Hamilton county vehicle emissions testing

CASE: CINCINNATI VEHICLE INSPECTION AND MAINTENANCE PROGRAM

The Clean Air Act of 1970 established National Ambient Air Quality Standards (NAAQS) for a number of pollutants, including carbon monoxide (CO) and photochemical oxidants (Ox). A major source of CO and Ox pollution is motor vehicles. The 1977 Amendments to the act required urban areas which fail to meet the CO and Ox standards (non- attainment areas) to establish motor vehicle inspection and maintenance (I/M) programs by December 31, 1987. The plans for these programs must be included in the State Implementation Plans (SIPs) which the states submit to the U.S. Environmental Protection Agency (EPA) to show their efforts to comply to the Clean Air Act. Under vehicle I/M programs, all automobiles and light duty trucks must have their exhaust gases checked at least once a year for CO, Ox, and hydrocarbon (HC) emissions. Owners of vehicles which fail to meet tailpipe emission standards are required to make necessary repairs — up to a maximum of $200 — to bring their vehicles into compliance and have their vehicles reinspected within 30 days. Approximately 30 percent of all vehicles tested fail the initial test, and all but 2 percent of those can be brought into compliance with simple carburetor, fuel injection, and timing adjustments or catalytic converter replacement costing less than $200. Vehicles which cannot be brought into compliance for less than $200 must be tuned to manufacturers' specifications and have a properly functioning catalytic converter and have no indications of tampering with the emission control system. Any attempts to bypass a vehicle's emission control system must be corrected regardless of cost. The Cincinnati, Ohio area is currently in non-attainment of both CO and Ox NAAQSs. The Ohio Environmental Protection Agency (Ohio EPA) is currently developing plans for an I/M program in Hamilton County where Cincinnati is located. The Ohio EPA staff has identified three different program options: 1) inspection by private service stations and garages, 2) inspection at centralized, state franchised inspection stations, and 3) inspection at centralized, state run inspection facilities. Under the private service station and garage option, private service stations and garages which are certified by the state would perform emission inspections. Currently 4,000 private service stations and garages in Hamilton County perform the annual safety inspection of vehicles required by the state. The state recently raised the fee that stations and garages could charge for safety inspection to $4.00. This was after years of complaints by service station operators and garage owners that they were losing money on safety inspections and only provided it as a service to customers. In a recent survey of service stations and garages, the Bureau of Motor Vehicles found that the average time spent on safety inspections is 15 minutes and the new $4.00 fee represented a reasonable charge. Under the private service station and garage option for emission testing, the emission inspection would be piggy-backed onto the annual safety inspection. Private service stations would be allowed to charge an additional $6.00 for the emission inspection. Reinspections of failed vehicles would be free. Ohio EPA also projects that approximately half of the 4,000 service stations and garages in the safety inspection program would drop out of a combined inspection program because they would be unable to recoup the cost of the emission analyzer required for the emission tests. The $6.00 fee is based on an average emission test of 15 minutes at $4.00 plus $2.00 to cover the costs of the emission gas analyzer (400 tests a year on a machine which leases for $800 annually). Program enforcement would be via vehicle registration — as with the safety inspection. The state estimates its cost at $250,000 annually to oversee an I/M program — $100,000 for central office personnel and

vehicle registration personnel, and $150,000 for licensing, inspection, and certification of service stations and garages in the program. Emission testing equipment would have to be tested monthly to guarantee quality control. Under the other two options the state or a private contractor would operate 5 centralized, high volume test facilities in Hamilton County. Each facility would only conduct emission tests and each would handle between 750 and 1000 tests a day. Ohio EPA has requested bids from private contractors interested in providing I/M service. Table 2 summarizes data for the low bidder, along with data for a state operated program. The contractor said that he would charge $4.50 per inspection (with free reinspection) to cover his costs. The contractor would keep the facility open later in the evening than the state, thus reducing the number of inspection stalls and allowing use of lower cost, part-time personnel. Under both contractor and state run programs, the state would incur administrative costs of $100,000 for central office personnel and vehicle registration personnel. The director of Ohio EPA is leaning towards the state operated system because of the $4.00 fee. He/she isn't sure of his/her decision because the private service station and garage option provides additional convenience for motorists, despite its $6.00 fee. In addition, the private contractor who would operate the program under the private, centralized facility option, has been conducting an extensive public relations program espousing the virtues of having a private contractor rather than the state running the program. The contractor points to the local taxes that would be paid by a private contractor and not by the government, and the fact that the contractor would be creating private sector jobs that would stimulate the economy in an area where employment is 6.8 percent. You are a staff analyst at the Ohio EPA and have been asked to do an analysis of the I/M options for the director. You are to present your findings to him/her in a 3 page (900 word maximum) policy brief. Specifically, the director wants a cost effectiveness analysis of the three programs that bring the Cincinnati area into compliance with the Clean Air Act. In addition, the state is given the option of having a semi-annual inspection instead of annual inspections. He/she would also like to know if the benefits of semi-annual inspections merit the additional cost. Information from the EPA criteria document used to set NAAQS is included in Table 4 to help in this analysis.

TABLE 1: GENERAL INFORMATION ON OPTIONS GARAGES AND SERVICE STATIONS CONTRACTOR STATE Number of facilities 2000 5 5 Average distance to inspection station (one way) 2.5 miles 5.9 miles 5.9 miles Average time spent going to inspection station (one way) 12 minutes 25 minutes 25 minutes Average length of emission test 15 minutes 8 minutes