1.  COMMENT: The commentor indicated that he is opposed to the extension
of the new vehicle inspection exemption from four (4) years to five (5)
years but willing to work with the Motor Vehicle Commission (MVC) on a
smooth transition and further changes that will benefit the State
budget, the public and small businesses.  The commentor believes that if
the new vehicle inspection exemption period is extended, the time period
when the motorist will ignore an illuminated Check Engine light will be
extended from 4 to 5 years, polluting the air for an additional year. 

RESPONSE:   The Department evaluated the emission reduction impacts of
the proposed extension of the new vehicle inspection exemption period
using the protocol set forth in the USEPA’s final rule on I/M
requirements.  The USEPA protocol requires a demonstration, using the
most current version of USEPA’s mobile source emission model, that the
equivalency of the emission levels achieved by the State’s proposed
enhanced I/M program design be compared to those of the performance
standard.  Using this protocol, the results of the model indicate that
there is no difference between emission factors for New Jersey’s
existing and proposed enhanced I/M programs for ozone precursors (VOCs
and NOx). For these pollutants the magnitude of the increase in
emissions due to the increased new vehicle exemption period from 4 years
to 5 years is completely offset by the reduction in emissions due to the
increased effectiveness of New Jersey’s Private Inspection Facilities
(PIFs).

The new enhanced I/M program design results in an insignificantly small
increase in the

predicted carbon monoxide emission factor relative to the existing
enhanced I/M

program. The increase is well below the USEPA margin of error of +/-
0.02 grams per mile (gpm).  When stated to 4 significant figures, the
carbon monoxide emission factors are the same. 

 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, the State's new enhanced I/M program meets the USEPA low enhanced
performance standard. 

The Department appreciates the commentor’s willingness to work with
the State on making a smooth transition into the new I/M program.  The
Department is also committed to working with the PIFs, the MVC and other
State agencies to ensure that changes to the inspection program continue
to protect the health of New Jersey’s citizens and its environment. 

2.  COMMENT: The commentor supports upgrading the Private Inspection
Facility (PIF) inspection effectiveness. However, he notes that PIFs
should receive 100% equivalency, and not limit it to 96% as proposed in
the SIP revision. The basis for the commentor’s claim is that it is in
the best interest of PIF inspectors to identify and point out vehicle
defects to their customers. 

RESPONSE: The Department commissioned a study to reevaluate the level of
PIF effectiveness.  The study arrived at a factor of 96% PIF inspection
equivalency for emissions testing. The study compared Centralized
Inspection Facility (CIF) and PIF inspections, assigning a default of
100% credit to CIF inspections. Among the factors examined, the study
looked at emission inspection failure rates and suspected incorrect
emission testing rates for both on-board diagnostics (OBD) and tailpipe
tests. The study’s findings support the commentor’s assertions that
the PIF OBD tests should receive 100% credit. Results from tailpipe
testing, however, are less conclusive and the Department agrees with the
study’s conclusions that it is prudent to retain the previous estimate
of 80% effectiveness. The overall 96% PIF credit results from a weighted
blending of 100% PIF credit for OBD and 80% PIF credit for tailpipe
tests. Since an increasing percentage of tests are now OBD and not
tailpipe, the OBD effectiveness dominates the weighting. 

3.  COMMENT: The commentor feels that the use of OBD effectiveness in
supporting lower rates of in-use deterioration in emissions performance
may be flawed. The commentor further contends that motorists do not
always respond to the OBD malfunction light and may refuse needed
emission repairs if their vehicle is not exhibiting driveability issues
and is not due for an I/M test.  The commentor goes on to state that the
problem of ignoring needed repairs may have become even worse in recent
years as a result of economic concerns reducing money available to
motorists for repairs. The commentor believes that the State is missing
this effect but has no way of calculating it. 

RESPONSE: The rate of motorist response to an illuminated Check Engine
light in between inspection cycles (off-cycle), is a basic function
built into the USEPA emission factor model.  The Department used the
most current version of the model to estimate the emissions impact of 
the proposed changes to the I/M program.  The USEPA will make changes to
the model if key assumptions, such as the motorist’s response rate to
an illuminated MIL change over time.  

4.  COMMENT:  The commentor stated that, although aware that the hearing
was not addressing safety-related inspection issues, the same issue
regarding lack of motorist response to a Check Engine light applies to
safety-related defects.  The commenter stated that his association
members continue to document instances where motorists bring their cars
in for maintenance and are advised of serious safety issues, and now,
without a safety-inspection program and the need to have the
safety-related item corrected in order to pass inspection, they are more
frequently ignored by the motorist.

RESPONSE:  Legislation signed into law on June 28, 2010, directed the
Motor Vehicle Commission to end mechanical inspections on August 1, 2010
for non-commercial vehicles.  The commentor is correct that the
NJDEP’s SIP hearing covered only the emissions-test related aspects of
the I/M program and did not address the mechanical inspection program. 
As such, comments on the mechanical inspection program will not be
addressed in this document.  However, the Department has forwarded the
transcripts from the SIP hearing to the MVC for their information.  

