2003 I/M Program Annual Report: Data Analysis
The collection of accurate data is essential to the management, evaluation, and enforcement of an I/M program. The State's high enhanced I/M program in NYMA has been collecting inspection and emissions test data on individual vehicles as well as quality control data related to emissions testing equipment since the onset of the program in January 1998. The UPSTATE I/M program is not computerized at this time.
A. Computerized Network for NYMA
A computerized network is utilized for transmitting the realtime field data from 4,059 decentralized test-and-repair inspection stations in the high enhanced I/M program in NYMA to both NYSDMV and the Data Manager's (TestCom, Inc.) computer servers. All data, transmitted via telephone lines as well as those collected offline, are downloaded from the Data Manager's servers and submitted to NYSDEC through a FTP server on a biweekly basis.
Regular data management meetings have been held every month with a full participation from NYSDMV, NYSDEC, and TestCom. During these meetings, network performance related issues are discussed. Various statistics were compiled by the Data Manager to measure and compare month by month NYMA network performance and efficiency. These statistics, provided by TestCom, are summarized in Table II.A.
This computerized network for the NYMA I/M program has been utilized as a means for communications between the Data Manager and the 4,059 inspection facilities. In addition, realtime inspection activities were also being monitored by NYSDMV (and the Data Manager) based on various enforcement criteria. More effective enforcement actions have resulted and are presented in the Quality Assurance Report and Quality Control Report sections.
B. Test Data Report
Overall statistics related to the registered vehicle fleet, by model year and by fuel type, from both NYMA and UPSTATE for year 2003 are provided in Appendix A.
As can be seen from Appendix A, 96% of the vehicles registered in NYMA and 92.38% of those in UPSTATE are gasoline powered. Diesel-fueled vehicles represent 2.04% of the NYMA fleet and 2.16% of the UPSTATE fleet. Note that the statistics for "other fuels" included very few vehicles operated with CNG, propane, hybrid, or flex fueled.
Summary statistics related to the enhanced I/M program in NYMA are provided in Tables II.B.1 and II.B.2. Detailed statistics based on emissions tested light-duty fleet, by vehicle model year and by vehicle type, are presented in Appendices B and C, with Appendix B being a summary of the exhaust emissions test results, and Appendix C a summary of anti-tampering check and gas cap test results. Note that emissions tested light-duty fleet included model years 1978 through 2002 vehicles only.
As can be seen, 87.60% of the emissions-tested light-duty fleet was transient tested (NYTEST) with 7.87% failure rate, 0.15% of the transient tested light duty fleet received waivers (with waiver rate of 1.92%), 0.06% failed the anti-tampering check, and 0.11% failed the gas cap test. Further, 12.40% of the emissions-tested light-duty fleet that was idle-tested, the failure rate was 1.52%, 0.01% of them received waivers (with waiver rate of 0.35%), 0.04% failed the anti-tampering check, and 0.12% failed the gas cap test.
For each individual NYMA county and each of the three NYTEST equipment vendors (ESP, SUN or Snap-On, and SPX), their initial test volumes and initial failure rates were tabulated and are presented in Appendix D. In terms of the number of inspection stations, ESP has the biggest share (58.08%), followed by SUN (21.74%) and SPX (20.18%). Note that almost all inspection facilities are located within the NYMA nine county boundary. Only a few inspection stations are located outside the NYMA boundary (Orange and Putnam counties, and a facility used by the New York Port Authority located in New Jersey), and they are combined under the category of "other county" (or Other) in Appendix D.
Based on the NYMA transient tested vehicle fleet, the overall average emission reductions attributed to the repair of 229,210 light-duty vehicles that failed the transient test are: 0.98/15.97/1.84 in g/mi for HC/CO/NOx, respectively. The overall average emission reductions from the repair of 5,935 idle-tested light-duty vehicles are: 246 ppm for HC and 1.53% for CO. Detailed average emission reductions due to repairs are provided in Appendix E, listed by vehicle model year, vehicle type, and type of emissions test.
It was observed from previous years' enhanced I/M program data that a portion of the light-duty fleet, after failing their initial test, switched to and passed a different test (either from an initial transient to final idle, or from an initial idle to final transient). The total number of these "switchers" was 19,789 (0.55% of total) in year 2000, 8,969 (0.24% of total) in year 2001, and 6,289 (0.17% of total) in year 2002. This number has further reduced to 5,211 (4,492 switched from transient to idle and 719 switched from idle to transient, 0.14% of total emission tested fleet) in 2003.
The EPA IM240 final cutpoints were implemented on April 1, 2003 in the NYMA enhanced I/M program. As expected, overall higher failure rates were observed for both light-duty vehicles and light-duty trucks.
The OBD inspection program began to be incorporated into the NYMA I/M program in July of 2004, but data is not available at this time.
Statistics related to the overall UPSTATE I/M program are provided in Tables II.B.1 and II.B.2. As can be seen, from a total of 5,514,634 light-duty fleet that was subject to annual safety inspections, 0.28% failed safety inspections, 0.04% failed the anti-tampering check, and 0.05% failed the gas cap test. Since the UPSTATE I/M program has no computerized network system, no detailed statistics (by vehicle model year, by vehicle type, or by county) are available. With the implementation of an OBD inspection program planned for the near future for the Upstate counties, it is expected that a computer network-based inspection system, similar to the one currently operating in NYMA, will soon be set up so that test data from the UPSTATE I/M program can be reported in detail.
C. Quality Assurance Report
Considerable progress has been continuing in NYSDMV's quality assurance programs. Case development and hearing testimony training were revisited in year 2001 with review work continued into year 2002, resulting in a more refined and efficient procedure being developed for use by the enforcement personnel. Access to intranet-based query offerings on inspection data and inspection certificate data were expanded, and the number of users doubled from the previous year. In addition, field staff have been able to call in for an immediate administrative stop on inspection stations for failure to comply with the regulations. A new electronic case-tracking management tool named CAPTAIN, developed in 2001, has been fully functional during 2002. Refinements of the desk audit techniques and administrative stop capabilities are continuing.
Results of the various NYSDMV compliance efforts in NYMA I/M program are summarized in Table II.C.1. From a total of 4,059 certified inspection stations and a total of 17,248 inspectors licensed and certified to conduct safety inspections and emissions testings in NYMA, a total of 8,628 overt audits was performed. All inspection stations have received at least one overt audit, with most stations receiving two. Stations not receiving two overt audits were typically new facilities whose premises were recently (initially) inspected by field personnel for compliance with regulations prior to operation. In addition to these "regularly scheduled" overt audits, inspection stations were also specially targeted for overt audits based on their history of having high frequencies of idle tests performed and/or high numbers of gas cap tests bypassed. As a result of hearings related to overt audits, 9 inspection stations were suspended for a total number of 456 days.
A total of 1,436 covert audits and 150 inspection station surveillance audits were performed. Of the covert audits that were completed, 213 vehicles were set to fail on one component of the emissions tests and 80 were set to fail for two or more. Components set to fail included: 8 for catalyst, 87 for EGR, 79 for PCV, 35 for evaporative emission system, 104 for gas cap, 0 for ignition system (including ignition and wires), 1 for oxygen sensor, 0 for MAP, 0 for mass air flow, 0 for fuel pressure, 2 for air filter, and numerous for safety inspection related failures. From these, 146 inspection stations correctly failed the vehicle, 79 resulted in false passes with vehicles set to fail on one component, 38 false passed with vehicles set to fail on two or more components. In 21 of the covert audits, the inspection stations were allowed to diagnose and repair the vehicles. 16 of the facilities diagnosed and repaired the vehicles properly and 5 did so improperly.
A total of 21 covert vehicles and 18 covert auditors were made available for use in the undercover audit work in NYMA. As a result of hearings related to covert and surveillance audits, 26 inspection stations were suspended for a total of 664 days.
Desk audits were primarily based on weekly queries of inspection data focused on some preset criteria such as intentionally bypassing the transient tests via incorrect vehicle weight code, vehicle type, and/or traction control/all wheel drive code. This desk audit work has proven to be more efficient in producing results than the costlier covert audits required by the EPA. In 2003, a total of 403 desk audits was performed, with 9 inspection stations suspended due to desk audits for 127 days. Consumer complaints are also being used as a source of enforcement action. Based on a total of 314 cases, 29 inspection stations were suspended due to complaints/hearings for 1,050 days.
In addition, the use of administrative stops in our quality assurance program has been viewed as an extremely effective tool. Usually the administrative stops are the direct result of desk audits described above (via weekly queries of the database), telephone requests by the field staff, or from NYSDEC equipment audits. Administrative stops are placed on the facility file to prevent the inspection stations from performing inspections/emissions tests until they conform to the requirements of the license or registration they hold. These are immediately very effective in the NYTEST realtime environment. Table II.C.3 summarizes the statistics on administrative stops. As shown, during 2003, a total of 1,013 administrative stops was issued.
Progress has been made toward improving and refining quality assurance elements for the UPSTATE I/M program as well. Statistics on various elements in the UPSTATE quality assurance program are presented in Table II.C.2. There were 8,730 licensed inspection stations and a total of 23,274 inspectors certified to conduct safety inspections in the Upstate area. A total of 8,507 overt audits was performed. As a result of hearings related to overt audits, 6 inspection stations were suspended for a total of 197 days. A total of 1,096 covert audits was performed. From hearings related to covert audits, 39 inspection stations were suspended for a total of 3,237 days.
For the Upstate area, 21 covert vehicles and 32 covert auditors were made available for use in the undercover audit work. A total of 284 cases of consumer complaints was received. As a result of hearings related to consumer complaints, 19 inspection stations were suspended for a total of 1,643 days.
The administrative stop has also been utilized in the UPSTATE program, although it is less effective as in the NYMA program. Inspection facilities are unable to procure any additional stickers when they have a stop on their facility license. Statistics on administrative stops are presented in Table II.C.3. As shown, a total of 111 administrative stops were issued for the UPSTATE during 2003.
All the quality assurance program elements that have been in place for the NYMA I/M program would be applied to the Upstate area, once an OBD inspection program (and the computerized network system) is implemented.
D. Quality Control Report
The fully decentralized test-and-repair network with 4,059 inspection stations in NYMA inherently demands increased quality control resources when compared to centralized test-only designs. The NYTEST equipment utilizes three (3) main components to analyze and evaluate vehicle exhaust emissions: a dynamometer, a VMASTM sampler, and an analyzer gas bench. Many of the analyzer check requirements defined in 40 CFR Part 51.359 were developed for high-volume centralized test programs using laboratory-grade instruments, and therefore, are not directly applicable to the NYTEST environment. In addition, given the high number and geographic dispersion of the inspection facilities located in NYMA, it is not feasible for NYSDEC to conduct performance audits twice per year for each inspection station.
Procedures to conduct equipment audits at the NYMA inspection stations were developed during 2001, and the full equipment audits commenced in August 2001. During 2003, NYSDEC visited 259 stations and conducted a total of 231 equipment audits. Table II.D summarizes the equipment audit statistics for 2003. Note that many inspection facilities failed the equipment audits for more than one reason. Therefore, the audit failure percentages in Table II.D would add up to more than 100%. The top three (3) audit failures were: leak check, gas audit, and VMASTM flow check.
Administrative stops were issued to inspection stations that failed the equipment audits, per discussions in the Quality Assurance Report section. Note that an audit failure for any of the reasons listed in Table II.D does not necessarily lead to an administrative stop (or a shutdown), since the majority of the audit failures were remedied/corrected within 72 hours. As shown in Tables II.C.3 and II.D, a total of 126 failed equipment audit cases were noted, while 18 administrative stops/facility shutdowns were issued by NYSDMV.
The UPSTATE I/M program currently does not use any emissions test equipment, and does not require equipment audits. It is anticipated that when an OBD inspection program (and the computerized network system) is implemented, there will be a quality control program based on OBD scanning tool audit procedure developed for the Upstate area.
E. Enforcement Program Report
The high enhanced I/M program in NYMA has provided mandatory annual safety inspections for all light-duty fleet and mandatory annual safety inspections with emission tests for the estimated 85.25% of the light-duty fleet. A total of 5,136,000 stickers were issued in 2003. Under this program, stickers are being generated by the computer with a security font. With the computerized network system, the number of stickers missing, stolen, or sold has decreased.
NYSDMV implemented a registration-based denial enforcement program in 2001. This program was phased in gradually based on vehicle's model year. Full implementation was successfully reached in late 2002 with all model years requiring an emission inspection. Under this program, motorists must have a valid inspection on file within the previous 15 months upon registration renewal. Otherwise, a warning is printed on the registration renewal invitation. In the event that motorists provide sufficient proof (e.g., valid sticker number or receipt) later on, the denial would be overridden and renewal of registration would be allowed. During 2003, 147,339 motorists received a warning with their registration renewal invitation. Of the motorists who received this warning, 56,157 still attempted to renew their registration without correcting the problem and were denied renewal. The summary of this month by month registration denial enforcement program statistics is provided in Table II.E.
Vehicle information, such as a license expiration date, area of operation (i.e., NYMA or outside NYMA), vehicle weight class, provided by the motorists at the time of vehicle registration, has already been built into the bar-code entries which are required and transmitted to the NYMA database at the time of vehicle inspection/emissions testing. Both NYSDEC and NYSDMV have been utilizing the database as a computer matching-based enforcement program to monitor the vehicle information and check for validity. For example, a transient-tested vehicle must not be coded as heavy-duty vehicle. These rigorous studies and investigations are ongoing resulting in record updates and data corrections.
From the inspection sticker compliance survey, NYSDMV inspected 9,600 stickers from vehicles in NYMA. An overall compliance rate of 97.91% was found. The results can be broken down by the following categories: 17 (0.18%) had no stickers, 7 (0.07%) had the wrong stickers, 100 (1.04%) with stickers expired for less than 60 days, and 77 (0.80%) with stickers expired for 60 days or more.
Since the UPSTATE program is not computerized at this time, there is no registration-based denial enforcement program implemented as yet. An enforcement activity that is unique to the Upstate area is based on the traffic tickets issued by law enforcement from multiple sources such as state, county and local courts from most of the Upstate area excluding NYMA and some cities in the western part of the State. There were 183,834 traffic tickets issued to motorists in 2003 for having a 306B violation (i.e., operating uninspected vehicles).
With the implementation of NYVIP program in the UPSTATE area by September of 2004, the computer matching-based enforcement program, parking lot sticker audits, and inspection sticker compliance survey program currently operational in NYMA could easily be adapted to the Upstate area to become statewide programs.
