HomeMy WebLinkAbout06/20/2008 - Vehicle Inspection Program For Ozone Air Quality - Air Quality Advisory Board (2)
20 June 2008
Fort Collins City Council
City of Fort Collins
P.O. 580
Fort Collins, CO 80522
Subject: Vehicle inspection program for ozone air quality
We understand that the North Front Range MPO and the Regional Air Quality Council
are seeking input on the possibility of a vehicle inspection and maintenance [IM]
program for the North Front Range. The Fort Collins Air Quality Advisory Board is
pleased to have this opportunity to comment.
In summary, the Board recommends that there should be some form of IM program in
the Fort Collins area, and that the program should not be voluntary. The Board also
prefers that testing dollars stay within the local community if possible, and that the
testing program should reflect the rising cusp of technology as opposed to older, static
technology.
The options that were presented to us include
1. IM-240
2. OBD – On Board Diagnostics
3. Two Speed Idle Test
4. Remote Sensing Technology
Although we would have preferred to prefer to comment based on an understanding of
the detailed costs and benefits of each option, that information was not available to us.
Our highest preference, however, would generally go to the option that produces the
greatest emission reductions. In the event that the options are nearly equal, or equally
uncertain as to outcome, we offer these further comments.
On-Board Diagnostics
• Pros:
o Because it utilizes local automotive technicians, OBD enhances the direct
relationships between motorists and the technicians who keep their emission
control systems in good repair, while also recirculating testing dollars within
the local community.
o OBD is attractive because it is supported by an enormous investment in
emission control systems by the automotive manufacturers, and OBD is
evolving to greater effectiveness and precision.
• Cons:
o We are concerned about reports that OBD has a high rate of false passes with
respect to high emitting vehicles, i.e., the 10% of vehicles that cause 50% of
the emissions. It is hard to see how OBD could be effective if it missed a
significant number of high-emitters.
o Because OBD systems produce error codes at a very detailed level within the
engine system, we are concerned that OBD would cause motorists and
technicians to waste time and money on minutiae that do not contribute to
emission reduction. Therefore, an OBD program should address only those
error codes that have been shown to correlate to significant failure of the
emission control system.
IM-240
• Pros:
o Because IM-240 is already used in the Denver area, we like the idea that the
IM program would be consistent for all communities along the Front Range.
o IM-240 has a lengthy track record of success in Colorado, giving us the
most confident and accurate pollution-reduction estimates.
• Cons:
o Because IM-240 is centralized, and assuming that that the IM-240 contractor
is not a local company, testing dollars would leave the community rather than
be recalculated here.
o IM 240 is an older testing technology that is not expected to improve further.
We think this, in part, because most states have adopted OBD, so there is
insufficient customer base to support further improvement in IM-240
technology.
Thanks for the opportunity to comment. Please contact me if there is any question
regarding this recommendation of the Air Quality Advisory Board.
Sincerely yours,
Eric Levine, Chair
CC:
Suzette Mellette, North Front Range MPO
Ken Lloyd, Regional Air Quality Council