Environmental Quality BoardHarrisburg, PA

October 16, 2007

Thomas K. Fidler, Deputy SecretaryOffice of Waste, Air and Radiation

Management

Feasibility of Modifying the Pennsylvania Vehicle Emissions Inspection Program

Background on I/M Programs The Clean Air Act Amendments of 1990 require

states to adopt and implement motor vehicle inspection/maintenance (I/M) programs in certain carbon monoxide and ozone nonattainment areas and the Ozone Transport Region.

PA’s federally enforceable I/M Program was approved by EPA and codified in the State Implementation Plan (SIP) at 40 CFR Part 52.2020.

Background (continued) The I/M Program is mandatory in 25 counties in

Pennsylvania; testing and inspection procedures vary by region (Philadelphia, Pittsburgh, Southcentral, and Northern Regions).

ERIE

CRAWFORD

WARREN

FOREST

McKEAN POTTER

CAMERONELKVENANGO

MERCER

BEDFORD

BLAIR

SOMERSET

CAMBRIA

INDIANA

ARMSTRONG

BUTLER

LAWRENCE

BEAVER

ALLEGHENY

WASHINGTON

GREENEFAYETTE

WESTMORELAND

JEFFERSONCLINTON

LYCOMING

SULLIVAN

TIOGA BRADFORDWAYNE

WYOMING

PIKE

LUZERNE

MONROE

SCHUYLKILL

CARBON

LEHIGH

COLUMBIA

BUCKSBERKS

CHESTER

LANCASTER

MONTGOMERY

YORK

LEBANONPERRY

CUMBERLAND

DAUPHIN

JUNIATAM

IFFLIN

UNION

SNYDER

CENTRE

ADAMSFRANKLINFULTON

HUNTINGDON

CLEARFIELD

CLARION

LACKA-WANNA

MON-TOUR

NORTH-UMBERLAND

NORTHAMPTON

DELAWARE

SUSQUEHANNA

PHILADELPHIA

Section 126.451(3) of the PA Clean

Vehicles Program requires:

The Department, in conjunction with PennDOT, to study and evaluate the feasibility of modifying the Pennsylvania Vehicle Emission Inspection Program…considering the additional reductions in NOx, VOCs, and other pollutants to be achieved through implementation of the Pennsylvania Clean Vehicles Program. (25 Pa. Code § 126.451(3) )

Evaluation of the I/M Program Legal

Requirements for program. Requirements of program in broader context of

attaining/maintaining health-based national ambient air quality standards.

Technical Emissions estimation in future years: 2010 and

2018. Benefits and latitude for modification within I/M

requirements.

Constraints for modification of Pennsylvania’s I/M Program

I/M programs are mandatory in ozone transport regions established under the Clean Air Act.

Timely attainment/maintenance of the ozone and fine particulate standards.

Compliance with federal “anti-backsliding” requirements in nonattainment or maintenance areas, which require compensating emission reductions.

Compliance with the applicable I/M federal performance standard.

Compliance with the federally prescribed elements of I/M programs.

Findings The benefits of the I/M program include VOC and NOx emission

reductions needed to achieve and maintain ozone and fine particulate standards.

Striped area indicates additional emissions if I/M program were not in place.

I/M Counties Highway VOC Emissions

0

50

100

150

200

250

2010 2018

tons

per

day

I/M Counties Highway NOx Emissions

0

50

100

150

200

250

300

350

400

2010 2018

tons

per

day

Technical Evaluation Evaluated PA I/M program by area with all other

strategies in place against EPA’s I/M performance standard program with all PA strategies in place.

Both sides of comparison must use PA-specific data with only the I/M program varying.

“Anti-backsliding” and attainment needs are not part of this analysis.

Findings The programs with on-board diagnostics are

projected to continue to meet or slightly exceed the applicable EPA performance standard in 2010 and 2018.

Cost-effective emission reduction benefits to replace any lost through I/M modifications would be difficult to find.

Programs without on-board diagnostics may not produce enough benefits in future years to meet the applicable EPA performance standard as 1996+ vehicles become a larger percentage of fleet.

Conclusion

The emission reductions achieved under PA’s Clean Vehicles Program can not supplant reductions required under the federally mandated enhanced I/M program.

The Clean Vehicles Program, if approved by EPA as a SIP, would be considered a SIP strengthening air quality control measure.

Therefore, the Clean Vehicles Program could not be used to modify the stringency of the I/M program.

Modifications to PA’s I/M Program are not advisable at this time.

Thank YouThomas K. Fidler

Deputy Secretary, Office of Waste, Air and Radiation Management

Joyce E. Epps

Bureau of Air Quality

Kristen Campfield

Office of Chief Counsel

Arleen Shulman

Bureau of Air Quality