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Appendix G - Summary of the NYVIP Readiness Report

TABLE 1 : OBD Initial Inspection Readiness Rejection/Failure Rates
STATE INITIAL READINESS REJ/FAILURE RATE COMMENT
New Jersey 1.90% Period of 01/12/04 - 04/13/05 (Started OBD August 2003)
Maryland 2.00% Year 2004 (Started OBD 2002)
Georgia 2.90% Year 2004 (Started OBD 2002)
Wisconsin 3.30% Period of 11/28/04 - 02/26/05 (Started OBD 2001)
New York 5.70% Period of 09/01/04 - 03/07/05 (Start-up/Cold Weather Study Period)
New York 5.00% Period of 07/01/2004 - 10/15/2005

FIGURE 1: NYVIP Readiness Failure Rates (Initial and All Inspections)

FIGURE 1: NYVIP Readiness Failure Rates (Initial and All Inspections)

FIGURE 2 : Minimum Daily Temperatures Across New York State

Minimum daily tempertures for Buffalo, Plattsburgh and Albany

FIGURE 3 : Temperature (Albany) and Initial Inspection Readiness Failure Rate (Statewide)

Temperature & Initial Readiness Failures

FIGURE 4: Initial Readiness Failure Rates: Overall and Dealer

Initial Readiness Failure Rate comparison of NYVIP RED and Dealer RED

FIGURE 5: Results of Alternate Readiness Criteria on Initial Inspections

Alternate readiness criteria by model year (MY)

TABLE 2: AN INSPECTION HISTORY EXAMPLE - MULTIPLE ISSUES
VIN DATE_TIME TYPE ODOMETER WAIVER RED CAT O2_SEN EGR EVAP HEAT_CAT HEAT_O2 SEC_AIR AC
1B3ES47C1TD507852 1/19/2005 18:29 1 95030 F N N N U U N U U
1B3ES47C1TD507852 1/19/2005 20:35 2 95051 F N N N U U R U U
1B3ES47C1TD507852 1/20/2005 13:29 2 95051 F N N N U U N U U
1B3ES47C1TD507852 1/20/2005 14:21 2 95051 F N N N U U N U U
1B3ES47C1TD507852 1/20/2005 18:30 2 95128 F N N N U U N U U
1B3ES47C1TD507852 1/20/2005 19:43 2 95159 F N N N U U N U U
1B3ES47C1TD507852 1/21/2005 9:39 2 95181 F N N N U U N U U
1B3ES47C1TD507852 1/23/2005 18:03 2 95244 F N N N U U N U U
1B3ES47C1TD507852 1/26/2005 15:03 2 95255 Y F N N N U U N U U

FIGURE 7: NYC Taxi and Limousine (Calculated) Initial Readiness Failure Rate

Initial readiness failure rates (calculated) for NYC taxis and limousine

SUMMARY

1. The NYVIP initial readiness failure rate is significantly higher than the other I/M jurisdictions contacted (including both centralized test-only and decentralized test-and-repair networks.) DEC attributes NYVIP's high initial readiness failure rate to:

» Start-up related issues where both motorists and inspectors are unclear as to how OBD II works;
» Unsuccessful attempts by motorists and technicians to fraudulently avoid a MIL Commanded On OBD II failure by disconnecting the battery or clearing codes with a scan tool;
» Dealers experience a higher initial readiness failure that elevates the fleet-wide NYVIP readiness failure rate statistics. Dealers account for about 14% of the initial OBD inspections, but 30% of the initial readiness failure rate; and
» The prevailing practice of "clearing codes" after every attempted repair. (At times, this is appropriate).

3. The difficulty in getting vehicles to pass an OBD re-inspection for readiness (multiple attempts) can be due to:

» Inspectors are not reviewing available information for recalls or TSBs;
» Technicians and motorists are not using, or are not completing drive cycles accurately; and
» OEM-related drive cycles have associated costs to the station/motorist and are not always readily available.

4. The proposal to add another monitor to EPA's readiness criteria for Model Year 2001 and newer vehicles would not resolve the high initial readiness failure rate issue, and would enlarge the existing readiness "loophole."

5. Other I/M jurisdictions do not experience a significant increase in the initial readiness failure rate during cold weather events.

6. The NYVIP initial readiness failure rate cannot be attributed to any one, or few, vehicle manufacturers.

7. DEC/DMV queried the NYVIP database for vehicles (not covered by EPA's guidance) that demonstrate a high initial readiness failure rate. By the limited number of affected inspections, these vehicles are NOT considered a significant source of the elevated NYVIP initial readiness failure rate. These vehicles are under discussion with other I/M jurisdictions and the EPA.