Air Pollution: Limited New Data on Inspection and Maintenance Program's
Effectiveness (Letter Report, 03/21/96, GAO/RCED-96-63).
Pursuant to a congressional request, GAO provided information on the
50-percent penalty, also called a discount, that states suffer under the
Environmental Protection Agency's (EPA) Clean Air Act enforcement for
operating vehicle emissions inspection and maintenance (I&M)
test-and-repair networks instead of test networks.
GAO found that: (1) EPA issued the 50-percent discount rule after it
found that test-and-repair networks were less effective in controlling
motor vehicle emissions; (2) since issuing the rule, EPA has not
conducted any studies to obtain new data on the effectiveness of
test-and-repair networks; (3) 14 of the 23 states required to implement
enhanced I&M programs have not conducted studies on the 50-percent
discount, mostly because they implemented, or intended to implement,
test-only programs; (4) the other 9 states did not conduct studies to
assess the relative effectiveness of the two kinds of I&M networks; (5)
California studied relative effectiveness and concluded that there was
little difference between test-and-repair networks and test-only
networks; (6) Georgia is conducting a study, and the preliminary
findings lead Georgia to believe that it should suffer only a 35- to
45-percent discount for its hybrid I&M program; and (7) Congress enacted
legislation to eliminate automatic discounts based on the type of
testing network and allow states 18 months to study their I&M programs'
effectiveness. GAO also found that EPA has allowed the states great
flexibility in implementing enhanced I&M programs by: (1) providing I&M
system models; (2) establishing credits for test-only networks, for
states that require that only certified mechanics perform repairs, and
for less costly testing systems; (3) relaxing performance standards for
states that can still meet their overall targets for reducing emissions.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-96-63
TITLE: Air Pollution: Limited New Data on Inspection and
Maintenance Program's Effectiveness
DATE: 03/21/96
SUBJECT: Motor vehicle pollution control
Air pollution
Motor vehicle repairs
State-administered programs
Data collection operations
Test facilities
Inspection
Environmental law
IDENTIFIER: EPA Vehicle Emission Inspection and Maintenance Program
California
Georgia
******************************************************************
** This file contains an ASCII representation of the text of a **
** GAO report. Delineations within the text indicating chapter **
** titles, headings, and bullets are preserved. Major **
** divisions and subdivisions of the text, such as Chapters, **
** Sections, and Appendixes, are identified by double and **
** single lines. The numbers on the right end of these lines **
** indicate the position of each of the subsections in the **
** document outline. These numbers do NOT correspond with the **
** page numbers of the printed product. **
** **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced. Tables are included, but **
** may not resemble those in the printed version. **
** **
** Please see the PDF (Portable Document Format) file, when **
** available, for a complete electronic file of the printed **
** document's contents. **
** **
** A printed copy of this report may be obtained from the GAO **
** Document Distribution Center. For further details, please **
** send an e-mail message to: **
** **
** **
** **
** with the message 'info' in the body. **
******************************************************************
Cover
================================================================ COVER
Report to the Chairman, Subcommittee on Oversight and Investigations,
Committee on Commerce, House of Representatives
March 1996
AIR POLLUTION - LIMITED NEW DATA
ON INSPECTION AND MAINTENANCE
PROGRAM'S EFFECTIVENESS
GAO/RCED-96-63
EPA's Inspection and Maintenance Program
(160292)
Abbreviations
=============================================================== ABBREV
EPA - Environmental Protection Agency
GAO - General Accounting Office
I&M - inspection and maintenance
Letter
=============================================================== LETTER
B-270865
March 21, 1996
The Honorable Joe Barton
Chairman, Subcommittee on Oversight
and Investigations
Committee on Commerce
House of Representatives
Dear Mr. Chairman:
To reduce and control air pollution, the Clean Air Act requires the
Environmental Protection Agency (EPA) to establish national air
quality standards and prescribes deadlines for states and localities
to attain these standards. The act requires states to develop
strategies for attaining or maintaining the standards and to set
forth their strategies in documents known as state implementation
plans. These plans explain in detail how, and by how much, states or
localities will reduce or control emissions from both mobile and
stationary sources.\1 EPA reviews and approves these plans by
calculating the estimated emission reductions that the planned
actions should achieve and comparing these estimates with the overall
reductions needed.
Because motor vehicles contribute substantially to air pollution,
EPA, in November 1992, issued a rule requiring 83 of the more
seriously polluted areas in 23 states to implement more stringent
programs--called enhanced inspection and maintenance (I&M) programs\2
--for testing and reducing vehicles' emissions.\3 This rule
established credits for the reductions in emissions anticipated from
implementing the various elements of an I&M program. It also allowed
states to vary these elements, including the type of testing network
to be used in periodically testing vehicles' emissions, provided the
overall reductions anticipated from implementing a state's I&M
program would be at least as great as the reductions achievable from
implementing EPA's model, or benchmark, program.
Testing networks, which consist of authorized facilities throughout
an area, may be test-only (inspectors are prohibited from making any
repairs), test-and-repair (inspectors/mechanics are allowed to make
repairs), or hybrid (using both types of facilities).\4 However,
EPA's data, collected before November 1992, indicated that
test-and-repair networks were less effective\5 in controlling
emissions than test-only networks. Consequently, EPA's rule provided
that the number of credits assigned to test-and-repair networks would
be decreased by 50 percent, while test-only networks would receive
full credit. Some states and other interested parties questioned the
adequacy of EPA's supporting data for this 50-percent discount\6 and
maintained that it amounted, in practice, to an inflexible
requirement for using test-only networks. In light of the concerns
raised by the 50-percent discount, you asked us to provide you with
(1) the results of any audits, surveys, or studies performed since
November 1992 that have a bearing on this discount and (2) the status
of EPA's efforts to provide states with more flexibility in designing
I&M programs.
--------------------
\1 Mobile sources include motor vehicles, trucks, buses, boats and
planes, farm and lawn equipment, and other off-road sources.
Stationary sources include steel mills, utilities, refineries,
chemical plants, textile and furniture manufacturers, pulp and paper
mills, dry cleaners, service stations, and a host of other industrial
and commercial facilities.
\2 Inspection/Maintenance Program Requirements; Final Rule, 57 Fed.
Reg. 52950 (Nov. 5, 1992)(codified at 40 C.F.R. sec. 51). Under
this rule, about 85 million of the approximately 200 million vehicles
currently in use in the United States are subject to enhanced testing
programs.
\3 At the same time, EPA's rule required less polluted but
nonattaining areas to implement less stringent, or basic, testing
programs.
\4 According to EPA, hybrid programs usually allow newer vehicles to
be inspected--at the owner's option--at either type of facility,
while older vehicles must be tested at test-only facilities because
such vehicles often require greater maintenance.
\5 According to EPA, test-and-repair programs have an inherent
conflict of interest because a test-and-repair facility's inspector
may pass a noncomplying vehicle if the motorist is a regular customer
or if the vehicle's emission control system was previously repaired
at the facility.
\6 The term "50-percent discount" is used to show that
test-and-repair networks receive only half as many emission reduction
credits as test-only networks, which receive full credit. The U.S.
Court of Appeals for the District of Columbia Circuit, which upheld
this differential, described the applicable provision of EPA's 1992
rule as a "50-percent penalty" in 1994. However, a November 1995
statute refers to the same provision as a 50-percent discount. We
therefore use the statute's terminology hereafter in this report.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Since EPA issued its rule on the inspection and maintenance program's
requirements in November 1992, it has not conducted any audits or
surveys and has only partially funded one ongoing study that has a
bearing on the 50-percent discount. According to EPA officials, the
agency did not need to collect additional data because it had
adequately supported the discount provision in 1992 and a court had
upheld the provision in 1994. Of the 23 states required to implement
enhanced inspection and maintenance programs, only 2 (California and
Georgia) have developed data relevant to the 50-percent discount
since November 1992. Although we identified eight studies performed
by other interested and affected parties since 1992, only three
directly compare types of inspection and maintenance programs and the
other five provide only an indication of the various networks'
effectiveness. No clear consensus on the relative effectiveness of
test-and-repair and test-only programs emerged from these studies.
EPA has taken several actions to provide states with more flexibility
in designing and implementing enhanced inspection and maintenance
programs that will meet their individual needs. For example, in
February 1995 the agency established credits for (1) various types of
hybrid networks; (2) requirements that repairs be performed by
trained, certified mechanics; and (3) less costly testing systems.
As a result, more test-and-repair facilities can participate in
enhanced testing programs, and states can more readily accumulate the
credits they need to meet their air quality standards. In addition,
in September 1995 EPA revised its rule to allow states to meet a new,
less stringent performance standard as long as the states can still
meet their overall targets for reducing emissions. Although this
change gave more states the flexibility to offset the 50-percent
discount for test-and-repair networks with additional reductions in
emissions from stationary sources, it did not modify the 50-percent
discount for test-and-repair networks. In response to the concerns
of some states and other interested parties, the Congress enacted
legislation\7 in November 1995 eliminating any automatic discounts
based on the type of testing network and giving states 18 months to
collect new data demonstrating the effectiveness of their inspection
and maintenance programs, including their testing networks. On
December 12, 1995, EPA issued guidance to its regions suggesting
innovative program features that states may use to improve the
effectiveness of their test-and-repair programs. As of December
1995, officials from seven states told us they would likely collect
new data now, and several others said they were considering this
option. Appendix I summarizes the states' data collection activities
since November 1992 and recent plans. Appendix II summarizes the
results of other studies performed since 1992 that are relevant to
the 50-percent discount.
--------------------
\7 The National Highway System Designation Act of 1995 (P.L. 104-59,
sec. 348, Nov. 28, 1995).
BACKGROUND
------------------------------------------------------------ Letter :2
According to EPA, motor vehicles produce much of the pollution that
forms ozone (nitrogen oxides and hydrocarbons), and they are likewise
a major source of carbon monoxide in urban areas.\8 About 30 percent
of the nitrogen oxides, about 50 percent of the hydrocarbons, and
about 90 percent of the carbon monoxide emitted annually in major
urban areas come from motor vehicles, according to EPA's estimates.
Although EPA points out that today's new cars are up to 90 percent
cleaner than their 1970 counterparts, the number of vehicle-miles
traveled has more than doubled since 1970 and is still increasing,
effectively offsetting much of the gain from cleaner vehicles. In
addition, EPA and others have found that malfunctioning and poorly
maintained vehicles produce excess emissions. According to EPA, such
vehicles can emit from 2 to 17 times as much pollution as they were
designed to emit. To control emissions from mobile sources, the
Congress amended the Clean Air Act in 1990 to require states, as part
of their strategy for reaching attainment, to implement enhanced I&M
programs in areas classified as serious or worse ozone nonattainment
areas\9 and in certain areas with carbon monoxide problems.
To implement the act, EPA promulgated an enhanced I&M rule on
November 5, 1992, which specified a performance standard, or minimum
emission reduction requirement, for pollutants in each area required
to implement an enhanced I&M program. EPA's November 1992 rule also
established a model program whose use, EPA believes, will enable
states to meet the performance standards for areas under their
jurisdiction. The model program assumes that states will implement
test-only programs and that they will require annual emission testing
for all 1968 and newer vehicles and more extensive testing for 1986
and newer vehicles using high-tech, computer-controlled emission
analyzers, combined with other tests of vehicles' emission control
systems. Use of the model program, according to EPA, would reduce
hydrocarbons by 31.9 percent, carbon monoxide by 35.4 percent, and
nitrogen oxides by 13.4 percent by 2000. The actual performance
standard for each area varies on the basis of local factors, such as
the age of the local vehicle fleet, the relative proportions of
light-duty trucks and passenger vehicles, and the average speed and
trip length for vehicles in the area.
EPA's 1992 rule allows a state to vary the model program's design
elements as long as the state's I&M program reduces vehicles'
emissions by as much or more than is needed to meet the minimum
performance standard for carbon monoxide, hydrocarbons, and nitrogen
oxides. Besides the type of testing network, which is one of the key
variables that EPA considers in assessing an I&M program's
effectiveness, a state may vary other design elements, including the
frequency of inspections, types of automobiles (by model and year) to
be inspected, types and weights of light-duty trucks to be inspected,
type of testing equipment, number and types of vehicle emission
control systems to be inspected, stringency of the tailpipe test,
number and percent of vehicles that may receive a waiver,
availability of multiple waivers, amounts that owners must spend
toward repairing their vehicle's emission control system before a
waiver may be granted,\10 and other factors. Some factors that
states do not choose also affect an I&M program's effectiveness in
reducing emissions, such as the composition and age of the area's
vehicles, miles traveled, speeds traveled, lengths of the trips
taken, types of fuels used, climate, and temperature. Thus, the type
of testing network is only one of many variables that can influence
an I&M program's effectiveness.
To establish emission reduction credits for the type of testing
network (test-only, test-and-repair, or hybrid) used in an enhanced
I&M program, EPA obtained supporting data from three primary sources:
audits,\11 tampering surveys,\12
and special studies. These data, combined with more than 15 years'
experience with I&M programs, led EPA, in its November 1992 rule, to
require a 50-percent reduction in the number of emission credits
assigned to tailpipe and selected other tests performed under
test-and-repair programs.\13
This 50-percent discount applied by default if a state did not have
operating data from its existing test-and-repair program showing that
its program had achieved a higher rate of effectiveness. EPA
officials pointed out that although the number of credits for a
test-and-repair network is discounted by 50 percent, the number of
credits for an entire program is generally discounted by only 35 to
45 percent, depending upon the program's other design elements and
the local area's parameters.
--------------------
\8 Tropospheric, or ground-level, ozone and carbon monoxide have been
linked to a variety of health problems, ranging from eye, nose, and
throat irritation to bronchitis, emphysema, and other serious lung
diseases.
\9 EPA classifies nonattainment areas in categories ranging from
marginal through extreme.
\10 The act requires that vehicle owners spend at least $450 towards
emission-related repairs before a waiver may be granted; however,
under EPA's rule, states may increase this amount to obtain extra
credits or use vehicle scrappage programs to lower the minimum
required expenditures.
\11 Generally, two types of audits are used to evaluate an I&M
program's effectiveness, and both may be conducted by either EPA or a
state. In an overt audit, an inspector may observe vehicles being
tested, review a facility's records, check equipment calibrations, or
other such activities. In a covert audit, undercover vehicles are
purposely set to fail either tailpipe emission tests or tampering
checks.
\12 Tampering surveys involve pulling motorists over to the roadside
at random to determine whether their vehicle's emission control
system has been altered or removed.
\13 For vehicles tested under test-and-repair programs, EPA's 1992
rule also reduces by 75 percent the number of credits for the
evaporative canister used to collect fuel that evaporates, the
pollution control valve, and the air system.
EPA HAS FEW NEW DATA ADDRESSING
THE 50-PERCENT DISCOUNT
------------------------------------------------------------ Letter :3
Since 1992, EPA has not conducted any audits or tampering surveys to
obtain new data supporting its position on the 50-percent discount.
However, EPA is participating with academia, industry, and the state
of Georgia in an ongoing study that addresses the discount. This
study, which is supported by a 5-year, $5 million research grant to
the Georgia Institute of Technology, calls for, among other things,
evaluating the effectiveness of Atlanta's I&M program.\14
According to EPA officials, additional data were not required because
the agency adequately supported its 1992 decision and a May 1994
court ruling\15 upheld this decision. The court's opinion noted that
"ample evidence in the record supports the EPA's imposition of the 50
percent penalty." Nevertheless, EPA officials told us that they plan
to do more audits and tampering surveys in the future, once states
have more experience with operating enhanced I&M programs. They also
pointed out that, beginning 2 years after implementing an enhanced
I&M program, a state must conduct an ongoing evaluation of at least
one-tenth of 1 percent of the vehicles subject to annual inspection
in order to quantify the program's emission reduction benefits.
--------------------
\14 This study is discussed under states' data collection efforts
below.
\15 Natural Resources Defense Council, Inc. v. EPA, 22 F.3d 1125
(D.C. Cir. 1994).
STATES AND OTHERS HAVE FEW NEW
DATA ADDRESSING THE 50-PERCENT
DISCOUNT
------------------------------------------------------------ Letter :4
Officials from 14 of the 23 states required to implement enhanced I&M
programs told us that their states have not conducted audits or
tampering surveys to address the 50-percent discount, primarily
because their states either already have implemented, or at one point
had planned to implement, a test-only I&M program. Therefore, the
states believed that data from audits or tampering surveys were not
needed or were not a high priority in relation to their I&M program's
other needs.
Officials from the other nine states required to implement enhanced
I&M programs told us that while their states have conducted some
audits and/or tampering surveys since 1992, these efforts were not
designed to assess the relative effectiveness of different types of
I&M networks and therefore could not be used, according to the
officials, to compare test-only to test-and-repair programs. For
example, New Jersey, which has both test-only and test-and-repair
facilities, audits each of the 35 test-only stations twice each year
but uses a different approach to target test-and-repair stations for
audits. Given a far larger number of test-and-repair stations and
limited resources, New Jersey generally targets these stations for
audits on the basis of customers' complaints, low failure rates, or
other signs of problems. The state's goal when doing these audits is
to improve compliance by targeting the worst-offending stations--not
to assess the relative effectiveness of different network types.
Officials from the other eight states also indicated that their audit
data cannot be used to empirically assess the effectiveness of the
different network types.
State officials said that there were several reasons why their states
had not developed data since 1992 to address the 50-percent discount.
They cited the 1994 court case, EPA's 1995 commitment to provide
states with greater flexibility in designing I&M programs, and
uncertainty about how to demonstrate the effectiveness of different
I&M network types while making major changes in their programs.
EPA officials also said that there were several reasons why states
had not developed data to address the 50-percent discount. They said
some states have intended to use test-only facilities all along and
therefore did not have a reason to develop information on alternative
networks. Other states, according to EPA, did not believe that their
I&M programs were more than 50 percent as effective in reducing
emissions as test-only programs; therefore, they did not see the need
to collect data to justify higher credits. Appendix II summarizes
the states' audits, tampering surveys, and other data collection
activities since November 1992.
STATES' SPECIAL STUDIES
---------------------------------------------------------- Letter :4.1
Although none of the 23 states have developed audit or tampering data
to address the 50-percent discount, 2 states (California and Georgia)
have conducted special studies since the November 1992 rule was
issued. The California Senate Transportation Committee commissioned
a study by the RAND Corporation, which, in October 1994, found no
empirical evidence requiring the separation of the test and repair
functions. In February 1995, another California study, performed for
the California I/M Review Committee, found little difference in the
effectiveness of a test-only program and a test-and-repair program in
reducing emissions. EPA has taken issue with these findings and
stated in March 1995 that it does not consider the studies cited in
support of such conclusions to be based on sound methodology. These
California studies are discussed in appendix II.
Georgia is also conducting a special study to address the 50-percent
discount as part of an overall assessment of the Atlanta I&M
program's effectiveness. As of December 1995, Georgia Tech had
completed a 2-year assessment of the Atlanta hybrid network's
effectiveness and was incorporating peer review comments into the
final paper. On the basis of the data collected thus far, the
principal researcher believes that the Atlanta program should receive
only a 35- to 45- percent discount--not a 50-percent discount. EPA
officials said that they have some concerns about the study's use of
remote sensing devices\16 to demonstrate the program's effectiveness
in reducing emissions. EPA said it will work with Georgia Tech to
ensure that the data are suitable for making such determinations.\17
The study is expected to be issued early in 1996, according to the
principal researcher. This study is also discussed in appendix II.
--------------------
\16 Remote sensing devices use an infrared beam to assess vehicles'
exhaust emissions in actual traffic conditions on public roads.
According to EPA officials, assessing an I&M program's effectiveness
in reducing emissions by using remote sensing devices is difficult
because these devices measure exhaust concentrations at only one
instant in time when the vehicle's operating conditions are unknown,
measure only carbon monoxide and hydrocarbons, and have not yet
reliably measured nitrogen oxides. In contrast, EPA's computerized
testing equipment measures all three pollutants over time--while the
vehicle is accelerating and decelerating and under various other
simulated driving conditions.
\17 EPA officials also noted that the agency recently assisted two
states (Virginia and Utah) in analyzing previously collected data
from their respective test-and-repair programs. These analyses
compared the effectiveness of each state's network to that of another
state's (Minnesota's) test-only network to determine how much credit
each state's program should receive during the 18-month period
allotted for collecting new data under the new statute. According to
EPA, the analyses indicate that each state's program is effective
enough to receive full credit during the 18-month period. Meanwhile,
both states plan to work with EPA to develop a new methodology to
evaluate the effectiveness of their demonstration I&M programs.
OTHERS' EFFORTS
---------------------------------------------------------- Letter :4.2
In addition to contacting EPA and state officials, we contacted the
principal investigators for other interested and affected parties
identified to us as having started or completed work since 1992 that
might have a bearing on the 50-percent discount. Our discussions
with these investigators revealed that, of the eight studies
identified, five provided some indication of the overall
effectiveness of one or more I&M programs but did not directly assess
the effectiveness of the I&M programs' testing networks. The other
three studies, according to their principal investigators, not only
provided an indication of an I&M program's effectiveness but also
directly assessed the I&M network's effectiveness in reducing
emissions. However, no clear consensus on the relative effectiveness
of test-and-repair and test-only programs emerged from these studies.
For example, in contrast to the Georgia study discussed earlier,
which indicated that Atlanta's I&M hybrid program was more effective
in reducing emissions than EPA's 50-percent discount would indicate,
a California study found little difference in the effectiveness of a
test-only program and a test-and-repair program and observed that
both were less effective than EPA's model program. These studies'
findings are summarized in appendix II.
EPA HAS PROVIDED MORE
FLEXIBILITY TO STATES
IMPLEMENTING ENHANCED I&M
PROGRAMS
------------------------------------------------------------ Letter :5
EPA has recognized that uncertainty about the effectiveness of
different types of I&M testing networks has delayed the
implementation of enhanced I&M programs in some states. Accordingly,
the agency has taken several actions to give states more flexibility
in designing and implementing enhanced I&M programs that the states
believe will meet their individual needs. For example, in February
1995 EPA established emission reduction credits for different types
of hybrid I&M networks. In essence, EPA provided states with
examples of approvable I&M programs by establishing alternative I&M
network designs that, if properly implemented, would be as effective
in reducing emissions as EPA's test-only model program and would
enable states to meet their performance standards. These alternative
I&M networks included (1) an age-based hybrid, in which older
vehicles are sent to test-only facilities, while newer vehicles may
go to test-and-repair facilities; (2) a retest hybrid, in which all
vehicles are initially tested at test-only facilities and vehicles
that require retesting are sent, after being repaired, to
test-and-repair facilities if they have failed only once and to
test-only facilities if they have failed more than once (repair
verification); and (3) a targeted hybrid, in which information on the
emission performance of vehicles (by make, model, and engine type) is
used to target poorly performing types of vehicles for test-only
inspections while other types of vehicles are sent to test-and-repair
facilities.
Also in February 1995, EPA established credits for the states that
require repairs to be performed by trained, certified mechanics, and
for less costly testing systems. States can earn extra credits if
repairs are performed by trained, certified mechanics because such
repairs are generally more effective and longer lasting.
Furthermore, now that EPA provides credits for less costly and less
complex testing equipment,\18 more test-and-repair facilities can
participate in enhanced testing programs. Additionally, EPA has been
working with states and other stakeholders to establish emission
reduction credits for the use of remote sensing devices to measure
vehicles' emissions in actual traffic conditions. Once identified,
poorly performing vehicles can be called in for repairs before they
are due to be reinspected. By giving credits for using remote
sensing devices to identify vehicles needing out-of-cycle repairs,
EPA will be able to help the states with alternative networks meet
their performance standards. EPA officials believed that such
credits would be finalized by the spring of 1996.
Additionally, in September 1995 EPA revised its 1992 rule to allow
states to meet a new, less stringent performance standard as long as
the states could still meet their overall targets for reducing
emissions. This change gave more states the flexibility to offset
the 50-percent discount for test-and-repair networks with additional
reductions in emissions from stationary sources. According to EPA,
in making such a decision, a state must consider the impact that the
decision could have on stationary sources. For example, stationary
sources may have to replace or add more pollution control equipment,
reconfigure their manufacturing processes, or change the raw
materials they use--actions that can be more expensive than obtaining
equivalent reductions from mobile sources. In October 1995, EPA also
proposed greater flexibility for certain areas within a 13-state
region of the northeastern United States where the movement of ozone
pollution is a problem. This proposal, if approved, would allow
qualified areas to meet an even lower performance standard, thereby
helping these areas meet the commitments in their state's plan while
choosing to implement test-and-repair I&M networks.
EPA's actions, when taken together, provided states with
significantly more flexibility than was previously available.
However, the agency continued to discount the number of credits for
test-and-repair programs by 50 percent, and many expressed concern
that states did not have sufficient flexibility to design I&M
programs that best suited their needs. The Congress responded to
these concerns in late November 1995 by passing a law that eliminated
EPA's automatic 50-percent discount and gave states 18 months to
collect new data supporting their particular I&M program's
effectiveness in reducing vehicles' emissions. On December 12, 1995,
EPA issued guidance to its regions suggesting innovative program
features that states may use to improve the effectiveness of their
test-and-repair programs. Subsequently, officials from seven states
told us they would likely collect new data supporting the
effectiveness of their test-and-repair programs, and officials from
several other states were considering this new option. The current
I&M plans for each state appear in appendix I.
EPA officials told us they will work with these states to ensure that
adequate test data are collected during this 18-month evaluation
period. They pointed out that the agency plans to meet with all
affected states in March 1996 to help these states develop
appropriate methodologies for assessing the effectiveness of their
interim I&M programs in reducing emissions. They said that these
states' enhanced I&M programs will be assessed using criteria similar
to those specified in the evaluation component of the 1992 enhanced
I&M rule. According to EPA, this approach should provide consistent,
reliable data for use in quantifying each state's emission reduction
benefits.
--------------------
\18 EPA's model program calls for the use of IM-240 testing
equipment--a high-tech, computer-controlled emission analyzer that
measures tailpipe emissions under a 240-second simulated driving
cycle while the vehicle is driven on a treadmill-like device, called
a dynamometer, that simulates vehicle load, or engine stress, during
such events as acceleration and deceleration. IM-240 systems cost
over $140,000 per lane.
AGENCY COMMENTS
------------------------------------------------------------ Letter :6
We provided copies of a draft of this report to EPA for its review
and comment and obtained comments from officials in the Office of
Mobile Sources, including the Director of that office. These
officials said that, overall, the report is accurate and fair in its
presentation. They also suggested clarifying changes, which we
incorporated into the report. For example, they suggested that we
refer to the reduction in emission credits for test-and-repair
networks as the 50-percent discount, a term used in a 1995 statute,
rather than as the 50-percent penalty, a term used earlier by a
federal court. We made this change throughout the report. They
further suggested that we point out early in the report that recent
legislation has eliminated any automatic discounts of test-and-repair
networks. This information already appeared near the beginning of
our report; however, we added a citation identifying the relevant
legislation and noted that EPA had provided guidance to its regions.
Finally, the officials suggested that we include an I&M contractor's
observation supporting the effectiveness of the test-only sites in a
state that is not required to implement an enhanced I&M program.
Although we included this observation in appendix I, we did not
incorporate it into the body of the report because it does not fall
within the scope of our review.
---------------------------------------------------------- Letter :6.1
We conducted our review from July 1995 through February 1996 in
accordance with generally accepted government auditing standards. A
detailed discussion of our scope and methodology appears in appendix
III.
As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 15 days after the date of this letter. At that time, we will
send copies to the Administrator of EPA and other interested parties.
We will also make copies available to others upon request.
Please call me at (202) 512-6111 if you or your staff have any
questions. Major contributors to this report are listed in appendix
IV.
Sincerely yours,
Peter F. Guerrero
Director, Environmental
Protection Issues
STATES' AUDITS, TAMPERING SURVEYS,
AND STUDIES ADDRESSING THE
50-PERCENT DISCOUNT SINCE NOVEMBER
1992
=========================================================== Appendix I
The number of credits that EPA assigns for the design elements in a
state's inspection and maintenance program is pivotal to EPA's
approval of the state's implementation plan. Additionally, EPA may
withhold highway funds and impose other sanctions against a state
that fails to develop an adequate plan by the prescribed deadline.
Thus, a state seeks to obtain as many credits as possible from each
of the design elements in its inspection program, including the type
of testing network.
States may use three primary sources of data--audits, tampering
surveys, and special studies--to establish the relative effectiveness
of different types of enhanced inspection and maintenance (I&M)
networks, according to EPA. We found that only 2 (California and
Georgia) of the 23 states\1 that are required to implement an
enhanced I&M program have developed data since November 1992, when
EPA issued its enhanced I&M rule decreasing the number of credits
assigned to test-and-repair networks by 50 percent.\2 According to
state air program officials, this 50-percent discount has not been
more widely addressed for several reasons, which are discussed in
this appendix. In addition, the appendix provides further details on
the states' audits, tampering surveys, and studies conducted since
November 1992, as well as on the type of I&M network planned for each
state as of December 1995.
--------------------
\1 New York and Virginia were working with EPA to develop a data
collection protocol in order to study the issue.
\2 EPA officials pointed out that in Florida, a state that is not
required to implement an enhanced I&M program, vehicle owners have
the option of going to test-only or test-and-repair sites. These
officials cited a contractor's observation that a greater percentage
of the vehicles inspected at test-only sites pass their initial
inspection the following year.
AUDITS
--------------------------------------------------------- Appendix I:1
According to EPA, states generally use two types of audits (overt and
covert) to evaluate their I&M program's effectiveness. In an overt
audit, a state inspector may observe vehicles being tested, review a
facility's files and records of past tests, analyze data, check
equipment calibrations, or perform other such activities. In a
covert audit, undercover vehicles are purposely set to fail either
tailpipe emission tests or tampering checks. Officials from most of
the states required to have an enhanced I&M program said that while
they have done overt and/or covert audits, these efforts were not
designed to evaluate the appropriateness of EPA's 50-percent
discount. In some instances, state officials told us that they
generally targeted problem stations, often on the basis of consumers'
complaints, for overt and covert audits in order to minimize the
number of improper inspections. For example, New Jersey, which has
both test-only and test-and-repair facilities, audits each of the 35
test-only stations twice each year while using a different approach
to monitor test-and-repair stations. Because there are many more
test-and-repair stations in New Jersey and resources are limited, the
state generally targets test-and-repair stations for a covert audit
on the basis of customers' complaints, low failure rates, and other
indicators of poor performance or noncompliance. The state's goal
when auditing these stations is to improve compliance by targeting
the worst offenders--not to assess the relative effectiveness of
different network types.
TAMPERING SURVEYS
--------------------------------------------------------- Appendix I:2
Tampering surveys involve pulling motorists over to the roadside to
inspect their vehicle's emission control system to see if this system
has been altered or removed. If properly implemented, tampering
surveys can serve as a basis for comparing tampering rates among
different I&M programs. However, such surveys are costly and
generally require the aid of local or state police. Although EPA
conducted such surveys on over 62,000 vehicles in 40 states from 1978
to 1990, since November 1992 most states, according to EPA, have not
independently conducted roadside tampering surveys to compare the
relative effectiveness of test-and-repair and test-only networks;
none of the 23 states required to implement enhanced I&M programs
have conducted such surveys since November 1992. Although the motor
vehicle departments in some states, such as New Jersey, have
conducted thousands of roadside pullovers to check for safety
problems and, in some cases, evidence of tampering, air quality
officials in these states told us these data have not been used to
assess the effectiveness of different network types. Some pointed
out that, in the past, they generally had not seen the need for
roadside tampering surveys because vehicles were checked for
tampering during their inspection at a testing facility.
Additionally, EPA and others have pointed out that tampering is less
of a concern with newer-technology vehicles, and many see remote
sensing as a less expensive way to identify problem vehicles in
actual driving conditions.
SPECIAL STUDIES
--------------------------------------------------------- Appendix I:3
Of the 23 states required to implement enhanced I&M programs, only
California and Georgia have conducted special studies to address the
50-percent discount. Both of these studies are discussed in appendix
II. EPA officials also pointed out that the agency recently assisted
Virginia in analyzing previously collected data from its
test-and-repair program. While not a special study of the 50-percent
discount, this analysis compared the effectiveness of Virginia's
test-and-repair network to that of Minnesota's test-only network to
determine how much credit Virginia's program should receive during
the 18-month period allotted for collecting new data under the new
statute. According to EPA, the analysis indicated that Virginia's
program is effective enough to receive full credit during the
18-month interim period. EPA pointed out that the agency plans to
meet with Virginia and other affected states in March 1996 to help
these states develop appropriate methodologies for assessing the
effectiveness of their interim I&M programs in reducing emissions.
We did not identify any other studies to collect quantitative data on
the 50-percent discount that had been completed since November 1992
by the 23 states required to implement enhanced I&M programs.\3
--------------------
\3 However, Utah, a state that is not required to implement an
enhanced I&M program, recently received assistance from EPA similar
to that provided to Virginia. Utah can use the extra credits from
the state's mobile sources to offset the need for more stringent
controls on the state's stationary sources.
STATES' CHANGING NEEDS FOR DATA
--------------------------------------------------------- Appendix I:4
As states have changed the plans for their I&M programs, their needs
for data have also changed. For example, as table I.1 shows, in
August 1994, 19 of the 23 states were planning to implement test-only
I&M networks, which would have received full credit when EPA reviewed
the states' implementation plans. Thus, these states did not see the
need to collect data to address the 50-percent discount. Most of the
officials from these 19 states indicated that their plan to employ a
test-only network was a primary reason they had not collected data to
address the 50-percent discount. However, as time passed and EPA
provided states with more flexibility in designing programs that they
believed would best suit their needs, more and more states moved away
from test-only networks. As of December 1995--just weeks after the
Congress enacted legislation eliminating EPA's 50-percent
discount--only nine states were planning to implement test-only
programs. Air quality officials from seven states said they were now
planning to collect data on their I&M network's effectiveness, and
officials from several other states were considering this option.
Table I.1
Enhanced I&M Networks Planned for Each
State as of August 1994 and December
1995
Type of I&M Type of I&M
network network
planned as of planned as of
State August 1994 December 1995
------------------------------ ------------------ ------------------
California Hybrid Hybrid
Colorado Test-only Test-only
Connecticut Test-only Test-only
Delaware Test-only Test-only
District of Columbia Test-only Test-only
Georgia Hybrid Hybrid
Illinois Test-only Test-only
Indiana Test-only Test-only
Louisiana Test-only Test-and-repair
Maine Test-only Uncertain
Maryland Test-only Test-only
Massachusetts Test-only Hybrid
Nevada Test-only Test-and-repair
New Hampshire Test-only Uncertain\a
New Jersey Hybrid Hybrid
New York Test-only Hybrid
Pennsylvania Test-only Test-and-repair
Rhode Island Test-only Uncertain
Texas Test-only Hybrid
Vermont Test-only Test-and-repair
Virginia Uncertain Test-and-repair
Washington Test-only Test-only
Wisconsin Test-only Test-only
----------------------------------------------------------------------
Note: We obtained information on the states' I&M plans through phone
discussions with state air quality officials in December 1995.
\a As of December 14, 1995, EPA was reviewing New Hampshire's request
for redesignation as an attainment area, and air quality officials
said they were uncertain whether an enhanced I&M program would still
be required for the state. If such a program is required, New
Hampshire will implement a test-and-repair or a hybrid network.
However, data relevant to the 50-percent discount have not been
developed for other reasons. For example, some state officials told
us they did not oppose EPA's 50-percent discount of test-and-repair
programs because, in their opinion, it was appropriate. Elsewhere,
however, the reasons this provision has not been more widely
addressed since 1992 vary by state and by time period. For example,
in October 1993 some states indicated that they had neither the time
nor the resources to develop the data to meet EPA's demonstration
requirements for a test-and-repair I&M program. EPA officials also
noted that prior to May 1994, some states were awaiting the outcome
of the court case challenging the 50-percent discount, and some
wanted to see the outcome of EPA's initiatives for giving greater
flexibility to states before moving forward with an enhanced I&M
program. Also, officials from several states pointed to uncertainty
about how to demonstrate the effectiveness of different I&M network
types while making major changes in their programs.
SYNOPSIS OF STUDIES HAVING A
BEARING ON THE 50-PERCENT DISCOUNT
SINCE NOVEMBER 1992
========================================================== Appendix II
We identified seven completed studies and one ongoing study that the
principal investigators believe have a bearing on the 50-percent
discount. Three of the studies address the discount and the other
five, while not directly addressing it, provide an indication of an
I&M program's effectiveness. We reviewed each study's methodology
and results and discussed them with the principal researchers, who
said that their studies' methodologies did not isolate their findings
to the relative effectiveness of different I&M network types and thus
were of limited usefulness in quantitatively addressing the
50-percent discount. A synopsis of each study, listed
chronologically, is presented below.
at virtually the same rate for the first 2 years after the I&M
program began as they had for the 5 prior years. According to the
study, ambient carbon monoxide levels had declined steadily by 6
percent per year since 1987, and no measurable change occurred in
that pattern after annual vehicle inspections began in July 1991.
Thus, the monitoring data failed to demonstrate a systematic
reduction in ambient carbon monoxide levels following the I&M
program's implementation. The study credited most of the reduction
in emissions to improvements in tailpipe emission standards and new
car technology. Researchers concluded from direct measurement that
only 1.3 percent of the improvement in air quality could be credited
to the vehicle inspection system, with a margin for error of plus or
minus 1.4 percent. The principal researcher said this study was not
designed to evaluate the relative effectiveness of test-and-repair
and test-only I&M networks and therefore did not directly address the
50-percent discount. However, the study did question whether this
test-only I&M program had achieved statistically significant
reductions.
RESTRUCTURING SMOG CHECK: A
POLICY SYNTHESIS
-------------------------------------------------------- Appendix II:1
The RAND Corporation prepared this October 1994 study for the
California Senate Transportation Committee. The study had multiple
objectives, including critically evaluating the analytic, scientific,
and empirical bases for EPA's 1992 enhanced I&M rule. The study
concluded that official evaluations of the I&M program are too
unreliable and uncertain for use in policy-making, but other more
reliable data originally gathered for other purposes imply that key
aspects of the program are approaching failure. RAND's investigation
and synthesis provided the researchers with little confidence in the
ability of their regulatory agency's existing methodologies to
realistically and reliably assess and forecast performance, compare
alternatives, and provide a rational guide to policy. Accordingly,
RAND suggested that an independent comprehensive inquiry into the
state of emission and evaluation protocols is urgently needed.
Furthermore, the study concluded that existing national data, limited
as they are, suggest little difference in the measures of
effectiveness between centralized (test-only) and decentralized
(test-and-repair) I&M programs. Thus, they concluded there was no
empirical basis for requiring that the test and repair functions be
separated.
AUDIT RESULTS: AIRCARE I/M
PROGRAM
-------------------------------------------------------- Appendix II:2
This December 1994 study was prepared by the Radian Corporation and
de la Torre Klausmeier Consulting, Incorporated, for the British
Columbia Ministry of Environment, Lands and Parks, and the British
Columbia Ministry of Transportation and Highways. The purpose of
this study was to (1) estimate the reductions in emissions that are
occurring as a result of the program, (2) determine the effectiveness
of the current emission testing procedures in identifying and
ensuring the repair of high-emitting vehicles, (3) generate
statistics from the program to determine whether it is meeting its
design specifications, and (4) identify needed program enhancements.
The principal researcher said that the study was not designed to
evaluate the 50-percent discount provision; however, the study
indicated that the Vancouver, British Columbia, test-only network,
which was implemented in September 1992, is superior to a
test-and-repair I&M program. The study found that the failure rate
for vehicles in British Columbia dropped from 14 percent to 11
percent from 1993 to 1994 and concluded that the program had a
lasting impact on reducing emissions in the province. A majority of
the vehicles that failed in the first year passed in the second year,
indicating that repairs generally were not just temporary
adjustments. Ninety-nine percent of the vehicles were tested
correctly, although in about 1 percent of the inspections, the
contractor used a less stringent standard for nitrogen oxide,
resulting in a few vehicles (less than 1 percent) being improperly
passed.
AN ANALYSIS OF EPA'S 50-PERCENT
DISCOUNT FOR DECENTRALIZED I/M
PROGRAMS
-------------------------------------------------------- Appendix II:3
This February 1995 study was prepared by the California Inspection
and Maintenance Review Committee. Its purpose was to evaluate the
scientific basis for EPA's 50-percent discount by evaluating EPA's
audits and tampering surveys of I&M programs, as well as other
researchers' studies of on-the-road vehicle emissions. The study
challenges the relevance of EPA's 50-percent discount for
test-and-repair networks as compared with test-only networks.
The study concluded that direct measurements of the variables that
I&M is supposed to reduce--emission system tampering and tailpipe
emission levels--show little difference between centralized
(test-only) and decentralized (test-and-repair) I&M programs. The
study concluded that whether an I&M program is centralized or
decentralized has not been an important factor in determining the
program's effectiveness. Among other things, the study also
concluded that (1) on-the-road and ambient measurements of vehicles'
emissions indicate that both centralized and decentralized programs
have performed poorly, (2) EPA's tampering surveys show little
difference in tampering rates between centralized and decentralized
programs, (3) data collected and analyzed by EPA included errors in
favor of centralized programs, (4) EPA's audits included structural
biases against decentralized programs, (5) EPA did not collect audit
data that could be used to assess reductions in emissions, and (6)
EPA did not present a methodology for converting the audit data into
a quantifiable discount.
EMISSION REDUCTION BENEFITS
ATTRIBUTABLE TO THE MINNESOTA
VEHICLE INSPECTION PROGRAM
-------------------------------------------------------- Appendix II:4
This March 1995 study was conducted for the American Lung Association
of Minnesota by Sherman Engineering, Incorporated. The purpose of
the study was to document reductions in emissions achieved from the
Minnesota Vehicle Inspection Program. The principal researcher said
this study was not designed to evaluate the appropriateness of the
50-percent discount.
The study's findings are based upon an analysis of a set of
inspection data collected from July 1991 through June 1993. Tailpipe
test data were used, since they represented the only available set of
data that constituted a direct measure of the emission reduction
capabilities of the I&M program. The principal researcher said that
the results of the study may be used in weighing the environmental
impact of any action to reduce the number of vehicles to be tested in
Minnesota. The study concluded that tailpipe test data from the
Minnesota I&M program demonstrate that significant reductions in
mobile source emissions have been achieved and that these reductions
are comparable to and may exceed the benefits predicted by approved
federal modeling techniques.
EVALUATION OF THE CALIFORNIA
PILOT I&M PROGRAM
-------------------------------------------------------- Appendix II:5
This March 1995 study was prepared for the California Bureau of
Automotive Repair by the Radian Corporation. The objectives of the
study were to (1) determine the emission reduction effectiveness of
alternative loaded mode tests, such as the acceleration simulation
mode tests compared to the IM-240 test;\1 (2) demonstrate how well
high-emitting vehicles within a designated geographical area can be
identified using remote sensing equipment; and (3) demonstrate the
effectiveness of using a high-emitting vehicle profile (based on
factors such as the model year, engine family defect history,
tampering probability, number of times a vehicle was sold, and remote
sensing data) to identify vehicles with the highest probability of
failing an emission test.
This study was broken down into two major parts: the El Monte Pilot
and the Sacramento Pilot. Data to evaluate the repair effectiveness
of alternative loaded mode tests were generated in the El Monte
portion of the California Pilot program. The El Monte Pilot was
performed by the California Air Resources Board. It tested vehicles
using three different types of testing equipment. The Sacramento
Pilot was conducted to demonstrate the effectiveness of remote
sensing devices in identifying problem vehicles and also to evaluate
techniques for profiling vehicles' emissions. The study used the
1994 data obtained from the El Monte and Sacramento pilot studies to
conclude that the planned California hybrid program can be equivalent
to EPA's performance standard for vehicles' exhaust emissions if 18
percent of the vehicles targeted in enhanced I&M areas are sent to
test-only stations for annual emission testing. According to the
principal researcher, this study was not designed to address the
50-percent discount.
--------------------
\1 See footnote 18 in the letter of this report.
EMISSION TESTING POLICIES FOR
THE COMMONWEALTH OF
PENNSYLVANIA
-------------------------------------------------------- Appendix II:6
This June 1995 study was a project by 33 students from the Department
of Engineering and Public Policy and the Department of Social and
Decision Sciences at Carnegie Mellon University. The purpose of the
study was to evaluate the automotive testing policies of the
Commonwealth of Pennsylvania. The evaluation focused on automotive
emission inspection and maintenance technologies; emissions of carbon
monoxide, volatile organic compounds, and nitrogen oxides; and
concentrations of ozone resulting from automotive emission control
programs involving both (1) centralized emission inspection only and
(2) decentralized inspection and maintenance. An economic analysis
of these alternatives was also done. The study did not address the
50-percent discount.
The study used data from two other studies as well as ozone
concentrations measured in Allegheny County, Pennsylvania, as factors
in two computer models. One computation showed that ozone would be
reduced only by 1.7 percent if IM-240 testing were introduced. Thus,
the study concluded, among other things, that (1) IM-240 testing in
Pennsylvania would lead to negligible reductions in ozone emissions,
(2) centralized emission testing is significantly more costly than
decentralized testing, and (3) achieving emission reductions from
mobile sources appears to cost more than achieving similar reductions
from stationary sources.
MEASURING I/M PROGRAM
EFFECTIVENESS USING REMOTE
SENSING DATA
-------------------------------------------------------- Appendix II:7
According to the principal researcher, this ongoing study, subtitled
Results of the Continuous Atlanta Fleet Evaluation, is in final draft
form and should be completed early in 1996. The data are being
developed by the Georgia Institute of Technology in association with
11 other organizations, including the Georgia Department of Natural
Resources and EPA's Office of Research and Development. While the
study addresses the 50-percent discount, its primary purpose is to
evaluate the effectiveness of the Atlanta, Georgia, I&M program. The
study compares the results of remote sensing device measurements from
nine Georgia counties that do not have I&M requirements with the
results from four counties that do. It also compares the ratio of
the percentage reductions in hydrocarbons and carbon monoxide
actually achieved with the ratio of emission reductions postulated
from the EPA model for a program of the same type.
The study found that the four counties with an I&M program have lower
emission averages than the nine counties without an I&M program. It
concluded that the reasons for the higher levels of emissions in the
nine counties are (1) a higher proportion of trucks compared with the
other four counties and (2) the absence of an I&M testing program.
The principal researcher said their research provides evidence that,
as a whole, test-and-repair programs are probably less effective than
test-only programs. However, there is sufficient variability in both
network types to change the effectiveness of any particular program.
He estimated that test-only programs vary from 50 to 90 percent in
effectiveness (when compared with the EPA mobile model) and that
test-and-repair programs vary from 40 to 80 percent in effectiveness.
Thus, he believes that the results of the research are relevant to
the 50-percent discount because the results provide evidence that the
Georgia I&M program's effectiveness ranges from 55 to 65 percent.
OBJECTIVES, SCOPE, AND METHODOLOGY
========================================================= Appendix III
The Chairman, Subcommittee on Oversight and Investigations, House
Committee on Commerce, asked us to (1) provide the results of any
audits, surveys, or studies performed since EPA issued its November
1992 enhanced I&M rule that have a bearing on the rule's provision
decreasing the number of credits for test-and-repair programs by 50
percent as compared with test-only programs and (2) determine the
status of EPA's efforts to provide states with more flexibility in
designing I&M programs that best suit their needs.
To identify audits, tampering surveys, or studies that might have a
bearing on the 50-percent discount,\1 we reviewed five electronic
databases;\2 the rulemaking docket (Public Docket Number A-95-08) for
EPA's September 18, 1995, revision to the enhanced I&M rule; and the
hearing transcript for selected hearings on I&M issues. We also
attended two symposiums where I&M issues were discussed.
Additionally, we interviewed officials and obtained documents from
EPA's Office of Air and Radiation in Washington, D.C.; Office of
Mobile Sources in Ann Arbor, Michigan; and Office of Research and
Development in Research Triangle Park, North Carolina. We also
obtained information from knowledgeable air quality officials in the
23 states required to implement enhanced I&M programs under the 1990
act.
To ensure complete identification of the studies conducted by other
interested and affected parties since November 5, 1992, we also
interviewed people who had addressed the 50-percent discount in
documents they had sent for inclusion in EPA's docket, as well as
individuals identified to us by EPA or state officials; by
representatives of academia, industry, or environmental groups; or
through our own efforts discussed above. After developing a list of
potential studies, we obtained and reviewed the studies and discussed
their impact on the 50-percent discount with the authors or principal
investigators. Also, with the EPA and state officials identified
above, we discussed EPA's efforts to provide states with more
flexibility in designing I&M programs.
We conducted our review from July 1995 through February 1996 in
accordance with generally accepted government auditing standards.
--------------------
\1 See footnote 6 in the letter of this report.
\2 The electronic databases reviewed included "Enviroline," which
covers more than 5,000 international primary and secondary
environmental publications on all aspects of the environment;
"EiCompendex Plus," the electronic version of The Engineering Index,
which provides worldwide coverage of approximately 2,600 journals and
selected government reports and books on the environment and other
issues; "Pollution Abstracts," a leading resource for references to
environment-related literature on pollution, its sources, and its
control; "Energy Science and Technology," one of the world's largest
sources of literature references on energy and related topics,
including the environment, with coverage of journal articles, report
literature, conference papers, books, patents, dissertations, and
translations; and EPA's "Technology Transfer Network," a worldwide
network of electronic bulletin boards providing information and
technology exchange in areas pertaining to air pollution control,
with emphasis on EPA's "Mobile Sources Information" bulletin board,
which covers information pertaining to mobile source emissions,
regulations, test results, models, and guidance.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV
RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C.
Lawrence J. Dyckman, Associate Director
William F. McGee, Assistant Director
NORFOLK REGIONAL OFFICE
James R. Beusse, Evaluator-in-Charge
Philip L. Bartholomew, Staff Evaluator
Hamilton C. Greene, Jr., Staff Evaluator
DeAndrea M. Leach, Staff Evaluator
*** End of document. ***