[Federal Register Volume 90, Number 236 (Thursday, December 11, 2025)]
[Proposed Rules]
[Pages 57411-57414]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-22594]


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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R05-OAR-2025-1048; FRL-13020-01-R5]


Air Plan Disapproval; Ohio; E-Check Attestation Provisions

AGENCY: Environmental Protection Agency (EPA).

ACTION: Proposed rule.

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SUMMARY: The Environmental Protection Agency (EPA) is proposing to 
disapprove a revision to the Ohio State Implementation Plan (SIP) 
submitted on July 9, 2025, by the Ohio Environmental Protection Agency 
(Ohio EPA). The revision, which Ohio EPA submitted pursuant to Ohio 
Amended Substitute House Bill 54 (``E-Check Ease Act''), includes 
provisions that would create an alternative to state-run mandatory on-
board diagnostic (OBD) inspections with a self-attestation program that 
allows motorists to self-attest that their vehicles comply with 
emissions requirements. This approach is inconsistent with statutory 
and regulatory requirements for Enhanced inspection and maintenance (I/
M) programs under the Clean Air Act (CAA) and would interfere with 
attainment and reasonable further progress toward the 2015 ozone 
National Ambient Air Quality Standards (NAAQS).

DATES: Comments must be received on or before January 12, 2026.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-R05-
OAR-2025-1048 at https://www.regulations.gov, or via email to 
[email protected]. For comments submitted at Regulations.gov, 
follow the online instructions for submitting comments. Once submitted, 
comments cannot be edited or removed from the docket. EPA may publish 
any comment received to its public docket. Do not submit to EPA's 
docket at https://www.regulations.gov any information you consider to 
be Confidential Business Information (CBI), Proprietary Business 
Information (PBI), or other information whose disclosure is restricted 
by statute. Multimedia submissions (audio, video, etc.) must be 
accompanied by a written comment. The written comment is considered the 
official comment and should include discussion of all points you wish 
to make. EPA will generally not consider comments or comment contents 
located outside of the primary submission (i.e., on the web, cloud, or 
other file sharing system). For additional submission methods, please 
contact the person identified in the FOR FURTHER INFORMATION CONTACT 
section. For the full EPA public comment policy, information about CBI, 
PBI, or multimedia submissions, and general guidance on making 
effective comments, please visit https://www.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT: Francisco J. Acevedo, Air and 
Radiation Division (AR18J), Environmental Protection Agency, Region 5, 
77 West Jackson Boulevard, Chicago, Illinois 60604, (312) 886-6061, 
[email protected]. The EPA Region 5 office is open from 8:30 
a.m. to 4:30 p.m., Monday through Friday, excluding Federal holidays.

SUPPLEMENTARY INFORMATION: Throughout this document whenever ``we,'' 
``us,'' or ``our'' is used, we mean EPA.

I. Background

    The CAA establishes a framework for controlling emissions of ozone 
precursors in areas that do not attain the NAAQS. Section 182 of the 
CAA (42 U.S.C. 7511a) requires that certain ozone nonattainment areas 
implement vehicle I/M programs to identify and repair high-emitting 
vehicles operating in the nonattainment area. Nonattainment areas 
classified as Moderate must adopt at least a ``Basic'' I/M program (CAA 
section 182(b)(4)), and areas classified as Serious or above must adopt 
an ``Enhanced'' I/M program (CAA section 182(c)(3)). Pursuant to the 
CAA and EPA's corresponding implementing regulations at 40 CFR 51 
subpart S, both Basic and Enhanced I/M programs are subject to certain 
performance standards and program administration requirements, 
including mandatory OBD vehicle inspections, corrective action and 
retesting for vehicles that fail inspection, and enforceable program 
mechanisms to ensure compliance.
    The Cleveland-Akron-Lorain metropolitan area in northeast Ohio is

[[Page 57412]]

designated nonattainment for the 2015 ozone NAAQS. The area is 
classified as a Serious ozone nonattainment area effective January 16, 
2025 (89 FR 101901, December 17, 2024). As a result of its 
classification, Ohio is currently required to implement an Enhanced I/M 
program meeting all statutory and regulatory requirements for Serious 
areas.
    Ohio implements ``E-Check'', its SIP-approved vehicle I/M program, 
in the Cleveland-Akron-Lorain metropolitan area.\1\ E-Check has long 
been relied upon in Ohio's SIP to provide emission reductions necessary 
for both reasonable further progress (RFP) and attainment 
demonstrations for multiple ozone standards. The program consists of a 
hybrid network that combines state-contracted centralized inspection 
facilities with a number of decentralized service centers where 
approximately 880,000 vehicles annually with a gross vehicle weight 
rating of up to 10,000 pounds undergo OBD-based testing consistent with 
EPA's I/M regulations at 40 CFR part 51, subpart S. EPA fully approved 
Ohio's I/M program on April 4, 1995, 60 FR 16989, and approved 
revisions to the program on January 6, 1997, 62 FR 646.
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    \1\ Under Ohio's E-Check program, Ohio EPA is required to ensure 
emissions testing is performed in Cuyahoga, Geauga, Lake, Lorain, 
Medina, Portage, and Summit counties.
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    In March 2025, the Ohio General Assembly enacted the ``E-Check Ease 
Act.'' The E-Check Ease Act includes a provision incorporated into Ohio 
Revised Code (ORC) 3704.14(C)(2) that fundamentally alters the State's 
I/M framework. The law creates an alternative compliance pathway under 
which motorists may obtain an ``alternative emissions certificate'' by 
signing a self- attestation form declaring, ``to the best of their 
knowledge,'' that their vehicle complies with State and Federal 
emission requirements. Unlike the current E-Check program, this pathway 
does not involve the direct inspection of the OBD system to check for 
the proper functioning of the vehicle's emissions control systems and 
to ensure repairs when needed. It also provides no civil or criminal 
penalties for submitting a false attestation. The only consequence is 
rejection of the self-attestation form and a requirement to resubmit it 
or undergo a standard inspection.
    The E-Check Ease Act also provides that the addition of the 
alternative emissions certification to Ohio's E-Check program is not 
effective until EPA approves a SIP revision submitted by Ohio EPA 
incorporating this modification of Ohio's I/M program. If EPA approves 
the modification of Ohio's I/M program, Ohio EPA would be required to 
amend their regulations governing the E-Check program contained in Ohio 
Administrative Code (OAC) 3745-26 to include these provisions and 
submit the amended regulations to EPA as a revision to Ohio's OAC 3745-
26 SIP-approved regulations.
    Accordingly, Ohio EPA developed and submitted a SIP revision on 
July 9, 2025, requesting EPA approval of the self-attestation option as 
part of the State's federally enforceable I/M program. Ohio's 
submission included a demonstration under CAA section 110(l), asserting 
that the revision would not interfere with attainment or reasonable 
further progress toward the 2015 ozone NAAQS. Ohio's SIP submission and 
associated supporting documents are available in the docket for this 
action, at https://www.regulations.gov, Docket ID No. EPA-R05-OAR-2025-
1048.

II. EPA's Evaluation of Ohio's SIP Revision

    EPA has carefully reviewed Ohio's July 9, 2025, SIP submission 
requesting approval of an alternative emissions certification process 
within Ohio's existing I/M program considering the requirements of the 
CAA, EPA's implementing regulations, and longstanding program guidance. 
Ohio's July 9, 2025, SIP submission included a copy of the E-Check Ease 
Act that was signed into law on March 31, 2025. In support of the SIP 
revision, Ohio also included a demonstration under section 110(l) of 
the CAA, which prohibits approval of SIP revisions that interfere with 
attainment or reasonable further progress toward the NAAQS. Ohio's 
analysis assumed that 100 percent of eligible motorists could use the 
self-attestation option within one year of implementation.
    In addition, Ohio EPA provided public notice and an opportunity to 
comment on the SIP revision and associated CAA section 110(l) 
demonstration. The State received over 650 comments. Most commenters 
requested elimination of the E-Check program altogether, while others 
either supported the self-attestation option as a modernization or 
opposed it as ineffective and detrimental to air quality. Ohio EPA 
responded to comments and submitted the public notice and response to 
comments as part of the SIP submittal.
    Based on our evaluation, EPA proposes to disapprove the revision 
because it is inconsistent with Enhanced I/M statutory requirements, 
EPA's I/M regulations at 40 CFR part 51, subpart S, and the anti-
backsliding provision of CAA section 110(l).

A. Elimination of Required OBD Inspections

    Section 182(c)(3)(C)(vii) of the CAA explicitly requires Enhanced 
I/M programs to include ``inspection of emission control diagnostic 
systems.'' Similarly, CAA section 202(m)(3) requires I/M program SIPs 
to ``provide for inspection of onboard diagnostic systems.'' EPA's I/M 
regulations at 40 CFR 51.373(g)-(h) further mandate that OBD checks be 
implemented in all Enhanced I/M areas. The Ohio SIP revision would 
offer an alternative to OBD inspections with self-attestation by the 
vehicle owner or lessee, which is not a permissible test method in the 
CAA or EPA's I/M regulations. The absence of direct inspection of the 
motor vehicle removes a critical enforcement mechanism, prevents the 
identification and effectuation of much-needed vehicle emissions 
control systems repairs that would benefit air quality, and undermines 
the performance standard for Enhanced I/M required by the CAA and EPA's 
I/M regulations.

B. Lack of Proof of Corrective Action

    The CAA requires that vehicles failing inspection must demonstrate 
proof of corrective action prior to retesting (CAA section 
182(a)(2)(B)). Under Ohio's proposal, a motorist whose self-attestation 
is rejected may simply amend and resubmit without providing evidence 
that repairs were made. This creates a mechanism that is inconsistent 
with statutory intent and undermines the repair and compliance 
assurance functions that are fundamental elements of I/M programs.

C. Lack of Effective Enforcement Provisions

    Effective program administration is a core element of Enhanced I/M. 
The CAA requires that States employ management and enforcement features 
necessary to ensure program compliance (CAA section 182(a)(2)(B), 
182(c)(3)(B)). EPA regulations require enforceable and meaningful 
penalties for noncompliance, such as for cases of registration fraud 
(40 CFR 51.361(a)(10)). However, Ohio's legislation states that no 
penalty shall apply to a person who the Ohio EPA director has 
determined to have falsified a self-attestation form, other than the 
issuance of a notice directing the person to amend and resubmit the 
attestation. This minimal consequence fails to deter

[[Page 57413]]

fraud and does not meet statutory and regulatory requirements for 
effective enforcement.

D. Interference With Attainment and RFP

    CAA section 110(l) prohibits EPA from approving SIP revisions that 
interfere with attainment of or reasonable further progress towards the 
NAAQS. As mentioned above, Ohio included a section 110(l) analysis as 
Attachment B in its July 9, 2025, SIP submittal. This analysis shows 
that in 2023, 880,832 vehicles were tested, with 55,789 (6.6%) failing 
their initial inspection. Ohio's analysis did not estimate the impact 
to ozone precursor and other pollutant emissions as the result of 
modifications to the I/M program.
    The purpose of I/M programs is not only to identify high-emitting 
vehicles, but also to ensure that effective repairs have been made. A 
self-attestation program does not provide any compliance assurance for 
repairs on these high-emitting vehicles. If self-attestation were to 
replace CAA-mandated test methods, high-emitting vehicles such as the 
approximately 55,000 vehicles that failed initial inspection in 2023 
could continue operating unrepaired.
    Another significant benefit of an OBD I/M test program is the 
reduction of emissions as the result of pre-inspection repairs. Since 
the OBD system allows motorists to see that repairs are necessary via a 
lit Check Engine light and that their vehicle would fail an OBD test 
inspection, many motorists will opt to have their vehicles repaired 
prior to the required periodic inspection to avoid the inconvenience of 
a failed test and a return trip for a retest. Thus, vehicles that fail 
an initial I/M test represent a portion of the vehicles that have their 
emissions reduced as the result of an OBD I/M program that ensures 
repairs for compliance. However, there is no incentive in a self-
attestation program for motorists to get pre-inspection repairs, so a 
self-attestation program would not be expected to get the emission 
reduction benefits from pre-inspection repairs.
    If Ohio's proposed modification to its E-Check program were to be 
approved, tens of thousands of vehicles with malfunctioning emission 
controls could remain in service, increasing ozone precursor emissions 
and jeopardizing attainment of the 2015 ozone NAAQS in the Cleveland-
Akron-Lorain area. This strongly suggests interference with both 
attainment and reasonable further progress.

E. Lack of Statutory Authority for Self-Certification

    While the CAA allows States flexibility in program design (e.g., 
frequency of testing, centralized vs. decentralized networks, 
exemptions for certain newer model years), the CAA and EPA's 
corresponding implementing I/M regulations require actual inspection 
methods to identify high-emitting vehicles. EPA has previously approved 
flexibilities such as remote OBD testing, clean screening using on-road 
sensing, and kiosks (66 FR 18156, April 5, 2001; 72 FR 14235, March 27, 
2007). However, no provision of the CAA authorizes wholesale 
replacement of inspections with self-attestation. As mentioned above in 
section II.A., the CAA is explicit that the ``inspection of onboard 
diagnostic systems'' is a required element of I/M programs.\2\ Thus, 
Ohio's proposed self-attestation approach is not permissible.
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    \2\ CAA section 202(m)(3).
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    EPA notes that, while the CAA and EPA's I/M regulations require 
actual inspection of emission control systems, States retain 
significant flexibility in how these requirements are implemented. For 
example, Ohio and other States have successfully incorporated options 
such as:

--Vehicle model year exemptions (e.g., exempting very new vehicles, 
which are less likely to have emission control failures, or very old 
vehicles not equipped with OBD).
--Modified inspection frequencies (annual versus biennial testing).
--Different inspection network types (centralized test-only facilities 
versus decentralized networks of service stations).
--Remote OBD testing through telematics, which allows certain vehicles 
to transmit OBD information electronically without visiting a station.
--Self-service kiosks or mobile testing units, which can make testing 
more convenient and less intrusive for motorists.
--``Clean screening'' programs using on-road remote sensing devices, 
which allow low-emitting vehicles to be exempted from scheduled testing 
based on demonstrated real-world performance.

    Where these flexibilities have been incorporated, States have 
generally found that public perception of I/M programs is more 
positive, as these approaches are seen as modernized, less burdensome, 
and less intrusive for motorists while still ensuring compliance with 
statutory requirements. Importantly, all of these options retain an 
objective inspection mechanism consistent with Clean Air Act 
requirements and EPA's implementing regulations. In contrast, Ohio's 
proposed self-attestation provision would eliminate the core 
requirement for inspection of OBD systems and therefore cannot be 
considered a permissible flexibility.

III. What action is EPA taking?

    Because the E-Check Ease Act eliminates mandatory OBD testing, 
fails to require proof of corrective action for failing vehicles, and 
lacks enforceable penalties for falsification, EPA determines the SIP 
revision is inconsistent with CAA requirements for Enhanced I/M 
programs (sections 182(c)(3) and 202(m)(3)), EPA's I/M regulations at 
40 CFR part 51, subpart S, and the anti-backsliding provisions of 
section 110(l). Therefore, EPA is proposing to disapprove Ohio's July 
9, 2025, SIP revision. If finalized, Ohio must continue implementing 
its existing Enhanced I/M program or submit a new SIP revision that 
complies with CAA and regulatory requirements.

IV. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review

    This action is not a significant regulatory action and was 
therefore not submitted to the Office of Management and Budget (OMB) 
for review

B. Executive Order 14192: Unleashing Prosperity Through Deregulation

    This action is not expected to be an Executive Order 14192 
regulatory action because this action is not significant under 
Executive Order 12866;

C. Paperwork Reduction Act (PRA)

    This rule does not impose an information collection burden under 
the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 
et seq.).

D. Regulatory Flexibility Act (RFA)

    I certify that this action will not have a significant economic 
impact on a substantial number of small entities under the RFA (5 
U.S.C. 601 et seq.). This action will not impose any requirements on 
small entities. This action is disapproving SIP provisions that are 
inconsistent with CAA requirements for Enhanced I/M programs (sections 
182(c)(3) and 202(m)(3)), EPA's I/M regulations at 40 CFR part 51, 
subpart S, and the anti-backsliding provisions of section 110(l).

[[Page 57414]]

E. Unfunded Mandates Reform Act (UMRA)

    This action does not contain any unfunded mandate as described in 
UMRA, 2 U.S.C. 1531-1538, and does not significantly or uniquely affect 
small governments. The action imposes no enforceable duty on any State, 
local, or Tribal governments or the private sector.

F. Executive Order 13132: Federalism

    This action does not have federalism implications. It will not have 
substantial direct effects on the States, on the relationship between 
the national government and the States, or on the distribution of power 
and responsibilities among the various levels of government.

G. Executive Order 13175: Consultation and Coordination With Indian 
Tribal Governments

    This rule does not have Tribal implications, as specified in 
Executive Order 13175. It will not have substantial direct effects on 
Tribal governments. Thus, Executive Order 13175 does not apply to this 
rule.

H. Executive Order 13045: Protection of Children From Environmental 
Health and Safety Risks

    This action is not subject to Executive Order 13045 because it is 
not 3(f)(1) significant as defined in Executive Order 12866, and 
because EPA does not believe the environmental health or safety risks 
addressed by this action present a disproportionate risk to children 
because it disapproves revisions to a State program that are 
inconsistent with statutory and regulatory requirements for vehicle 
inspection and maintenance programs under the CAA and would interfere 
with attainment and reasonable further progress toward the 2015 ozone 
NAAQS.

I. Executive Order 13211: Actions That Significantly Affect Energy 
Supply, Distribution, or Use

    This action is not subject to Executive Order 13211 because it is 
not a significant regulatory action under Executive Order 12866.

J. National Technology Transfer Advancement Act

    This rulemaking does not involve technical standards.

List of Subjects in 40 CFR Part 52

    Environmental protection, Air pollution control, Incorporation by 
reference, Intergovernmental relations, Nitrogen oxides, Ozone, 
Reporting and recordkeeping requirements, Volatile organic compounds.

    Dated: November 20, 2025.
Cheryl Newton,
Acting Regional Administrator, Region 5.
[FR Doc. 2025-22594 Filed 12-10-25; 8:45 am]
BILLING CODE 6560-50-P