2005 I/M Program Annual Report
The United States Environmental Protection Agency (USEPA or EPA) has defined the reporting requirements for all state-run Inspection/Maintenance (I/M) programs in 40 CFR Part 51.366 (7-1-98 Edition). The I/M program for the State of New York (the State) is jointly administered by the New York State Department of Environmental Conservation (NYSDEC) and the Department of Motor Vehicles (NYSDMV). This report reflects the coordination between the two agencies and is being submitted to the EPA to fulfill the State's annual reporting requirements for the calendar year of 2005.
Since 1998, the State has operated a high enhanced I/M program in the nine (9) counties of the New York Metropolitan Area (NYMA). A mass emission transient test, referred to as the New York Transient Emission Short Test (NYTEST), is the cornerstone of this program. The installation of the New York Vehicle Inspection Program (NYVIP) OBD software began in NYMA on April 1, 2005, and by May 5, 2005 all testing facilities were required to conduct OBD II inspections. In 2005, more than 4.7 million vehicles and trucks were registered in NYMA, of which 75.34% had emissions tests and 58.40% of the emission tests were OBD II inspections.
A low enhanced I/M program has been operating in the remaining fifty-three (53) counties of New York (Upstate New York or Upstate) since 1998. The NYVIP, an OBD II-based I/M program, was implemented on December 1, 2004. In 2005, more than 5.1 million vehicles and trucks were registered in Upstate and 55.30% of them received OBD II inspections.
Pursuant to a Consent Order filed on September 6, 1977, the taxi fleet operating in New York City is required to be emissions tested three times per year. These vehicles were included in the NYMA enhanced I/M Program since 1998. Following upgrades to their Woodside testing facility, the New York City Taxi Limousine Commissions (TLC) commenced OBD II inspection for all yellow medallion taxi cabs on December 8, 2003. The program continued in 2005 for their fleet of 14,527 vehicles and a total of 33,406 OBD II inspections performed.
The State's goal is to continue improving the performance of the many tasks that are already in place in the program. New York will maintain conformance with the March 1996 I/M State Implementation Plan (SIP) and the proposed February 2006 NYVIP SIP, and its intended goal: cleaner air for the residents of New York.
In keeping with the Federal Clean Air Act Amendments (CAAA) of 1990, the NYSDEC and the NYSDMV in 1998 jointly implemented a high enhanced I/M program for NYMA and a low enhanced I/M program for Upstate, as outlined in the State's March 1996 I/M SIP and the proposed February 2006 NYVIP SIP.
In accordance with the reporting requirements described under 40 CFR Part 51.366 paragraphs (a) through (d), this report documents all the required annual information for the I/M program operations in the State of New York, including a high enhanced I/M program in NYMA, a low enhanced I/M program in Upstate, and a New York City taxi OBDII inspection program. The reporting period is from January 1, 2005 to December 31, 2005.
A. High Enhanced I/M Program in NYMA
A high enhanced I/M Program has been in operation in the following nine (9) counties in NYMA:
- Nassau and Suffolk counties in Long Island,
- the five (5) counties of New York City: Bronx, Kings, New York (or Manhattan), Queens, and Richmond, and,
- Rockland and Westchester counties located immediately north of the New York City.
Under the 1990 CAAA, the entire NYMA and seven towns in southern Orange County were designated as a severe non-attainment area for the one-hour ozone National Ambient Air Quality Standard. The City of New York and the counties of Nassau and Westchester were designated as non-attainment for CO until 2002 when they were re-designated as a maintenance area. New York County is also a moderate non-attainment area for PM10.
An idle test based I/M program was initially implemented in NYMA in 1981. On January 1, 1998, this idle emissions test program was replaced with a phase-in high enhanced I/M program.1 By May of 1999, this enhanced I/M program was fully functional for the entire NYMA. In 2004, a limited number of testing facilities commenced OBD II inspections using NYTEST-based OBD software certified by the State from two of the NYTEST equipment vendors (ESP, and SPX). The installation of the NYVIP-based OBD software (described in the next section) began in NYMA on April 1, 2005, and effective May 5, 2005 all testing facilities were required to conduct OBD II inspections for all applicable 1996+ model year light duty fleet.
Under this high enhanced I/M program, all vehicles registered in NYMA are required to have a safety inspection and an emissions test if not exempted, on an annual basis as well as at the time of vehicle ownership change. Vehicles exempted from the emissions test include: diesel-fueled vehicles, electric vehicles, motorcycles, historic vehicles, farm equipment, two-cycle spark ignition vehicles. In addition, the gasoline-fueled vehicles are exempt if less than two years or over 25 years old. The required emissions test includes:
- a comprehensive visual inspection of a given list of emissions control devices (ECDs) when applicable,
- a gas cap integrity (or pressure) check for NYTEST vehicles, a gas cap presence check for OBD inspected vehicles, and,
- one of the following emissions tests depending upon the vehicle type and vehicle model year:
- a one-speed idle test for all heavy-duty vehicles (HDVs),
- a mass-based emissions test (or NYTEST) for model years between 1981 and 1995 light-duty vehicles (LDVs) and light-duty trucks (LDTs),
- a one-speed idle test for model years between1981 and 1995 LDVs and LDTs equipped with all-wheel-drive or non-disengageable traction control (when it is impossible to perform a transient test on a two-wheel-drive dynamometer),
- an OBD II inspection for model years 1996+ LDVs and LDTs.
During 2005, 1,637,935 vehicles received NYTEST from 3,918 testing facilities. Graph 1 shows the distribution of testing facilities that performed NYTEST. In addition, 2,094,202 vehicles had OBD inspection from 3,767 testing stations located within NYMA. Graph 2 shows the distribution of testing facilities that performed OBD inspections. Note that all NYMA testing facilities are required to be capable of performing NYTEST and OBD inspections. Therefore, many testing facilities were in both Graph 1 and Graph 2.
B. Low Enhanced I/M Program in Upstate
Being located within the Ozone Transport Region (OTR), a low enhanced I/M program was implemented in the remaining fifty-three (53) counties of New York (Upstate) in January 1998, as outlined in the State's March 1996 SIP. An OBD II-based I/M program, named New York Vehicle Inspection Program (NYVIP), was phased in starting on September 17, 2004, and fully implemented on December 1, 2004. This NYVIP was expanded into NYMA effective May 5, 2005 to provide for a statewide OBD II inspection program.
Under this Upstate program, all vehicles registered in the Upstate counties are required to have a safety inspection and an emissions test if not exempted, on an annual basis as well as at the time of vehicle ownership change. Vehicles exempted from the emissions test include: diesel-fueled vehicles, electric vehicles, motorcycles, historic vehicles, farm equipment, two-cycle spark ignition vehicles. In addition, for gasoline-fueled vehicles we exempt the first two model years and those over 25 years old. The required emissions test includes:
- a comprehensive visual inspection of a given list of ECDs when applicable,
- a gas cap presence check, and,
- an OBD II inspection for model years 1996+ LDVs and LDTs.
During 2005, 2,821,855 vehicles had OBD II inspections from 6,193 participating testing facilities. Graph 3 shows the distributions of the OBD II inspection stations located in the Upstate area.
C. New York City Taxi Limousine Commissions (TLC) OBD II Inspection Program
The New York City TLC, under terms of a September 6, 1977 Consent Order with the City and other parties, is required to provide emissions testing for all of the taxi fleet on a three-times-per-year basis. Since 1998, the entire taxi fleet operating in NYMA has been included in the high enhanced I/M program described above.
On December 8, 2003, with the assistance from the TLC contractor, SysTech International, the first two lanes at TLC's Woodside inspection facility began safety and OBD II inspections. By August of 2004 all six lanes were operational.
With no provision for waivers and exemptions (i.e., including those at age two years and newer) , the entire TLC yellow medallion taxi fleet is required to undergo inspections at four month intervals. The required inspections include:
- a comprehensive safety check on various components of the vehicle including headlight, suspension, side slip, and brake system,
- visual inspections including ECD tampering check and gas cap presence check, and,
- an OBD II inspection.
In 2005, the entire fleet of 14,527 yellow medallions (13,288 LDVs and 1,239 LDTs) had more than 33,000 OBD II inspections performed. As of December 31, 2005 remaining issues include: inadequate reporting of the gas cap presence check result (i.e., not recorded in TLC's database, nor reported to NYSDEC), and the need to transmit inspection records in a form approved by the NYSDMV. These issues are expected to be resolved in 2006.
The collection of accurate data is essential to the management, evaluation, and enforcement of an efficient I/M program. The State's high enhanced I/M program in NYMA has been collecting vehicle inspection and emissions testing data since the onset of the program in January 1998. Quality control data related to NYTEST emissions testing equipment have also been collected since August 2001. The low enhanced I/M program for Upstate has been collecting computerized vehicle inspection and emissions test data since September 17, 2004. Computerized OBD II inspection data collected by the TLC have also been provided to NYS DEC since December 8, 2003.
A. Computerized Network
Under contracts with NYSDMV, SGS TestCom, Inc. has been the Data Manager for the NYMA I/M program since 1998, and the Program Manager for the NYVIP since 2004.
A computerized network is utilized by both the NYMA and Upstate programs for transmitting the real-time inspection/emissions data from all decentralized test-and-repair inspection stations to NYSDMV's mainframe computer and SGS TestCom computer servers. Data is downloaded and provided to NYSDEC on a biweekly basis.
Both contracts (managed by NYSDMV) require that SGS TestCom prepare and submit monthly reports on various aspects of the network performance. Compiled and reported statistics include transaction volume, number and type of help desk calls, system availability, average round-trip time, and average response time. Data management meetings are being held every month with full staff participation from NYSDMV, NYSDEC, and SGS Testcom. During these meetings, network performance and efficiency related issues are discussed.
The computerized network has also been utilized as a means for communications between the Contractor and the 9,960 inspection facilities across the State. In addition, real-time inspection activities are being monitored by both NYSDMV and NYSDEC based on various enforcement criteria. More effective enforcement actions have resulted and are presented in the Quality Assurance Report and Quality Control Report sections.
SysTech International is the Program Manager for the TLC OBD II inspection program. Data has been provided to NYSDEC on a monthly basis and to NYSDMV on an annual basis.
B. Test Data Report
Overall statistics related to the registered vehicle fleet (based on unique vehicle identification numbers, or VINs), by vehicle model year, fuel type, and I/M area (i.e., NYMA, Upstate) for year 2005 are provided in Appendix A Table A-1 (Page A-1). Note that some vehicle types were excluded due to the fact that they are exempted from the I/M program. Examples of these vehicle types are: all-terrain vehicles, motorcycles, farm equipment, commercial semi-trailers, snowmobiles, and motorboats. The statistics did include all the yellow medallions under TLC's OBD II inspection program. As can be seen, 96.79% of the vehicles registered in NYMA and 96.09% of those in Upstate were gasoline-powered. Diesel-fueled vehicles represented 2.97% of the NYMA fleet and 3.60% of the Upstate fleet. Only 0.23% of the NYMA and 0.30% of the Upstate vehicles, respectively, were compressed natural gas, propane, flex fueled or electric.
Appendix A Table A-2 (Page A-2) provides emissions tested vehicle counts from the three programs (NYMA, Upstate and TLC). Note that the vehicle counts for both NYMA and Upstate included vehicles with ownership change, excluded NYMA vehicles using Sun version 4.10 software for their transient/idle tests (described below), while the TLC vehicle counts represented the number of yellow medallions operating in NYMA. Note that all applicable model year 1996+ vehicles in NYMA were required to have OBD II inspections since May 5, 2005, thus resulting the number of vehicles in this model year group having NYTEST inspections being significantly reduced.
Summary statistics related to OBD II inspections from NYMA, Upstate, and TLC is provided in Appendix B (Tables B-1-a-i to B-3-b-ii). For example:
- In NYMA, 1,318,676 LDVs and 775,526 LDTs (representing 58.23% of the emissions tested fleet) had OBDII inspections with failure rates of 9.28% and 10.64%, respectively.
- From Upstate, the OBD II inspection failure rates were 6.78% for LDVs (from 1,584,493 vehicles) and 7.60% for LDTs (from a sample of 1,237,362 vehicles), slightly lower than those observed from the NYMA fleet.
- Due to their high odometer readings, the TLC vehicles had the highest OBD II inspection failure rates: 23.59% for the LDVs and 11.80% for the LDTs.
Summary statistics related to NYMA NYTEST results are provided in Appendix C (Tables C-1-a to C-2-c). A software reporting error by the SUN NYTEST platforms resulted in the need to exclude all their emissions test data from this 2005 Annual Report. Although the pass/fail determinations were performed correctly, the SUN version 4.10 software erroneously reported emissions readings (i.e., placed in the wrong data fields). A revised software version has been submitted to NYSDEC and NYSDMV to correct this issue. Due to this software issue, 124,582 transient-tested and 11,357 idle-tested LDVs and LDTs were excluded from Appendix A Table A-2, all tables in Appendix C, and NYMA county tables in Appendix D.
- From transient tested 974,064 LDVs and 341,687 LDTs (36.59% of the emissions tested NYMA fleet), the failure rates were 8.20% and 7.23%, with waiver rates 1.30% and 1.60% for the LDVs and LDTs, respectively. The overall average emission reductions were: 0.86/13.89/1.58 in g/mi for HC/CO/NOx respectively for LDVs, and 1.23/16.79/2.25 in g/mi for HC/CO/NOx respectively for LDTs.
- From idle tested 60,553 LDVs and 125,692 LDTs (5.18% of the emissions tested NYMA fleet), the failure rates were 2.93% and 2.19%, with waiver rates of 0.45% and 0.80% for the LDVs and LDTs, respectively. The overall average emission reductions were: 194 ppm for HC and 1.31% for CO for the LDVs, and 246 ppm for HC and 1.50% for CO for the LDTs
Appendix D describes the initial test volume and failure rate statistics by vehicle model year and each vehicle type (LDVs and LDTs) for each county. Note that the initial test volume and failure rate statistics from TLC data are already included in Appendix B (Tables B-3-a-i to B-3-b-ii), since all data were from one single testing facility. Appendix D (Tables D-1-1 to D-1-2) includes a total of twelve tables with statistics from the three different types of emissions tests (OBD II inspection, NYTEST transient, and NYTEST idle tests) for: the NYMA nine counties, two Upstate counties (Orange and Putnam counties where a few NYTEST facilities are licensed), and "Others" that consists of testing facilities with unknown NYMA or Upstate designations and one inspection station located in Jersey City, New Jersey under the jurisdiction of Port Authority of New York and New Jersey. Statistics on OBD II inspections from the remaining Upstate counties are provided in Appendix D Table D-2.
Per section 51.373 Subpart S (Inspection/Maintenance Program Requirements) updated on July 27, 2005, statistics related to anti-tampering ECD check and gas cap test results are no longer required. Therefore, the statistics are not included in this report.
C. Quality Assurance Report
Considerable progress continues to be made in NYSDMV's quality assurance programs. Case development and hearing testimony training, based on a more refined and efficient procedure developed during previous years, has been in place for use by the enforcement personnel since 2002. The use of intranet-based query offerings on inspection data and inspection certificate data has resulted in more users accessing the system and shorter turnaround time in issuing administrative stops on inspection stations for failure to comply with the regulations. The electronic case-tracking management tool named CAPTAIN, initially developed in 2001, has been fully functional since 2002. Refinements of the desk audit techniques and administrative stop capabilities are continuing.
The results of the various NYSDMV compliance efforts in the NYMA I/M program are summarized in Table II.C.1. From a total of 3,918 certified inspection stations and 13,552 licensed inspectors in NYMA, a total of 9,483 overt audits was performed.2 As a result of hearings related to overt audits, 12 inspection stations were suspended for a total number of 543 days.
A total of 17 covert vehicles and 23 covert auditors were made available for use in the undercover audit work in NYMA. A total of 1,951 covert audits and 22 inspection station surveillance audits were performed. As a result of hearings related to covert and surveillance audits, 62 inspection stations were suspended for a total of 1,528 days.
Of the covert audits that were completed, 416 vehicles were set to fail on one component of the emissions tests and 39 were set to fail for two or more. Components set to fail included: 21 for catalyst, 179 for EGR, 87 for evaporative emission system, 51 for gas caps, 43 for OBD Malfunction Indicator Light (MIL) On, 116 for various OBD monitors, and numerous for safety inspection related failures. From these, 381 inspection stations correctly failed the vehicle, 11 inspection stations false passed with vehicles set to fail on one component, one false passed with vehicles set to fail on two or more components, and 38 inspection stations did not do the inspections.
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 2005, a total of 232 desk audits was performed, with 5 inspection stations suspended for 145 days. Consumer complaints are also being used as a source of enforcement action. Based on a total of 272 cases, 10 inspection stations were suspended for 389 days.
In addition, the use of administrative stops in NYSDMV's 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's NYTEST file-based 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 have been very effective in the NYTEST real-time environment. Table II.C.3 summarizes the statistics on administrative stops. As shown, during 2005, a total of 1,596 administrative stops was issued.
Statistics on various elements in the Upstate quality assurance program are presented in Table II.C.2. There were 6,193 licensed inspection stations and 22,277 certified inspectors to conduct safety and OBDII inspections in the Upstate area. A total of 6,841 overt audits was performed in 2005. As a result of hearings related to overt audits, 6 inspection stations were suspended for a total of 265 days.
A total of 12 covert vehicles and 32 covert auditors were available for the undercover audit work for Upstate. A total of 1,086 covert audits was performed. From hearings related to covert audits, 22 inspection stations were suspended for a total of 1,733 days.
Of the covert audits that were completed, 152 vehicles were set to fail on one component of the emissions tests (and no vehicles were set to fail for two or more). Components set to fail included: 16 for catalyst, 21 for EGR, 54 for gas caps, 1 for OBD MIL On, 53 for various OBD monitors and 7 for OBD non-communications, and numerous for safety inspection related failures. From these, 112 inspection stations correctly failed the vehicle, 11 inspection stations false passed with vehicles set to fail on one component, and 7 inspection stations did not do the inspections.
In 2005, desk audits were not performed for the Upstate program. A total of 400 cases of consumer complaints was received. As a result of hearings related to consumer complaints, 15 inspection stations were suspended for a total of 1,416 days.
During 2005, a total of 95 administrative stops was issued for Upstate, as shown in Table II.C.3.
D. Quality Control Report
The NYTEST equipment utilizes three main components to analyze and evaluate vehicle exhaust emissions: Dynamometer, VMASTM sampler, and analyzer gas bench. Many of the analyzers 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 a year for each inspection station.
Procedures to conduct NYTEST equipment audits at the NYMA inspection stations were developed in 2001, and the full equipment audits commenced in August 2001. In 2005, NYSDEC visited 551 stations and conducted a total of 531 audits. Table II.D summarizes the NYTEST equipment audit statistics for 2005. 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 audit failure reasons were: leak check, calibration gas, and gas audit.
The percentage of testing stations failing the NYTEST equipment audits decreased in 2005. Stations were again specifically selected for audits based on the reported performance data indicating potential problems: i.e., low failure rate, high idle test percentage, high gas cap bypass rate, or had extremely high emissions readings. Also, more stations were audited on a geographic basis.
Administrative stops (or a shutdown) are issued to inspection stations that fail the NYTEST 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 did not necessarily lead to an administrative stop, since the majority of the audit failures were remedied/corrected within the required seventy-two hour time frames. In 2005, a total of 273 failed NYTEST equipment audit cases was noted, as shown in Table II.D. A total of 25 administrative stops/facility shutdowns were issued by NYSDMV, as shown in Table II.C.3.
Additionally, as part of the required NYTEST software update conducted by the vendors during 2001, certain analyzer quality assurance checks (i.e., periodic calibrations) are required on a daily and weekly basis. The software is designed to assure that acceptance criteria are met. Otherwise, the analyzer would be "locked out" and prevented from further testing until appropriate and necessary repairs are made. This quality control check information is automatically recorded and transferred to the NYSDEC in the form of calibration records. These records have also been used to target facilities for an NYTEST equipment audit. In 2005, a total of 222,287 calibration records was received.
E. Enforcement Program Report
With mandatory annual safety inspections and emissions tests, stickers (for passing vehicles) are being accounted for electronically (NYTEST and NYVIP) as well as generated directly by the inspection equipment (NYTEST) with a security font. With these computerized systems, the number of stickers missing, stolen, or sold has decreased.
Vehicle information, such as registration expiration date, area of operation (i.e., NYMA or Upstate), weight class, and fuel, have been encoded into the bar code for use during vehicle inspection. Both NYSDEC and NYSDMV utilize the database as a computer matching-based enforcement program to monitor the vehicle information and to check for validity. For example, a transient-tested vehicle must not be coded as a heavy-duty vehicle, or an applicable model year 1996+ light duty vehicle must receive an OBDII inspection. In addition, issues related to clean scanning and repair waivers are also being examined. These rigorous studies and investigations are ongoing, and have resulted in record updates and data corrections.
Another enforcement activity utilized by NYS DMV is based on the traffic tickets issued by law enforcement from multiple sources such as state, county and local courts. There were 155,494 traffic tickets issued to motorists in 2005 for having a V&T Law 306(b) violation (i.e., operating an uninspected vehicle), 40,687 of them were issued in NYMA and 114,807 in Upstate.
The high enhanced I/M program has provided mandatory annual safety inspections with emission tests for 79.93% of the entire light-duty fleet, with the remaining 21.07% exempt due to vehicles' age. In 2005, a total of 4,982,070 inspection stickers was issued for NYMA.
NYSDMV implemented a phased-in registration-based denial enforcement program3 in 2001, with full implementation in late 2002. The summary of this month by month registration denial enforcement program statistics is provided in Table II.E. Due to a change in NYSDMV reporting, the number of denial warnings issued was not available. As shown in Table II.E, of those motorists receiving warning in 2005, 60,330 still attempted to renew their registration without correcting the problem and their renewals were denied.
NYSDMV inspected 4,619 stickers from NYMA vehicles. Based on the inspection sticker compliance surveys, an overall compliance rate of 96.12% was found with 23 had no stickers, 2 had the wrong stickers, 99 with stickers expired for 60 days or less, and 55 with stickers expired more than 60 days.
For the low enhanced I/M program in Upstate, 55.30% of the light-duty fleet was required to have an OBD II inspection. A total of 5,486,402 inspection stickers (for safety inspections and emissions tests) was issued.
The registration-based denial enforcement program is yet to be adapted to Upstate, as it is necessary to build up at least one year's inspection record database first. The program will be phased in gradually in the near future.
NYSDMV inspected 5,838 stickers from Upstate vehicles. Based on the inspection sticker compliance surveys, an overall compliance rate of 95.12% was found: 31 had no stickers, 18 had the wrong stickers, 158 with stickers expired for 60 days or less, and 78 with stickers expired more than 60 days.
During 2005, the State of New York has fully implemented a statewide OBD II inspection program including both the NYMA and Upstate I/M areas. For the NYMA area, the requirement of OBD II inspections (using NYVIP software) for all model year 1996+ light duty fleet has commenced on May 5, 2005. For Upstate, the OBD II inspection program (required for all applicable model year 1996+ light duty fleet) commenced on December 1, 2004. A TLC OBD II inspection program began on December 8, 2003 and has continued into 2005.
More important, continuing efforts on the part of NYSDEC and NYSDMV will enable New York State to maintain conformance with the SIP, and its intended goal: cleaner air for the residents of the State of New York.
1 This high enhanced I/M program, in a pre-existing decentralized test-and-repair network, was proposed in the State's March 1996 I/M SIP approved by EPA on June 7, 2001. The program is based on the New York Transient Emissions Short Test (NYTEST), a dynamometer-based mass emissions analyzer system (which includes a dynamometer, BAR 97 analyzer, VMASTM unit, NYTEST software, and camera) that utilizes the IM240 driving cycle.
2 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.
3 Under the program, motorists must have a valid inspection record 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.