program.

11.	Evaluation Date:

An evaluation date of January 1, 2002 is used for the performance
standard runs.  An evaluation date of January 1, 2013 is used for the
program evaluation runs because the proposed I/M program should be fully
implemented by this date.



In addition to the parameters and assumptions discussed previously in
Subsection B, the NJDEP had to make other assumptions in order to
complete its performance standard and program evaluation modeling.  The
following table shows what those assumptions were and what values where
used to complete the modeling:

	Table 3: Other Modeling Assumptions

Modeling Parameters	

Value Used for Average Summer Runs 

(VOC and NOx)	

Value Used for Average Winter Runs (Carbon Monoxide)



Maximum Temperature (F)	

82.9	

41.2



Minimum Temperature (F)	

66.3	

26.7



Absolute Humidity (grains/pound)	

85.59	

20.00



Speed	

MOBILE6 Defaults	

MOBILE6 Defaults



Mechanic Training and Certification 	

yes - 100%	

yes - 100%



NJ Low Emission Vehicle Program w/o ZEV Mandate 	

yes	

yes



Gasoline RVP (psi) 	

6.8	

15



Oxygenated Gasoline 	

10% Ethanol	

10% Ethanol



C.	Modeling Results tc \l2 "D.	Performance Standard Modeling Results :

The following table shows the emission factors (in grams per mile)
obtained for the USEPA performance standard program, New Jersey’s
existing enhanced I/M program, and New Jersey’s proposed enhanced I/M
program for VOC, NOx and carbon monoxide, respectively.  Modeling files
are provided in Appendix III and the modeling results are summarized in
Appendix IV.

Table 4: Modeling Results

Program Type	VOC (gpm)	NOx (gpm)	Carbon Monoxide (gpm)

USEPA Low Enhanced Performance Standard (2002)	

0.903 - 0.943*	

2.376 - 2.416*	

21.834 - 21.874*

New Jersey Existing Enhanced I/M Program (2013)	

0.349	

0.687	

10.045

New Jersey Proposed Enhanced I/M Program (2013)	

0.348	

0.688	

10.025



* The performance standard values are expressed as a range to account
for the +/- 0.02 

gpm margin for error allowed for by the USEPA.  Therefore, the standards
are met so long as they fall below the upper limit of the range.

IV.	Conclusion tc \l1 "IV.	Conclusion 

As shown in Table 4, the model results indicate that there is no
significant difference between emission factors for New Jersey’s
existing and proposed enhanced I/M programs for ozone precursors (VOCs
and NOx).  

A slight increase in the emission factor for NOx is offset by a slight
decrease in the emission factor for VOCs although the magnitude of the
increases and decreases are well below the USEPA margin of error of +/-
0.02 gpm.  In addition, the emission factors calculated for New
Jersey’s proposed enhanced I/M program do not reflect the emission
reductions associated with the addition of light duty diesel vehicles to
New Jersey’s I/M program.  As part of the documentation of the rule
changes, the Department estimated emission reduction benefits of 49 tons
per year of VOC + NOX for the extension of the I/M program to light duty
diesel vehicles.   

    

The proposed enhanced I/M program provides a small reduction in the
predicted carbon monoxide emission factor relative to the existing
enhanced I/M program.

This demonstrates that the proposed changes to the enhanced I/M program
do not compromise the State’s efforts to meet and/or maintain National
Ambient Air Quality Standards (NAAQSs) for ozone or carbon monoxide. 
Also, as shown in Table 4, the State's proposed enhanced I/M program
meets the USEPA low enhanced performance standard.

  40 C.F.R. §51.351.

   40 C.F.R. §51.351(g)(13).

    60 Fed. Reg. 48029 (September 18, 1995).

  On July 19, 1996, the USEPA also establishing an additional enhanced
I/M performance standard for qualified areas in the Northeast Ozone
Transport Region (OTR), often referred to as the OTR low enhanced
performance standard. The emission reduction targets for the OTR low
enhanced performance standard are less than both the low enhanced
performance standard and the basic performance standard.  The USEPA
established two criteria that areas have to meet in order to be eligible
for the OTR low enhanced performance standard: 1) the standard applies
only in attainment areas, marginal ozone non-attainment areas and
certain moderate ozone non-attainment areas with populations under
200,000 in an OTR and 2) the standard program must be supplemented by
other measures in order to achieve emission reductions equal to or
greater than that which would have occurred had a regular low enhanced
I/M program been implemented.  New Jersey did not meet the criteria to
qualify for use of the OTR low enhanced performance standard.

 40 C.F.R. §51.351(g).

  40 C.F.R. §51.351(g)(13) allows for a margin of error of +/-0.02 gpm
for each pollutant result. 

  40 C.F.R. §51.351(a), 57 Fed. Reg. 52988 (November 5, 1992).

  Ibid.

.§51.351(d), 57 Fed. Reg. 52988, (November 5, 1992).

   Revision to the State Implementation Plan (SIP) for the Control of
Mobile Source Ozone Air Pollution--Enhanced Inspection and Maintenance
(I/M) Program, March 27, 1996, Section 3, Network Type and Program
Evaluation, pages 14-15.

  To determine whether a vehicles is classified as a LDGV, LDGT1, LDGT2,
or HDGV, please refer to the definition section of either of the
NJDEP’s rules for the implementation of the enhanced I/M program at
N.J.A.C. 7:27-15.1 and N.J.A.C. 7:27B-4.1.

 Specifically exempted vehicles are those vehicles which have been
exempted from enhanced emission testing, or alternatively, from emission
testing all together, through NJMVC regulations and statute.  These
vehicles include collector motor vehicles, low mileage vehicles, and
historic motor vehicles.

  Memorandum dated September 16, 1994 from Phil Lorang, then Director of
the Emission Planning and Strategies Division, USEPA to All Regional Air
Directors entitled “Discontinuation of Tail Pipe Lead and Fuel Inlet
Tests.”

  "Performing Onboard Diagnostic System Checks as Part of a Vehicle
Inspection and Maintenance Program", EPA420-R-01015, June 2001.

  40 C.F.R. §51.351(g)(13).

 PAGE   13 

 PAGE   vii 

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