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2008 Enhanced I/M Program Annual Report and 2007-2008 Biennial Report

EXECUTIVE SUMMARY

The United States Environmental Protection Agency (USEPA or EPA) has defined the reporting requirements for motor vehicle Inspection/Maintenance (I/M) programs in 40 CFR Part 51.366. The I/M program for the State of New York (the "State", or "NYS") is jointly administered by the New York State Department of Environmental Conservation (NYSDEC) and the Department of Motor Vehicles (NYSDMV). This report reflects the coordinated effort between the two agencies to administer the program and is being submitted to the EPA to fulfill the State's annual reporting requirements for the calendar year of 2008. The biennial report addresses program changes made during the period of January 1, 2007 to December 31, 2008.

In the nine (9) counties of the New York Metropolitan Area (NYMA), the State has administered an I/M program based on an idle test since 1981. A high-enhanced I/M program using a mass emission transient test, referred to as the New York Transient Emission Short Test ("NYTEST"), has been in place since 1998. On April 1, 2005, the State commenced an on-board-diagnostic (OBD) II-based vehicle inspection program, referred to as the New York Vehicle Inspection Program ("NYVIP"). By May 5, 2005 all testing facilities in NYMA were required to conduct OBD II inspections for all applicable 1996-and-later model year light duty vehicles (LDVs) and light duty trucks (LDTs). During calendar year 2008, more than 4.9 million vehicles were registered within NYMA, of which 3,789,361 (75.96% of the total registered) were emissions- tested, and 3,144,772 (82.99% of the emissions-tested vehicles) had OBD II inspections.

Since 1998, an ozone transport region (OTR) low-enhanced I/M program has been operating in the remaining fifty-three (53) counties of New York (Upstate New York). On December 1, 2004, the State fully implemented the OBD II-based NYVIP in Upstate New York. This allowed for the inclusion of all Upstate vehicles into the State's I/M program database. In calendar year 2008, more than 5.2 million vehicles and trucks were registered in the Upstate I/M area, and 3,431,393 of them (or 64.97%) received OBD II inspections.

Pursuant to a Consent Order filed on September 6, 1977, all yellow medallion taxi cabs operating in New York City, under the jurisdiction of the New York City Taxi Limousine Commission (NYCTLC, or TLC), are required to be emissions-tested on a three-times-per-year basis. Beginning in 1981, the TLC vehicles were subject to idle testing. Following upgrades to their Woodside testing facility, the TLC commenced an OBD II inspection program for their taxi fleet on December 8, 2003. This program continued in 2008 for their fleet of 15,048 vehicles (11,917 LDVs and 3,131 LDTs), with a total 37,642 OBD II inspections performed.

New York will maintain and implement measures consistent with the SIP in order to achieve its intended goal: Clean air for the residents of the State of New York.

I. INTRODUCTION

In 1998, the New York State Departments of Motor Vehicles (NYSDMV) and Environmental Conservation (NYSDEC) implemented statewide enhanced motor vehicle inspection and maintenance (I/M) programs. These programs have evolved over time to reflect the state and federal regulatory changes, as outlined within the following State Implementation Plan (SIP) revisions: "Enhanced Motor Vehicle Inspection/Maintenance Program (March 1996)," "New York Vehicle Inspection Program - NYVIP (March 2006)," and the proposed "New York Metropolitan Area Enhanced I/M Program (June 2009)."

In accordance with federal I/M reporting requirements under 40 CFR Part 51.366, paragraphs (a) through (d), this report provides the required annual information for I/M program operations within the State of New York. New York's I/M programs include a high-enhanced I/M program in the New York Metropolitan Area (NYMA), an ozone transport region (OTR) low-enhanced I/M program in the 53-county Upstate area (Upstate), and a New York City Taxi and Limousine Commission (TLC) inspection program. The subject reporting period for this report is January 1, 2008 to December 31, 2008, as well as any program changes during the period of January 1, 2007 to December 31, 2008.

A. High-Enhanced I/M Program in NYMA

A high-enhanced I/M program has been in operation in the following nine (9) counties:

- Nassau and Suffolk Counties in Long Island,

- The five (5) counties of New York City: Bronx, Kings (or Brooklyn), New York (or Manhattan), Queens, and Richmond (or Staten Island), and

- Rockland and Westchester Counties located immediately north of the New York City.

Under the federal Clean Air Act amendments of 1990, the entire NYMA and seven (7) towns in southern Orange County were designated as a severe non-attainment area for the one-hour ozone National Ambient Air Quality Standard. New York City, Nassau County, and Westchester County were also designated as a carbon monoxide (CO) non-attainment area until 2002 when they were re-designated as a maintenance area by EPA.

The Departments initially implemented an "idle test" I/M program within NYMA in 1981. On January 1, 1998, this program was upgraded to a high-enhanced I/M program to reflect EPA's Part 51 regulatory changes. The New York high-enhanced I/M program was called the "New York Transient Emissions Short Test" or "NYTEST." NYTEST is a dynamometer-based mass emissions analyzer system (including a dynamometer, BAR 97 analyzer, VMAS^TM unit, and NYTEST software) that utilizes EPA's IM240 driving cycle. By May 1999, the NYTEST program was fully functional within NYMA.

In 2004, a limited number of NYTEST stations were approved to conduct onboard diagnostic (OBD II) inspections using optional software (certified by the Departments) from two of the three NYTEST equipment vendors (ESP and SPX). The optional NYTEST OBD program was designed to become obsolete as the Department implemented a statewide OBD II inspection program. This program was subsequently adopted as the "New York Vehicle Inspection Program" or "NYVIP." Beginning on May 5, 2005, all licensed facilities in NYMA were required to maintain the NYTEST equipment for tailpipe testing of applicable vehicles and to purchase/operate the NYVIP equipment for OBD II-applicable vehicles.

All applicable NYMA vehicles are required to have a safety inspection and an emissions test on an annual basis as well as at change of ownership. Vehicles exempted from NYVIP/NYTEST emissions testing include: diesel-fueled vehicles, electric-powered vehicles, motorcycles, historic vehicles, farm equipment, and two-cycle spark ignition vehicles. Additional age-based exemptions exist based on vehicle model year. Vehicles less than two (2) model years old, and over twenty-five (25) model years old, are exempt from emissions testing. Emissions testing within the NYMA during calendar year 2008 included:

1) a comprehensive visual inspection of listed emissions control devices (ECDs);

2) a gas cap integrity (or pressure) check for NYTEST vehicles, or a gas cap presence check for OBD II inspected vehicles; and

3) one of the following emissions tests, depending upon vehicle weight, fuel type, and age:

- an OBD II inspection for applicable light-duty vehicles (LDVs) and light-duty trucks (LDTs) model years 1996 and newer;

- a NYTEST transient test, for applicable LDVs and LDTs model years 1983 to 1995;

- a one-speed NYTEST idle emissions test for LDVs and LDTs model years 1983 to 1995, if equipped with all-wheel-drive or non-disengageable traction control; or,

- a one-speed NYTEST idle emissions test for non-diesel/non-electric heavy-duty vehicles (HDVs) model years 1983 to 2006.

During calendar year 2008, the NYMA I/M program included 1,852,124 LDV and 1,292,648 LDT OBD II inspections, for a total of 3,144,772 OBD II inspections (initial inspections) from 3,903 inspection stations. An additional 644,589 vehicles (414,438 LDVs, 148,521 LDTs, and 81,630 HDVs) received NYTEST inspections (506,692 transient tests and 137,897 idle tests) from 3,606 NYTEST facilities. The distribution of those NYMA inspection stations is shown in Graph 1.

Note that New York State also requires annual I/M testing for heavy-duty diesel-fueled vehicles (HDDVs) registered within NYMA. However, this annual report does not include the statistics for the heavy-duty diesel I/M program as this program is not a part of NYTEST or NYVIP.

B. Low-Enhanced I/M Program in Upstate

Pursuant to the requirements for the ozone transport region (OTR), a low-enhanced I/M program was implemented in the remaining 53 counties of New York in January 1998, as outlined in the State's March 1996 SIP.

OBD II testing through NYVIP commenced in the Upstate area on September 17, 2004, and was fully implemented on December 1, 2004. NYVIP implementation was completed within NYMA on May 5, 2005, thus resulting in a statewide OBD II inspection program.

Under this Upstate program, all applicable vehicles registered in the 53 counties are required to have a safety inspection and an emissions test, on an annual basis as well as at change of vehicle ownership. Vehicles less than two (2) model years old are exempt from emissions testing. The Upstate emissions inspection includes:

1) a comprehensive visual inspection of listed ECDs;

2) a gas cap presence check; and,

3) an OBD II inspection for applicable LDVs and LDTs with model years 1996 and newer.

During calendar year 2008, the Upstate OTR low-enhanced I/M Program in Upstate included a total of 1,848,924 LDVs and 1,582,469 LDTs with 3,431,393 OBD II inspections (initial inspections) from 6,611 inspection stations. Graph 2 shows the distribution of OBD II inspection stations located in the Upstate area.

C. New York City 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 their yellow medallion taxi cab fleet on a three-times-per-year basis. On December 8, 2003, the first two lanes located at TLC's upgraded Woodside inspection facility began safety and OBD II inspections. By August of 2004, all six lanes at TLC were operational.

The TLC yellow medallion taxi cab fleet is required to undergo inspections at four-month intervals. The TLC regulations do not provide for waivers or age-based exemptions. The required TLC inspection includes:

1) a comprehensive safety check on various components of the vehicle including headlights, suspension, side slip, and brake system;

2) a comprehensive visual inspection of a given list of ECDs tampering check;

3) a gas cap presence check; and

4) an OBD II inspection.

In calendar year 2008, the TLC fleet of yellow medallion cabs (11,917 LDVs and 3,131 LDTs) received 37,642 OBD initial inspections. Note that some medallion taxicabs are retired from service during the calendar year and, therefore, those vehicles may not receive all three initial inspections.

II. DATA ANALYSIS AND REPORTING

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 within 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 on a monthly basis to NYSDEC since December 2003.

A. Computerized Network

SGS Testcom, Inc. has been the Data Manager for the NYTEST program since 1998, and the Program Manager for the NYVIP since 2004. A computerized network has been utilized for both the NYMA and Upstate programs for transmitting the real-time inspections/emissions data from all decentralized test-and-repair inspection stations to NYSDMV's mainframe computer and SGS Testcom's computer servers. NYSDEC continues to download the vehicle inspection/emissions data from SGS Testcom on a weekly basis.

This computerized network has also been utilized as a means for communications between the Contractor and the 10,514 testing facilities. Of these, 3,903 are located within NYMA and 6,611 are located within Upstate New York. 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.

Both NYTEST and NYVIP 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 volumes, numbers and types of help desk calls, system availability, and average response time. The statistics are summarized in Table II.A. Data management meetings are held every month with full staff participation from NYSDMV, NYSDEC, and SGS Testcom. During these meetings, network performance and efficiency related issues are discussed.

SysTech, International is the Program Manager for the TLC OBD II inspection program. During calendar year 2008, TLC data have been provided to both NYSDEC and NYSDMV on a monthly basis.

Table II.A: Data Management System Statistics (Calendar Year 2008)

Category	System Statistics
	January to March	April to June	July to September	October to December	Total
NYTEST Program* (from NYMA)
Transaction Volumes	540,107	659,564	635,815	555,764	2,391,250
-- Safety Only Updates	9,012	11,116	10,621	10,125	40,874
-- Emissions Updates	187,643	226,124	217,936	191,448	823,151
NYVIP Program (from both NYMA and UPSTATE)
Transaction Volumes	4,586,673	5,726,377	5,627,209	4,585,602	20,525,861
Emissions Updates	2,379,931	3,037,450	2,976,356	2,422,122	10,815,859
Total Help Desk Calls	10,897	15,700	11,562	8,946	47,105
System Availability	100.0%	100.0%	100.0%	100.0%	100.0%
Average Response Time** for Inquiry	0.9 seconds	0.4 seconds	0.4 seconds	2.3 seconds	1.0 seconds

* During calendar year 2008, all the "Help Desk Calls" for the NYTEST Program were handled by and combined with the NYVIP Program.
** After the modem link is established.

B. Test Data Report

Per section 40 CFR Part 51.373, statistics related to anti-tampering ECD check and gas cap test results are no longer required. Therefore, these statistics are not included in this 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., either NYMA or Upstate) for calendar year 2008 are provided in Table II.B.1, with more detailed statistics shown in Appendix A Table A-1.

Note that the statistics included the yellow medallions under TLC's OBD II inspection program and excluded vehicle types exempted from the I/M program. As can be seen, 96.25% of the NYMA and 95.12% of the Upstate registered vehicles were gasoline-powered. The hybrid vehicle counts are shown as a separate category in Table II.B.1 as they are already included in the gasoline fueled vehicle counts. Diesel-fueled vehicles represented 3.57% of the NYMA and 4.54% of the Upstate vehicle fleet. Only 0.18% of the NYMA and 0.33% of the Upstate vehicles, respectively, were powered with other fuels such as compressed natural gas, propane, or electric.

Table II.B.2 displays some general statistics derived from the emissions-tested vehicle fleet, with Appendix A Table A-2 providing emissions-tested vehicle counts from the three I/M programs (NYMA, Upstate, and TLC).

Note that the vehicle counts from NYMA and Upstate programs include vehicles with ownership change, while the TLC vehicle counts represent the number of yellow medallions operating in NYMA.

1. OBD II Inspection Programs

Detailed statistics related to the OBD II inspections obtained from NYMA, Upstate and TLC are provided in Appendix B, Tables B-1-a-i to B-3-b-ii.

In NYMA, as shown in Appendix B, Table B-1-a-i and Table B-1-b-i, 1,852,124 LDVs and 1,292,648 LDTs (representing 82.99% of the total emissions tested fleet) were OBD II inspected, with failure rates of 5.73% and 6.25%, and waiver rates of 2.04% and 1.98%, respectively. For Upstate, as shown in Appendix B Table B-2-a-i and Table B-2-b-i, the OBD II inspection failure rates were 5.66% for the 1,848,924 LDVs and 5.98% for the 1,582,469 LDTs. The waiver rates were 2.24% for LDVs and 2.01% for LDTs.

Due to their high mileage accumulation and the nature of being service vehicles, the TLC fleet, as shown in Appendix B Table B-3-a-i and Table B-3-b-i, had very high OBD II inspection failure rates: 15.41% for the LDVs and 8.17% for the LDTs. Note that no waivers are permitted for the TLC fleet.

Table II.B.1: General Statistics on New York State I/M Program (Calendar Year 2008)

Category	NYMA		UPSTATE
	Count	% of Total	Count	% of Total
Number of Counties	9		53
Number of Inspection Stations	3,903		6,611
Number of Certified Inspectors	13,106		21,814
Number of Registered Vehicles	5,000,167		5,281,816
Gasoline Fueled	4,812,768	96.25	5,024,088	95.12
- LDVs & LDTs	4,742,425	94.85	4,899,309	92.76
a. Pre-1983 Model Years	69,155	1.38	96,291	1.82
b. 1983-1995 Model Years	600,536	12.01	602,633	11.41
c. 1996-2006 Model Years	3,033,041	60.66	3,361,432	63.64
d. 2007+ Model Years	1,039,693	20.79	838,953	15.88
- Hybrids	32,474	0.65	27,107	0.51
- HDVs	70,343	1.41	124,779	2.36
a. Pre-1983 Model Years	10,025	0.20	13,065	0.28
b. 1983-2006 Model Years	50,461	1.01	94,433	1.79
c. 2007+ Model Years	9,857	0.20	17,281	0.33
Diesel Fueled	178,567	3.57	240,040	4.54
- LDVs & LDTs	61,592	1.23	72,189	1.37
- HDVs	116,975	2.34	167,851	3.18
Other Fuels	11,824	0.18	17,688	0.33
- LDVs & LDTs	7,869	0.16	12,569	0.24
- HDVs	963	0.02	5,119	0.10

Table II.B.2: Additional Statistics on New York State I/M Programs (Calendar Year 2008)

Category	NYMA		UPSTATE		TLC Taxis*
	Count	% of Total	Count	% of Total	Count	% of Total
Number of Registered Vehicles	4,702,839		5,388,476		15,048
Safety Inspection and Emission Tested Vehicles**	3,789,361		3,431,393		37,642
- Had OBD II Inspections	3,144,772	82.99%	3,431,393	100%	37,642	100.0%
a. Failed OBD II Initial Test	187,001	4.93%	199,189	5.80%	5,232	13.90%
b. Received Waiver	3,766		4,240		n/a
c. Waiver Rate	2.01%		2.13%
d. Unknown Final Disposition	16,580	0.43%	21,193	0.62%	69	0.46%
e. Passed OBD/Failed Gas Cap	873		552		40
f. Failed OBD/Failed Gas Cap	155		143		20
- Had NYTEST	644,589	17.01%
- Initial Test was a Transient	506,692	13.37%
- Initial Test was an Idle	137,897	3.64%
a. Failed the Initial Test	41,161	1.09%
b. Received Waiver	316
c. Waiver Rate	0.77%
d. Transient/Idle Switched	920	0.14%
e. Unknown Final Disposition	4,089	0.63%

* TLC vehicles are to be inspected three times per year with no provision for waiver.
** Including "change of ownership" vehicles (where safety inspection and emission test is required).

a.) Problems Identified During the Reporting Period

During calendar year 2008, DEC/DMV identified an error with the deployment of the State's intended RED.XML file, or "readiness file." The readiness file allows New York State program administrators to set the general (or default) readiness evaluation criteria and to identify specific vehicles that require alternate testing criteria.

The New York State RED.XML file is based on EPA's recommended guidance pertaining to the readiness evaluation, "Performing Onboard Diagnostic System Checks as Part of a Vehicle Inspection and Maintenance Program (EPA420-R-01-015, June 2001)." With respect to the readiness evaluation, most model year 1996 to 2000 vehicles are allowed to have up to two non-continuous monitors reported as Not Ready, and the vehicle will still pass the NYVIP readiness evaluation. Similarly, most model year 2001 and newer vehicles are allowed to have one non-continuous monitor reported as Not Ready, and the vehicle will still pass the NYVIP readiness evaluation. The NYVIP RED.XML file also has the flexibility to allow for alternate readiness criteria for vehicle specific applications, such as those vehicles listed within EPA's Appendix D guidance.

New York State Motor Vehicle Inspection regulation under 15 NYCRR Part 79 provides for a less than 2 model year "new vehicle" emissions testing exemption. So beginning on January 1, 2007, MY 2005 vehicles with two or more non-continuous monitors reported as Not Ready were supposed to fail the NYVIP OBD II inspection. Similarly, beginning on January 1, 2008, MY 2006 vehicles with two or more non-continuous monitors reported as Not Ready were supposed to fail the NYVIP OBD II inspection.

b.) Ways to Solve the Problems

In March of 2008, data integrity checks by DEC/DMV identified a pass/fail concern pertaining to model year 2006 Chevrolet Cobalt and Saturn Ion. Upon review by the Program Manager, SGS Testcom, the active RED.XML file was found to be missing default MY2005 and MY2006 entries. Approximately 11,900 vehicles were identified as having received a "false pass" beginning in January 2007. A false pass is defined as a completed inspection reported as a "pass" when the vehicle should have failed for at least one of the NYVIP OBD II failure criteria. Data analysis later determined that false pass inspections occurred between January 2, 2007 and March 16, 2008 and from June 2, 2008 to June 30, 2008

Prior to the identification of the RED.XML file issue, the validity of the five intermediate and final overall NYVIP pass/fail determinations were evaluated during acceptance testing of proposed NYVIP software. This testing is completed independently by the Program Manager, DEC, and DMV, and is followed by limited in-station beta testing before software is approved and released to all NYVIP stations. The RED.XML issue, however, involved the application of XML file changes after software approval. An expanded data analysis check was needed to detect the occurrence of invalid pass or fail inspection results after software approval. As a result, DEC has adopted a series of internal performance measures to validate the overall NYVIP OBD II Pass/Fail (P/F) result using the intermediate P/F results as reported by the vehicle (i.e., communication success, monitor status, MIL command, diagnostic trouble codes) and the visual MIL checks. In addition to the DEC checks, SGS Testcom has adopted additional quality assurance reporting to be included within the established monthly report requirements.

2. NYTEST Program

Summary statistics related to NYMA NYTEST results are provided in Appendix C, with Tables C-1-a to C-1-c for the transient tests, and Tables C-2-a to C-2-d for the idle tests.

For the pre-1996 model year fleet, 389,986 LDVs and 116,706 LDTs (13.37% of the total emissions tested NYMA fleet) received a NYTEST transient test as their initial emissions test. Observed failure rates were 7.62% for the LDVs and 6.22% for the LDTs, with waiver rates of 0.80% and 0.81%, respectively. The overall average emission reductions were: 0.92/15.20/1.37 g/mi for HC/CO/NOx for the LDV fleet, and 1.34/19.53/1.92 g/mi for HC/CO/NOx for the LDT fleet.

137,897 vehicles received a NYTEST idle test as their initial emissions test as follows: 24,452 LDVs, 31,815 LDTs, and 81,630 HDVs (3.64% of the total emissions tested NYMA fleet). The failure rates were 4.49% for the LDVs, 4.05% for the LDTs, and 2.21% for the HDVs, with corresponding waiver rates of 0.0%, 0.47%, and 0.44%, respectively. The overall average emission reductions were: 239ppm HC and 1.43% CO for the LDVs, 318ppm HC and 1.47% CO for the LDTs, and 453ppm HC and 1.73% CO for the HDVs.

An increase in the number of HDVs receiving an idle test is noted when compared to the 2007 annual report. This increase is attributed to a new DEC data QA check. The NYTEST records for the affected vehicles indicate that most were light duty trucks (LDTs) or light duty vehicles (LDVs) (GVWR less than 8,501 lbs) with model years 1996 and newer. However, a screening using VIN ASSIST, revealed that these vehicles had an actual GVWR greater than 8500 lbs. The DEC reference table was adjusted, hence resulting in an increase in HDVs. Note that NYVIP inspection software includes a GVWR validation routine when vehicle information is entered, but the older NYTEST inspection software does not include a similar procedure.

3. Testing Facilities

Since the State of New York I/M Program has 10,514 testing facilities, it is not practical to generate the required statistics by test station on the initial test volume and initial test failure rate. Instead, Appendix D displays the initial test volume and failure rate statistics by vehicle model year and vehicle type (LDVs and LDTs) from all the testing facilities in each county¹. Table D-1 includes a total of 12 tables (pages D-1-1 to D-1-12) with statistics from the two different types of emissions tests (OBD II inspections, and NYTEST transient/idle tests) for the nine NYMA counties, two Upstate counties (Orange and Putnam where a few NYTEST facilities are licensed), and "Others²". Table D-2 (pages D-2-1 to D-2-9) includes the OBD II inspection statistics from the remaining 51 Upstate counties.

In NYMA, Suffolk and Nassau Counties had the largest number of testing facilities (815 from Suffolk, 779 from Nassau). For OBD II inspections, the two counties with the highest LDV initial test volumes were Suffolk (382,819 inspections) and Nassau (371,267 inspections). The two counties with the highest LDT initial test volumes were Suffolk (296,142 inspections) and Nassau (236,162 inspections). Kings had the highest OBD II inspection failure rates for both LDVs (7.14%) and LDTs (7.60%), Queens had the second highest failure rates for LDVs (6.19%) and New York County had the second highest failure rates for LDTs (6.83%).

For transient tests, Suffolk County had the highest initial test volumes for both LDVs (77,877 tests) and LDTs (33,210 tests). Except for the three counties (Orange, Putnam, and Others) which had very low initial test volumes, Rockland had the highest failure rate (9.28%) for LDVs and Westchester had the highest failure rate (7.78%) for LDTs.

For idle tests, Suffolk had the highest initial test volumes for LDVs (4,701 tests) and Queens had the highest for LDTs (5,883 tests). The counties having the highest idle test failure rates were Nassau (5.07%) for the LDVs and New York County (5.48%) for the LDTs.

For Upstate, Erie County had the largest number of testing facilities (870 facilities), as well as the highest LDV (244,688 inspections) and LDT (186,065 inspections) initial test volumes. The top three LDV OBD II inspection failure rates were: Franklin (8.03%), Sullivan (7.78%), and Orleans (7.27%) Counties, while the top three LDT failure rates were: Greene (7.43%), Sullivan (7.26%), and Orleans (7.22%) Counties.

C. Quality Assurance Report

Considerable progress continues to be made in NYSDMV quality assurance program. 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.

1. NYMA

The results of the various NYSDMV compliance efforts in theNYMA I/M program are summarized in Table II.C.1.

Table II.C.1: Statistics on NYSDMV Quality Assurance Program - NYMA
(Calendar Year 2008)

Category	Overt Audit	Covert Audit	Surveillance	Desk Audit	Complaints	Total
Pending	0	0	0	0	0	0
No Action	6,020	1,641	0	28	107	7,796
Warnings Issued	1,099	665	0	3	79	1,846
Hearings Held	71	414	9	193	216	903
Total Cases	7,190	2,720	9	224	402	10,545
Hearing Results:
- No Action	6	3		4	2	15
- Revocation	2	14		8	5	29
- Suspension	6	39		22	24	91
- Civil Penalty	90	389		166	274	919
Mainframe Case	97	418		177	299	991
Fines Received	$64,195	$255,850		$105,395	$193,755	$619,195
Refunds	$0	$0		$0	$0	$0
Days Suspended	60	1,380		838	1,089	3,367

From a total of 3,592 certified inspection stations and 15,295 licensed inspectors in NYMA, a total of 7,190overt audits were performed³. As a result of hearings related to overt audits, 6 inspection stations were suspended for a total number of 60 days.

A total of 17 covert vehicles and 19 covert auditors were made available for use in the undercover audit work in NYMA. A total of 2,720 covert audits and 9 inspection station surveillance audits were performed. As a result of hearings related to covert and surveillance audits, 39 inspection stations were suspended for a total of 1,380 days.

Of the covert audits that were completed, 1,557 vehicles were set to fail on one component of the emissions tests and 2 were set to fail for two or more components. Components set to fail included: 97 for gas caps, 211 for DTC's,707 for OBD MIL not working, 388 for OBD monitors, 158 for non-communication, and numerous for safety inspection related failures. From these, 2,270 inspection stations correctly inspected the vehicle, 330 inspection stations false passed the vehicles, and 139 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. In calendar year 2008, a total of 224 desk audits were performed, with 22 inspection stations suspended for a total of 1,089 days.

Consumer complaints are also being used as a source of enforcement action. Based on a total of 402 cases, 24 inspection stations were suspended for a total of 3,367 days.

2. Upstate

Statistics on various elements in the Upstate quality assurance program are presented in Table II.C.2.

Table II.C.2: Statistics on NYSDMV Quality Assurance Program - Upstate
(Calendar Year 2008)

Category	Overt Audit	Covert Audit	Surveillance	Desk Audit	Complaints	Total
Pending	0	0	0	0	0	0
No Action	6,823	608	2	63	91	7,587
Warnings Issued	893	462	0	25	130	1,510
Hearings Held	75	134	1	2	218	430
Total Cases	7,791	1,204	3	90	439	9,527
Hearing Results:
- No Action	2	0		0	5	7
- Revocation	6	7		0	9	22
- Suspension	6	19		0	10	35
- Civil Penalty	67	97		2	194	360
Mainframe Case	77	107		2	203	389
Fines Received	$30,025	$38,915		$350	$69,940	$139,230
Refunds	$0	$0		$0	$0	$0
Days Suspended	278	858		0	139	1,275

There were 6,298 licensed inspection stations and 23,479 certified inspectors conducting safety and OBD II inspections in the Upstate area. A total of 7,791 overt audits were performed in calendar year 2008. As a result of hearings related to overt audits, 6inspection stations were suspended for a total of 278 days.

A total of 16 covert vehicles and 30 covert auditors were available for the undercover audit work for Upstate. A total of 1,204 covert audits were performed. From hearings related to covert audits, 19 inspection stations were suspended for a total of 858days.

Of the covert audits that were completed, 134 vehicles were set to fail on one component of the emissions tests. Components set to fail included: 10 for gas caps, 39 for OBD MIL On, 46 for OBD monitors,37 for DTC's, 2 for OBD non-communications, and numerous for safety inspection related failures. From these, 1,038 inspection stations correctly inspected the vehicles, 64 inspection stations false passed the vehicles, and 102 inspection stations did not do the inspections.

In calendar year 2008, 90 desk audits were performed for the Upstate program resulting in 2 civil penalties imposed. A total of 439 cases of consumer complaints were received. As a result of hearings related to consumer complaints, 10 inspection stations were suspended for a total of 139 days.

In addition, the use of administrative stops in NYSDMV 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 NYTEST file-based equipment audits. Administrative stops are placed on the facility file to prevent the inspection stations from performing any more inspections and/or 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 calendar year 2008, a total of 1,034 administrative stops were issued for NYMA and 328 for Upstate.

Table II.C.3: Statistics on NYSDMV Administrative Stops
(Calendar Year 2008)

Reason for Issuing Administrative Stops	NYMA	Upstate
Failure to Communicate with NYSDMV or Data Manager	0	0
Out of Business	216	913
Failed NYSDEC NYTEST Equipment Audit	87	0
Improper Idle Testing (i.e., Bypass Transient)	0	n/a
Missing or Inoperative Equipment	454	12
Bad Checks	46	34
Gas Cap Test Violation	0	0
Management Review	12	14
Failure to Pay Civil Penalties	120	46
Repair Shop Registration Suspended	0	0
Undelivered/Returned Mail	2	0
Suspended Pending Hearing	5	5
Failure to Have an Approved Computerized Vehicle Inspection System (with Required Hardware/Software)	90	0
No Communication from Facility	0	0
Total	1,034	328

D. Quality Control Report

The NYTEST equipment utilizes three main components to analyze and evaluate vehicle exhaust emissions: Dynamometer, VMAS^TM 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.

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 calendar year 2008, NYSDEC visited 1,818 inspection stations and conducted a total of 1,738 audits. Table II.D summarizes the NYTEST equipment audit statistics. Many inspection stations failed the equipment audits for more than one reason. Accordingly, the total of the specific reasons for a failed audit is more than 100% of the total stations that failed an audit. The top three reasons for audit failure were: leak check failure, gas audit failure, and use of unacceptable calibration gas.

Some stations were again specifically selected for audits based on the reported performance data indicating potential problems: i.e., calibration records, low failure rate, high idle test percentage, high gas cap bypass rate, extremely high emissions readings, or stations that conducted high numbers of tests during a selected time frame. However, during calendar year 2008, a greater number of stations were audited as routine audits selected to ensure that all stations can expect to eventually be periodically audited.

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 would not necessarily lead to an administrative stop, since the majority of the audit failures were corrected within the required time frames. In calendar year 2008, a total of 603 failed NYTEST equipment audit cases were noted, as shown in Table II.D.

Table II.D: Statistics on NYSDEC Quality Control Program - NYTEST Equipment Audit
(Calendar Year 2008)

Category	Count	% of Total
Total Number of Inspection Stations	3,606
-- # of Inspection Stations Visited	1,818
Total Number of Audits Performed	1,738
- # of Stations Passed the Audit	1,135	65.30
- # of Stations Failed the Audit	603	34.70
a. Software Check	0	0.00
b. Gas Cap Tester	52	2.99
c. System Flow Check	38	2.19
d. Leak Check	339	19.51
e. On-Board Gas	62	3.57
f. Gas Audit	73	4.20
g. VMASTM Flow Check	50	2.88
h. Total Number of Shutdowns	87	5.01

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 the 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 NYSDEC in the form of calibration records. These records, as mentioned above, have also been used to target facilities for an NYTEST equipment audit. In calendar year 2008, a total of 192,530 calibration records were received and these calibration records were selectively reviewed as necessary by NYSDEC staff.

E. Enforcement Program Report

With mandatory annual safety inspections and emissions tests, stickers (for vehicles "passing" either NYTEST or NYVIP) are being accounted for electronically as well as generated directly by the inspection equipment (NYTEST) with a security font.

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 should not be coded as a HDV, or an applicable model year 1996+ LDV should receive an OBD II inspection. In addition, issues related to clean scanning and repair waivers are also being examined.

Another enforcement activity utilized by NYSDMV is based on the traffic tickets issued by law enforcement from multiple sources such as state, county and local courts. There were 161,127 traffic tickets issued to motorists in calendar year 2008 for having a V&T Law 306(b) violation (i.e., operating an un-inspected vehicle), 37,585 of them were issued in NYMA and 161,127 in Upstate.

1. NYMA

The high enhanced I/M program has provided mandatory annual safety inspections with emission tests for 78.36% of the entire LD fleet, with the remaining 21.64% exempt due to vehicles' model year or fuel. In calendar year 2008, a total 5,000,441 safety/emissions and safety only inspection stickers were issued for NYMA.

2. Upstate

For the low enhanced I/M program in Upstate, 80.20% of the LD fleet was required to have an emission inspection. A total 5,251,683 inspection stickers (for safety inspections and emissions tests) were issued.

NYSDMV implemented a registration-based denial enforcement program for Upstate starting with dealer transactions in December 2006. Enforcement for the registration renewal population was phased-in gradually starting with the September 2007 renewals.

NYSDMV implemented a phased-in registration-based denial enforcement program⁴ in 2001, with a full implementation in late 2002. The summary of this month-by-month registration denial enforcement program statistics is provided in Table II.E.

Table II.E: Statistics on NYSDMV
Registration Denial Enforcement Program
(Calendar Year 2008)

Month	NYMA			Upstate
	Invitations	Denials	% Denied	Invitations	Denials	% Denied
January	153,924	5,226	3.40	149,689	4,098	2.74
February	183,115	4,543	2.48	176,667	3,317	1.88
March	186,350	4,960	2.66	208,864	2,849	1.36
April	292,242	5,128	1.75	503,746	3,455	0.69
May	191,662	5,066	2.64	225,666	2,535	1.12
June	193,383	4,941	2.56	219,686	2,055	0.94
July	169,801	5,256	3.10	213,195	1,441	0.68
August	212,733	4,810	2.26	287,928	994	0.35
September	206,884	4,824	2.33	249,790	1,069	0.43
October	177,170	4,703	2.65	195,184	1,150	0.59
November	159,324	4,876	3.06	187,720	1,124	0.60
December	159,324	3,538	1.21	761,303	1,606	0.21
Total	2,417,926	57,871	2.39	3,379,438	25,693	0.76

Due to a change in NYSDMV reporting, the number of denial warnings issued was not available at this time. As shown in Table II.E, of those motorists receiving warning in calendar year 2008, 57,871 still attempted to renew their registration without correcting the problem hence their renewals were denied.

NYSDMV inspected 10,144 stickers from vehicles statewide. Based on the inspection sticker compliance surveys, an overall compliance rate of 97.01% was found: 17 had no stickers, 11 had the wrong stickers, 158 with stickers expired for 60 days or less, and 117 with stickers expired more than 60 days.

III. BIENNIAL REPORTS

Changes made during calendar years 2007 and 2008 that affect the program design, funding, personnel levels, procedures, regulations, and legal authorities are summarized in the following three sections:

- OBD II inspection program for NYMA and Upstate
- TLC OBD II inspection program
- NYTEST program in NYMA

A. OBD II Inspection Program for NYMA and Upstate

The OBD II inspection program (or NYVIP) was fully implemented first for the Upstate region since December 1, 2004. All applicable 1996+ model year LD fleet in 2007 (3,212,615 vehicles) as well as in 2008 (3,431,393 vehicles) were OBD inspected.

NYVIP expanded into NYMA, and mandatory inspections were required beginning on May 5, 2005. All applicable 1996+ model year light duty vehicles in 2007 (1,741,499 LDVs and 1,199,296 LDTs) and in 2008 (1,852,124 LDVs and 1,292,648 LDTs) were OBD inspected, using the same OBD II software statewide.

NYVIP inspection software was revised during the reporting period. Version 0410 had been in place since November 2007. Version 0424 replaced Version 0410 upon its release in May 2008.

1. Summary of NYVIP Software Changes

Two versions of NYVIP software were in use during calendar year 2007. Version 0407 was approved for release in December 2006, and version 0410 was approved for release in November 2007.

Two versions of NYVIP software were in use during calendar year 2008. Version 0410 was approved for release in November 2007, and version 0424 was approved for release in May 2008. All 9,824 NYVIP stations were updated to the current version 0424 in July 2008. The following lists summarize the changes accomplished by each software version.

a. Software Version 0407

• Make List - Most motorcycle, trailer, and truck "Makes" were included within the inspection software. The motorcycle and trailer makes will only appear when the inspector selects that type of inspection.
• VIN Entry - When the inspector scans a DMV 1D bar code (located on the registration sticker), he/she is prompted to scan the VIN 1D bar code (located on the vehicle's dashboard or door jamb) or to enter the VIN manually. This sequence ensures that the inspection is credited to the proper vehicle.
• VIN Validation - NYVIP software will complete a VIN validation routine. Validated VINs will also be compared it to weight table to determine if the gross vehicle weight is less than 8,500 lbs (GVWR). If the decoded VIN can be matched to the weight table, NYVIP software will use a GVWR of less than 8,500 lbs to determine the emission test type (i.e., OBDII inspection). If a match cannot be made, the NYVIP software will allow the inspector to determine the appropriate weight code for the inspection. This routine will eliminate existing "warning messages," reduce the inspection time, and significantly improve the determination of inspection weight (i.e., GVWR for validated VINs).
• Entry of Emission Repair Information - The inspector will be limited to entering emission repairs during re-inspections to reduce confusion and to avoid accidentally entering the same repairs more than once.
• Emission Repair Confirmation Screen - The NYVIP inspection sequence will include a confirmation screen during the entry of emission repair costs to provide the inspector an opportunity to correct an incorrect entry.
• Safety Inspection, Service Brake Screens - NYVIP messaging was improved during the completion of the safety inspection related to brakes.
• Confirmation Screen to Avoid Inappropriate Unit Lock-out - Inspectors have erroneously selected the NYVIP non-communication failure reason, "NYVIP connector being broken or missing" when the NYVIP connector was actually OK but the workstation could not communicate with the vehicle. This selection caused the NYVIP unit to lock out, and the inspector was then required to contact the Help Desk to remove an errant lock-out. To minimize this from happening, a new confirmation screen has been added to assist the inspector in making the correct selection.
• Scan tool Interface - NYVIP software was revised to allow use of the Scan tool interface for the selection of "Y" (Yes) or "N" (No) for repair-related emission test waivers.
• Enhanced Messaging Related to Certificates - NYVIP will display revised messages to assist the inspector when issuing an inspection certificate to a trailer or to a vehicle receiving an inspection waiver.
• Daily Report - NYVIP will automatically print the Daily Report.
• Notice of a State Message -When a NYVIP message is sent to the station, the "Mailbox" icon will flash. The inspector will be able to use the mouse to open the State Message Menu.
• Safety and Emission Control Device Criteria - Safety and Emission Control Device inspection criteria were added to the Inspection Menu.
• Sticker Inventory Confirmation - The NYVIP software was revised to require inspector confirmation when inspection certificates (i.e., stickers) are entered into inventory. The inspector will select the type of stickers to be entered, and NYVIP will request the first sticker in each book to be scanned to confirm the correct stickers are being entered. If the book being scanned matches the selection made by the inspector, NYVIP will display a message indicating the stickers were entered into inventory
• Duplicate Printing - When reprinting an inspection receipt for a vehicle that received an emissions waiver, NYVIP will print both the Inspection Receipt and the Waiver form. Both documents will indicate that they are duplicates.
• End of Year Sticker Report - NYVIP will be print an End of Year Sticker Inventory Report that will list all unused inspection certificates, stickers noted as damaged or stolen, and what stickers can be returned to DMV for credit.

b. Software Version 0410

• Scan Tool Interface - The NYVIP scan tool interface was updated.

c. Software Version 0424

• Sticker Ordering from the Sticker Management Menu - Inspection facilities are now be able to order inspection stickers from DMV through their NYVIP unit.
• Daily Report - The Daily Report was revised to include a reminder to renew the facility inspection license. If a facility license is going to expire within 30 days and has not been renewed (i.e., a renewed license has not been scanned into the NYVIP unit), the Daily Report will include the following message. "Your Inspection Station license will expire at the end of the month. Please scan the barcode on the renewed license into your NYVIP unit. If you have not renewed your license, for faster service renew on-line at nysdmv.com."
• Sticker Inventory Report - Each section of the Sticker Inventory Report and End of Year Report include a total for that section (i.e., Safety Certificates Issued, Safety Certificates Damaged, Stolen, etc.).
• State Message Menu - All State messages are now listed on the menu with the date and time. Messages will also be listed by title to make it easier to locate a message on the menu at a later date.
• Safety Criteria - Some listings were separated for clarity. (79.22: Light Duty Trailers, 79.22a: Hitch System, 79.23: Medium Duty Vehicles, 79.23a: Brake System, 79.27: Heavy Vehicle Inspection, 79.27a: Tires, 79.28: Inspection of Motorcycles, 79.28a: Brakes).
• Computer Based Training (CBT) Menu - Selection #2 Online Help has been changed to Important Information. A listing of DMV website addresses for DMV forms to make it easier has also been added.
• Out of Business Selection - If a station selects the option "Out of Business" from the station menu, the NYVIP unit will print the Sticker Inventory Report, Station Performance Report and Analyzer Status Report for previous 3-month period. A Daily Report will also be printed for date of the last completed inspection.
• Vehicle Inspection Receipt - The border on the sides of the receipt have been eliminated to shorten print time and to reduce ink use. If applicable, 10-day extensions will be printed in bold black text. The following statement will also be printed in bold black text above a 10-day extension, "You must display this notice in the lower left corner of the vehicle's windshield." Also, receipts issued for motorcycle inspections will now indicate, "Brakes Inspected" instead of "Wheels Removed."
• Make Table - The following vehicle "Makes" have been added, MINI, Smart, Hummer, and Scion.
• Heavy Duty (HD) Trailer Inspections - In accordance with NYSDMV regulations and the NYVIP inspection fee chart, an inspection station with a class 2A license can inspect HD vehicles and trailers of 18,000 lbs and greater, while a class 2B license is required to inspect semi-trailers 18,000 lbs and greater. During a HD trailer inspection, a NYVIP message will ask the question, "Is this a Semi Trailer?" If the inspector replies "yes," the station must have a class 2B license and the inspector must have a Group 2 license in order for the inspection to be performed.
• Safety and Emission Control Device (ECD) Computer Screens - The instructions on these screens, as related to pass/fail criteria, have been clarified.
• Brakes Inspected Screen - The option of "Road Tested" has been added for motorcycle inspections.
• Daily Report Prompt - Previously, a prompt appeared at start-up asking the inspector if he/she would like to print yesterday's Daily Report. This prompt has been eliminated, as the Daily Report automatically prints at the end of the day.

2. Comparison of Failure and Waiver Rates

Comparisons of OBD II inspection failure rates by vehicle model year and vehicle type are displayed in Graphs 3 and 4. As can be seen, OBD II failure rates from calendar year 2007 were slightly higher than those from calendar year 2008. Rates from NYMA were slightly higher than those from Upstate.

Comparisons of OBDII waiver rates by vehicle model year and vehicle type are displayed in Graphs 5 and 6. The waiver rates are significantly higher in calendar year 2007 than in calendar year 2008 except for the model years 2003 and newer where the waiver rates are lower overall.

B. TLC OBD II Inspection Program

TLC's OBD II inspection program commenced on December 8, 2003. In 2007, the entire fleet of 14,674 yellow medallions (12,488 LDVs and 2,186 LDTs) had 37,442 OBD II inspections at TLC's Woodside inspection facility. This program continued to be operational in 2008, with 37,642 OBD II inspection results from 15,048 taxi cabs (11,917 LDVs, and 3,131 LDTs). Data were submitted to NYSDEC on a monthly basis and to NYSDMV (in an approved format) regularly as well. Comparisons of OBD II inspection failure rates by vehicle model year and vehicle type are displayed in Graph 7.

C. NYTEST Program in NYMA

Since May 5, 2005, OBD II inspections have become the required emissions tests for all model years 1996+ LDVs and LDTs. Accordingly, a large reduction in the number of vehicles receiving NYTEST was expected. In fact, the NYTEST volume reduction is calculated to be 78.41% and continuing to increase. In calendar year 2007 a total of 728,314 vehicles received NYTEST from 3,889 testing facilities, whereas in calendar year 2008 NYTEST inspections were reduced to 644,589 vehicles from 3,606 testing facilities.

Comparisons of NYTEST (transient and idle) failure rates by vehicle model year for LDVs and LDTs are displayed in Graphs 8, 9, and 10.

Comparisons of NYTEST (transient and idle) waiver rates by vehicle model year for LDVs and LDTs are displayed in Graphs 11, 12, and 13.

D. Vehicle Registrations vs. Emissions Tests, CY 2008

The Departments compared vehicle registrations to vehicles receiving an emission test for both NYMA and the Upstate I/M area for CY 2008. The procedure followed is described further within Appendix E: Procedure to Sort Registration File and Matching Emissions Inspections which includes a reference to Appendix F: Registration Type Codes. In summary, the NYMA and Upstate I/M area were found to have a 96.8 compliance rate. Graphs 14 and 15 provide the "by model year" comparison for NYMA and the Upstate I/M area.

IV. CONCLUSIONS

During calendar year 2008, the State of New York continued to operate the OBD II inspection program for all model year 1996+ LD fleet vehicles registered in both the NYMA and Upstate I/M areas, and the NYTEST program for all 1983 to 1995 model year LD fleet vehicles as well as all 1983 to 2006 HDV fleet vehicles registered in NYMA. The TLC OBD II inspection program, which began on December 8, 2003, also continued to function through calendar year 2008 with various improvements.

More importantly, 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 Note that TLC data were not included in the Appendix D since the TLC data were all from one single testing facility.
² County "Others" includes NYTEST facilities with unknown NYMA designations and one inspection station located in Jersey City, New Jersey under the jurisdiction of Port Authority of New York and New Jersey.
³ 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.
⁴ 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.