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7 Evaluating Inspection and Maintenance Costs and Other Criteria
Pages 169-198

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From page 169...
... We discussed in Chapter 6 the impact of high repair costs on motorists' decisions to scrap vehicles earlier than they otherwise would. High repair or compliance costs can also cause motorists or technicians to avoid an I/M program by driving their vehicles without legal registration or by tampering with the pollution-controT equipment.
From page 170...
... The full social cost of an I/M program is the measure of costs that should be used to examine cost-effective improvements in I/M and to compare I/M with alternative programs. It is important to note that activities in primarily one cost category vehicle repair actively achieve emissions reductions.]
From page 171...
... Cost of reinspection Fuel economy savings Some vehicles difficult to repair, requiring many trips to repair shops, increasing total cost of repair Average fuel economy effects of emissions repair appear to be small Program Costs of administering These costs are a small share of the administration program (aside from direct program; important to avoid double and oversight cost of testing) counting costs Enforcement costs Evaluation costs Enforcement efforts important to achieve emissions reductions; enforcement likely to affect compliance, but no research has been done on the magnitude of this link Thorough evaluation can be expensive; public-goods aspect of evaluation (evaluation in one state can provide evidence for other programs)
From page 172...
... Testing or inspection costs differ across I/M program types. Costs tend to be higher in decentralized programs than in centralized programs, primarily because of economies of scale in testing and because test fees for decentralized programs are in some instances market-~iven (e.g., in the California and Pennsylvania I/M programs)
From page 173...
... found that over two-thirds of the total costs go toward the inspection process. These costs include test costs (described above)
From page 174...
... 2000. Repair Costs Laboratory Studies of Repair Costs Several early studies on the cost of performing emissions repairs were done under controlled laboratory settings where a relatively small number of vehicles were repaired and tested by highly trained technicians.
From page 175...
... aAll emissions measurements were made with the Federal Test Procedure, except for Arizona I/M and the Orange County studies, which used the IM240 test, and California IMRC, which used the Acceleration Simulation Mode test. bData set of vehicles repaired at EPA labs and used to estimate changes in MC/CO emissions resulting from repairs (EPA 1992b)
From page 176...
... . Figure 7-2 shows little relationship between repair costs and net emissions reductions in the California I/M pilot study.
From page 177...
... Some of these repairs, such as those to sensors, will only affect the monitoring capability ofthe system and will not directly reduce emissions. In-Program Studies of Repair Costs Recently, data have been collected from ongoing I/M programs on the actual costs of repair for each round of I/M testing.
From page 178...
... FIGURE 7-2 Net emissions reductions versus repair costs for vehicles repaired in the California I/M pilot study. currently require owners of all repaired vehicles to report the repairs and the cost of repair.
From page 179...
... The average repair costs from the Orange County study are the highest ofthose shown in this table, inpartbecause the vehicles repaired had a repair cost limit equal to the vehicles' blue book values. Owners are likely to want to pay the minimal amount necessary to do what it takes to allow their vehicle to pass the test, which is reflected in average costs of repairs for in-program studies.
From page 180...
... This figure includes all costs of repair. Repair costs were estimated according to Harrington et al.
From page 181...
... In CaTifornia's decentralized program, operation costs are over half of the Smog Check budget (TMRC 2000~. Enforcement costs include the costs of monitonug the performance of testing facilities through overt and covert audits as well as costs associated with enforcing program requirements on noncompliance motonsts.
From page 182...
... The Arizona results also show that the anticipated repair costs differ substantially by age of vehicle, pnmarilybecause the probability offailure increases as vehicles age. The first two columns of Table 7-3 show the probability of failure and the average cost of repair by mode!
From page 183...
... (2) Probability Average Costs Vehicle Will of Repair for Vehicles Model Fail Initial Failing Vehicles ($/ vehicle)
From page 184...
... Politically, it has been difficult to enforce a regulation that appears to have such a regressive incidence. States have responded by allowing waivers for vehicle owners who have paid up to some repair cost minimum.
From page 185...
... These estimates can be used to compare the average costs of AM programs with alternative programs or to compare the costs of different program elements. As with evaluating emissions reductions, the baseline to which a new program is being compared is critical for cost-effectiveness calculations.
From page 186...
... Weighting is important for cost-effectiveness analysis, and weights are likely to vary across regions. Estimates of Program Cost-Effectiveness Cost-effectiveness of an entire I/M program canbe estimated by dividing the costs ofthe program by the weighted emissions reductions relative to some baseline.
From page 187...
... also examined the impact oftightening NOX cutpoints on the emissions reductions from the Californ~a Smog Check program. Additional study of cost-effectiveness oftightening cutpoints needs to be done before cutpoints are tightened beyond current levels.
From page 188...
... For a given level of emissions reductions, remote sensing resulted in lower inspection and driver costs and lower vehicle-repair costs than universal periodic testing. The study also found that if periodic I/M is in place, remote sensing between I/M tests improves overall cost-effectiveness of the program.
From page 189...
... Decentralized programs have come under particular scrutiny because, it is argued, they present many opportunities for testing fraud. Hubbard ( 1998)
From page 190...
... Motorists therefore shop around to find stations most likely to respond to incentives. Monitonng and enforcement costs are likely to be higher in a decentralized program with thousands oftest stations, though testing fraud has been reported in all program types.
From page 191...
... Counterfeit and stolen stickers are another problem. Legitimate stickers mustbe produced and distnbuted and carefi~ly handled to prevent unauthorized distribution.
From page 192...
... Selection of stations for covert audits is based on information indicating abnormal operation or the time since the last audit. Quality Assurance Additional safeguards are needed to ensure motorist compliance.
From page 193...
... For example, if diesel vehicles are not tested, vehicle owners should not be allowed to decIare that the vehicle is diesel powered without some proof or verification. Another way to avoid annual testing is to transfer the title ofthe vehicle or, in other words, to sell the vehicle.
From page 194...
... Tracking the number of overt and covert inspections and the number of enforcement actions taken against stations can provide evidence of the level of fraud occurring in a program and can target test stations for covert audits. PUBLIC ACCEPTANCE AND POLITICAL FEASIBILITY OF I/M AND PUBLIC AWARENESS OF AIR POLLUTION Vehicle emissions I/M programs are a comparatively burdensome environmental mandate for the public.
From page 195...
... FUTURE TRENDS IN VEHICLE TECHNOLOGY THAT AFFECT I/M PROGRAM EVALUATION Automobile manufacturers have made vast improvements in vehicle technology over the past 30 years. Laws imposed by federal and local governments to reduce emissions were often the motivating factor for many ofthese technological advances.
From page 196...
... Before OBDIT, evaluating the emissions-reduction benefits of vehicle testing was based on the principle of A - B = C, where A is the average fleet emissions before vehicle inspection, B is the average fleet emissions after failed vehicles are repaired and subsequently have reduced emissions, and Cis the net benefit ofthe repair and the overall reduced fleet emissions. The principle of OBDIT is to prevent A from including vehicles with emissions much higher then the rest ofthe fleet.
From page 197...
... Costs affect the performance of an I/M program because they can affect the behavior of vehicle owners and technicians in response to the program and therefore affect the emissions reductions achieved by the program. Considering costs is also important for determining how an I/M program can be designed or improved or, more broadly, for determining whether emissions-reduction efforts are best directed at I/M or alternative ways of reducing emissions.
From page 198...
... · Not only do we know little about the cost and emissions impact of current programs, we know even less about alternative enforcement efforts. How much difference do enforcement efforts, such as auditing repair-facility performance or intermittent testing with remote sensors or roadside pullovers, have on emissions reductions from a program?


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