vetterdstr

I understand the the new smog laws went into Effect yesterday. Of course, I want more HP for my car. I need to be in compliance with the new strict rules of Smog too. What would be the most aggressive heads and cam package that I can run without changing the computer code? I need it to pass the new tests that will be conducted through the computer port as well as the tailpipe test too.

vetterdstr :cheers:

6Speeder

There are packages out there that perform well and don't need computer programming to run. Morgan Motorsports did one for me, with a 218/218, .561" 114 LSA cam. It makes great power with Hypertech PPIII tuning, I'll just reprogram back to stock for the smog test.
:cheers:

vetterdstr

6Speeder, thanks for responding and you do have good HP numbers! :) Have you removed the programming and tested your car with an Ease program/laptop to see if the car passes the initial testing with the Key off? I would think that your car would but I am wondering if you have done that or not?

This is going to be one of the types of tests that will be performed on our cars in order to have it pass smog. :(

Thanks in advance,
vetterdstr

0Sales@MVPAutoParts.com

OR you can also use a MAF translator to lean it out before taking the car in for inspection.

-Tuan

vetterdstr

Tuan, if it was just the tail pipe testing that was going to be conducted I would not have an issue with it. The new testing will be through your computer port on all of our cars. Every single car 96 and newer will be tested in this fashion. If it does not pass that initial test with all the areas completed. You will be rejected (which is worse than failing) from the testing. I need to know if anyone has actually been able to pass these tests and have a High HP Heads and Cam package on a C5.

vetterdstr

0Sales@MVPAutoParts.com

Hmmm....I haven't heard that here in TX, yet. Let's hope that it is going to be a "CA-thing" only. Thanks for the heads-up.

-Tuan

vetterdstr

As of yesterday... Its a nation wide thing.

vetterdstr

jbsblownc5

A friend of mine owns a repaire and smog shop. I tested my car there a few weeks ago and he said it blew clean. Take a cruise if you must steve!
JB

Stunt

Hmm, I just had my C5 inspected this morning in rural VA. I don't even have cats on the car and it passed with flying colors. Out here in the sticks, the inspection stations don't have any smog testing equipment, let alone a way to hookup to the computer.

FRPTech

vetterdstr,

Do you know what they look for when they "plug in"???

I would assume that as long as none of the emissions components or codes(i.e. air pump, o2s, etc) are are removed with cutom programming you could pass the basic plugin test. But, then again maybe I'm off base - Can anyone clarify???

FRPTech

Tiger Shark

In addition to codes, they'll look to see if any of your factory programming parameters have been altered, i.e. custom programming. If you have custom programming, you'll fail the new test.

That's what I was told.

Tiger Shark

p.s. as far as more stringent emissions sniffer tests go... they can't hold you to anything more stringent than what your car was originally required to meet. So, as long as your heads/cam meets your original sniffer test requirements, you're fine. Newer cars will/may need to meet tougher sniffer tests. It all depends on what model car you have and what emissions requirements it had to meet at the time it was produced.

The other part of the new law deals with your OBDII computer. It will now be checked to make sure it's unaltered from the factory programming.



[Modified by TargaC5, 12:18 PM 1/2/2002]

C5Longhorn

So this means anyone with computer programming is SOL unless they go back to stock? This could affect alot of people on this forum.

Tiger Shark

No :bs!

That's exactly correct. Unless you go back to stock programming for this computer test, you're going to fail. That means anyone with a Powerloader, custom computer, or custom programming done by a tuner will fail unless you can get someone to put it back to stock for the test.

Mike Morgan

Well, It has acutally been happenning in CA for the past two months.

All it is, is a hook up to the OBDII port to check for codes and to verify the VIN #.

I don't see how a smog tech could know that the programming has been modified, unless there is no VIN # stored in the computer.

If you have a SES light, then a quick PCM reset will clear all of them. Most custom PCM programming will address any potential codes from engine mods.

FRPTech

TargaC5,

Thanks for the info. However, I'd still like to see some clarification here...

I'm just not buying it! There are variations even on a stock program so what is being compared when they plug-in?
How about basic programming i.e. gear change or rev limiter which has nothing to do with emissions. Or even go a little further i.e. fuel maps, etc... These will vary from car to car... Or better yet, can't the custom programming be used to "fool" the test by showing static values for a given area????

I'm finding it hard to believe that smaller shops will be performing tests with equipment sophisticated enough to detect cutom programming.

Again, not arguing, just looking for clarification on the test procedure...

FRPTech

FRPTech

Woops! Mike Morgan got the info out before my last post.

Thanks Mike! - This makes more sense....

FRPTech

Tiger Shark

I heard it was more than that. Maybe not.

Anyway, here's the full text (repost of team-zr1's post concerning the same topic):

Setting you up to understand newest smog testing mandates
Performing Onboard Diagnostic System Checks as Part of a Vehicle Inspection and Maintenance Program

June 2001

Introduction

The Clean Air Act as amended in 1990 (CAA) requires the Environmental Protection Agency (EPA) to set guidelines for states to follow in designing and running vehicle inspection and maintenance (I/M) programs. As well as distinguishing between basic and enhanced I/M programs, these guidelines must clarify how states are to meet other minimum design requirements set by the CAA. One such requirement that applies to both basic and enhanced I/M programs is the performance of Onboard Diagnostic (OBD) system checks as part of the required, periodic inspection.

On November 5, 1992, EPA published the I/M rule to meet most of the above-referenced CAA requirements. At the time the I/M rule was promulgated, however, federal OBD certification standards had not been published. To address the CAA’s OBD-I/M requirement, EPA reserved sections in the 1992 rule, with the understanding that these reserved sections would be amended at some future date. Although the federal requirement to incorporate OBD into new vehicles began with the 1994 model year (MY), manufacturers were allowed to request waivers on vehicles for MY 1994-95, so full compliance was not required on all light-duty cars and trucks sold in this country until MY 1996. On August 6, 1996, EPA published amendments to the 1992 I/M rule establishing OBD-I/M requirements for I/M performance standards and I/M State Implementation Plans (SIPs). The 1996 amendments also specified data collection, analysis, and summary reporting requirements for the OBD-I/M testing element; established OBD test equipment requirements and the OBD test result reporting format; and identified those conditions that would result in an OBD-I/M pass, failure, or rejection. Lastly, the August 6, 1996 amendments revised 40 CFR part 85, subpart W to establish OBD-I/M as an official performance warranty short test under section 207(b) of the Act.

At the time the original OBD-I/M requirements were established, it was not practical to evaluate the real-world, in-use performance of OBD because the vehicles in question were still too new and the number of those vehicles in need of repair were too few to make pilot testing worthwhile. Therefore, in 1998, EPA further amended its OBD-I/M requirements to delay the date by which I/M programs must begin OBD testing to no later than January 1, 2001.


One of the primary reasons for delaying the deadline for beginning OBD-I/M testing was to give EPA time to evaluate the OBD check as an I/M program element and to give states time to prepare for implementation. In conducting its evaluation of OBD, however, EPA found that identifying and recruiting OBD-equipped vehicles in need of repair proved more difficult and time-consuming than originally anticipated. As a result, EPA has only recently completed the assessment of OBD-I/M effectiveness and implementation issues referenced in this guidance. During the course of this evaluation, however, it became clear that certain regulatory changes were needed to ensure the smooth implementation of OBD-I/M testing by the states.

In response to its findings on OBD effectiveness and its study of the various implementation issues associated with OBD-I/M testing, EPA has amended the OBD-I/M testing requirements by publishing a final rulemaking (FRM) in the Federal Register on April 5, 2001 . The goal of these amendments is to update and streamline requirements and to remove regulatory obstacles that may otherwise impede the effective implementation of OBD-I/M testing. Among other things, the revised requirements: 1) provide states several options for extending the current deadline for mandatory implementation of the OBD-I/M inspection beyond January 1, 2001; 2) clarify states’ options regarding the integration of OBD-I/M checks into existing I/M networks; 3) revise and simplify the current list of Diagnostic Trouble Codes (DTCs) that constitute the OBD-I/M failure criteria to include any DTC that leads to the dashboard Malfunction Indicator Light (MIL) being commanded on; and 4) provide for exemptions from specific readiness code rejection criteria on OBD-equipped vehicles based upon vehicle model year.

In addition to the above cited regulatory revisions, EPA believes it is important to respond to states’ requests to provide additional guidance on how to successfully implement OBD-I/M testing in an I/M program. EPA is therefore issuing this guidance at this time in response to those requests and to assist those states and local areas that are considering or planning early implementation of OBD checks as part of their I/M programs.


Scope of Guidance

This guidance incorporates several key recommendations made to EPA by the OBD Workgroup, which is part of the Mobile Source Technical Review Committee, established under the Federal Advisory Committee Act (FACA). This guidance was also developed by drawing from the experiences of several states that are currently performing some form of OBD-based inspection. As of this writing, ten states (New York, California , Colorado, Alaska, Illinois, Wisconsin, Vermont, Oregon, Maine, and Utah ) are performing some form of vehicle OBD system check and at least three other states (Indiana, New Hampshire, and Georgia) are actively moving towards early implementation of vehicle OBD system checks. Lastly, the development of this guidance was aided by comments received from stakeholders in response to an earlier, draft guidance released for public comment in December 2000


Vehicle OBD System Checks: Basic Requirements

Recommended Model Year Coverage

Although some variety of OBD system has been an option on certain vehicle models since the early 1980's, standardized OBD systems (also known as OBD II) were not introduced until MY 1994, and such systems did not appear on all new light-duty vehicles sold in this country until MY 1996. Therefore, for I/M purposes, EPA does not require that pre-1996 MY vehicles be subject to the OBD inspection discussed in this guidance. Furthermore, EPA does not recommend that such testing include MY 1994-95 vehicles because not all such vehicles are OBD-equipped and the availability to manufacturers of limited waivers from some OBD requirements makes determining which of these vehicles to test (and to what standards) administratively very difficult. Additionally, EPA’s MOBILE6 emission factor model will not provide emission reduction credit for the performance of OBD-I/M checks on pre-1996 MY vehicles.


EPA also does not recommend that vehicles older than MY 1994 be subjected to OBD-based I/M testing, even if it is determined that the vehicle is equipped with an OBD computer, and may even have a malfunction indicator light (MIL) illuminated. The reason we do not recommend performing an OBD-I/M scan on pre-1994 MY OBD-equipped vehicles is because such vehicles use an earlier, non-standardized generation of OBD system (also known as OBD I). Due to the lack of federal standards for OBD I systems, the systems themselves tend to be proprietary and may not be compatible with the standardized OBD II scanners that will be used in most I/M programs .


Elements of an OBD-I/M Check

An OBD-I/M check consists of two types of examination: A visual check of the dashboard display function and status (also known as the MIL and/or bulb check) and an electronic examination of the OBD computer itself. These two examinations, taken together, comprise the seven step procedure outlined below.

1) Initiate an official test by scanning or manually inputting the required vehicle and owner information into the reporting medium (i.e., PC-based electronic reporting system or manual test report).

1) Visually examine the instrument panel to determine if the MIL illuminates briefly when the ignition key is turned to the “key on, engine off” (KOEO) position. A brief period of illumination of the MIL at start-up is normal and helps confirm the bulb is in proper, operating condition. This portion of the test procedure is also known as the “bulb check.” Enter the results of the bulb check into the reporting medium.

3) Locate the vehicle’s data link connector (DLC) and plug a scan tool into the connector. While it is recommended that this step be performed with the ignition in the “off” position, this step can also be performed with the ignition running. Given the variety of locations manufacturers have chosen in practice, locating the DLC may well be the most time-consuming element of the inspection. We will discuss the issue of atypical DLC location elsewhere in this guidance.


4) Start the vehicle’s engine so that the vehicle is in the “key on, engine running” (KOER) condition . The MIL may illuminate and then extinguish during this phase. Continued illumination while the engine is running is cause for failure. Also, if the MIL illuminates during this phase but was not observed in step 2, the vehicle should not be failed for step 2.

5) With the scan tool in the “generic OBD” mode, follow the scan tool manufacturer’s instructions to determine:

· Vehicle readiness status

· MIL status (whether commanded on or off) , and

· Diagnostic Trouble Codes (DTCs) for those vehicles with MILs commanded on .

6) Record the results of the OBD inspection in the appropriate medium. Depending upon the design and feature requirements of the program, this may be an automated process.

7) Without clearing DTCs or readiness codes, turn off the vehicle ignition, and then disconnect the scan tool . Clearing codes – if such is necessary – should be reserved for the repair portion of the program (even though in test-and-repair programs, the same personnel may be engaged in both activities). These codes (and the associated “freeze-frame” data) are important for the performance of proper diagnostics prior to repair.


Although the above inspection elements are listed sequentially, current regulations do not specify the sequence that must be followed in performing the OBD-I/M inspection, and EPA sees no reason for applying a rigid sequence at this time. In some cases it may make more sense to conduct the visual portion of the inspection after performing the onboard computer scan. For example, a state choosing to perform both a traditional tailpipe test and the OBD-I/M check on OBD-equipped vehicles may choose to reduce the overall test time involved by conducting the OBD scan at the same time the other test is performed. EPA has found that a scan tool can be plugged into a still-running vehicle without producing erroneous readings. Therefore, we believe states should be allowed the flexibility to determine the optimum test sequence to meet their programmatic needs. However, EPA does caution that unforeseen problems may arise with some subset of the fleet due to changes in the sequence. EPA therefore asks that states consult with the Agency should they find unusual failure patterns among certain makes and models of vehicles in conjunction with the use of alternative test sequences.

For readers who prefer their information presented graphically, a flowchart of an acceptable OBD system check is included in Appendix E of this guidance document. It was developed by the Center for Automotive Science and Technology at Weber State University, and is consistent with EPA guidance.


Basis for Failure or Rejection

Unless otherwise noted in this guidance, a vehicle should be failed for any of the following five reasons, with the exception of the last (for which the appropriate action is rejection):

1) It is a 1996 or newer vehicle and the data link connector (DLC) is missing, has been tampered with, or is otherwise inoperable. (Action: Failure)

2) The MIL does not illuminate at all when the ignition key is turned to the KOEO position. The MIL should illuminate (on some vehicles, only for a brief period of time) when the ignition key is turned to the KOEO position. (Action: Failure)


3) If the MIL illuminates continuously or flashes after the engine has been started, even if no fault codes are present, since this could indicate a serial data link failure. (Action: Failure)

4) Any DTCs are present and the MIL status, as indicated by the scan tool, is commanded on, regardless of whether or not the MIL is actually illuminated. Do not fail the vehicle if DTCs are present and the MIL status, as indicated by the scan tool, is off, because such non-MIL-triggering DTCs are considered “pending” and frequently self clear without requiring repair of the vehicle. MIL command status must be determined with the engine running. (Action: Failure)

5) The number of OBD system monitors showing a “not ready” status exceeds the number allowed for the model year in question. (Action: Rejection)

Table 1 below lists the possible test outcomes in tabular form.

Table 1 – Possible OBD-I/M Outcomes
Vehicle Passes If: * Bulb check OK and * MIL not lit while engine running and* MIL not commanded on for any DTCs and * All required readiness codes are set
Vehicle Fails If: * Bulb check not OK and/or* MIL lit while engine running and/or* MIL commanded on for any DTC and/or* DLC missing, tampered, or inoperable
Vehicle Rejected If: * More unset readiness codes found than allowed based on MY and/or* DLC cannot be located or is inaccessible


I/M-Related DTCs

Until recently, Federal I/M regulations identified a subset of power train (or P-code) DTCs as being relevant for I/M purposes. If a vehicle was identified through an I/M program as having a MIL commanded on for one or more of those P-codes, then Federal regulations required that the vehicle fail the inspection. In an attempt to simplify these failure criteria – and to harmonize Federal requirements with California Air Resources Board (CARB) requirements – EPA amended this requirement as part of its April 5, 2001 rulemaking. Under the revised failure criteria, a vehicle shall now be failed for the presence of any DTC that results in the “Check Engine” MIL being commanded on.

In commenting on an earlier draft of this implementation guidance, several commenters raised concerns that EPA’s simplified failure criteria would result in vehicles being failed for non-emission related components or systems, such as the brakes or suspension. Although some vehicle onboard computers may monitor non-emission-related components and systems at the manufacturer’s discretion, Federal regulations require that the “Check Engine” MIL only be illuminated for emission-related malfunctions. Other dashboard lights may be illuminated to indicate the need for service of a non-emission-related component or system, but the presence of such lights does not constitute grounds for failing the OBD-I/M check. Furthermore, EPA has examined data from over 300,000 OBD-I/M checks performed in actual I/M lanes and has not found a single instance of the simplified failure criteria leading to the failure of a vehicle for a non-emission-related component or system.

EPA also wants to acknowledge that it is possible we may need to limit the criteria for failing OBD-equipped vehicles after such vehicles reach an as-yet undetermined age and/or mileage. The reason for considering this possibility stems from the fundamental difference between how OBD triggers repairs versus how traditional tailpipe tests trigger repairs. Traditional I/M tailpipe tests identify a vehicle as failing for a given pollutant through direct sampling of the exhaust plume. These tests vary in the degree to which they provide any additional information that can be used to target the component or system failure that has led to the high emission reading. In such programs, repair technicians have a fair degree of discretion when it comes to recommending repairs to address a given failure, although owners are protected from excessive economic hardship by the cost waiver option. OBD, on the other hand, identifies specific components and/or systems in need of repair or replacement. As a result, EPA foresees the possibility that some advanced-aged OBD-equipped vehicles could be failed for DTCs for which the only available repair option would cost substantially more than the fair market value of the vehicle itself. Under such a scenario, the waiver option does not offer much consumer protection, since such repairs tend to be all-or-nothing propositions. For example, a motorist faced with a transmission repair cannot reasonably opt to have the transmission “half fixed” to take advantage of the cost waiver option.


Part ii next




[Modified by TargaC5, 1:06 PM 1/2/2002]

Tiger Shark

(repost from team-zr1's post concerning the same topic)

Part II
Given the relative newness of OBD II, EPA has not been able to gather the data necessary to determine whether situations like the one above will actually happen in practice (though the Agency certainly plans to gather such data in the future). We do believe however that program requirements should be reasonable, and that the economic burdens of a program should be balanced by the environmental benefit likely to result from the imposition of those burdens. Therefore, we may revise our failure criteria at some future date, once data has been gathered and analyzed concerning the actual costs associated with repairing high mileage/age OBD-equipped vehicles across the full range of possible MIL-triggering DTCs.


Test Report

If a vehicle fails, the test report given to the motorist should include the status of the MIL illumination command and the alphanumeric fault code(s) listed along with the DTC definition(s) as specified per SAE J2012 and J1930. Only the fault codes leading to the inspection failure should be listed on the report given to the motorist. EPA makes this recommendation because it is possible that an OBD system may set DTCs without commanding a MIL to be illuminated. These DTCs usually reflect an intermittent condition which may or may not be a problem at the time of testing. If the condition does not recur within a certain number of trips, the code will eventually be cleared; if the condition does recur, the system may then determine that a MIL should be illuminated. Therefore, no DTCs should be printed on test reports for vehicles that pass the inspection. An owner who receives notice of these codes on the same sheet of paper with notification of passing the state inspection may become confused or desensitized to the importance of DTCs and the MIL. Lastly, unset readiness codes should also be listed on the report if the number of unset readiness codes exceeds the limit for which an exemption is allowed (i.e., if the outcome of the test is rejection based upon the presence of too many unset readiness codes). If the number of unset readiness codes falls below the limit for which an exemption is allowed (and the vehicle would otherwise pass the inspection) then no unset readiness codes should be listed on the test report provided to the motorist.


Readiness Status: Initial Test


The OBD system monitors the status of up to 11 emission control related subsystems by performing either continuous or periodic functional tests of specific components and vehicle conditions. The first three testing categories – misfire, fuel trim, and comprehensive components – are continuous, while the remaining eight only run after a certain set of conditions has been met. The algorithms for running these eight, periodic monitors are unique to each manufacturer and involve such things as ambient temperature as well as driving conditions. Most vehicles will have at least five of the eight remaining monitors (catalyst, evaporative system, oxygen sensor, heated oxygen sensor, and exhaust gas recirculation or EGR system) while the remaining three (air conditioning, secondary air, and heated catalyst) are not necessarily applicable to all vehicles. When a vehicle is scanned at an OBD-I/M test site, these monitors can appear as either “ready” (meaning the monitor in question has been evaluated), “not ready” (meaning the monitor has not yet been evaluated), or “not applicable” (meaning the vehicle is not equipped with the component monitor in question).

There are several reasons why a vehicle may arrive for testing without the required readiness codes set. These reasons include the following:

6) Failure to operate the vehicle under the conditions necessary to evaluate the monitor(s) in question;

7) A recent resetting of the OBD system due to battery disconnection or replacement, or routine maintenance immediately prior to testing ;

8) A unique, vehicle-specific OBD system failure;

9) An as-of-yet undefined system design anomaly; or

10) A fraudulent attempt to avoid I/M program requirements by clearing OBD codes just prior to OBD-I/M testing (by, for example, temporarily disconnecting the battery).

In addition to the above considerations, EPA has also found that a small number of vehicles may be flagged as “not ready” or “not supported” for one or more of the continuous monitors (i.e., misfire, fuel trim, and/or comprehensive components). This makes no sense because continuous monitors are designed to run continuously (as their name implies) and therefore should always be flagged as “ready.” In its investigation of this issue, EPA has determined that the problem is the result of incompatibility between the vehicle and scanner software and is not indicative of a fault with the vehicle’s OBD system. As a result of this discovery, EPA recommends that programs disregard these continuous monitors when establishing the readiness status of the vehicle. This exclusion is for readiness determination purposes only; a vehicle with a MIL commanded on for a continuous monitor based DTC should continue to be failed in compliance with the test procedure discussed earlier in this guidance. EPA is working with state programs and OBD software suppliers to address this issue and will issue revised guidance as warranted.


Because the presence of unset readiness codes among the non-continuous monitors could be a sign of attempted fraud, it is important that all OBD-equipped vehicles be checked to confirm that readiness codes have been set as one of the pre-requisites for a valid OBD-I/M inspection. Nevertheless, as described in the FRM, EPA also believes that the previous requirement regarding readiness codes (i.e., that a vehicle be rejected from further testing if any monitor is found to be “not ready”) was more rigorous than either necessary or practical. Therefore, as discussed under “Basis for Failure or Rejection” above, EPA has revised the readiness requirement so as to allow states to complete the testing process on MY 1996-2000 vehicles with two or fewer unset readiness codes; for MY 2001 and newer vehicles, the testing process can still be completed provided there is no more than one unset readiness code. This does not mean that these vehicles are exempt from the OBD-I/M check . The complete MIL check and scan must be run in all cases, and the vehicle still must be failed if any of the failure criteria discussed in this guidance are met. The vehicle should continue to be rejected if it is MY 1996-2000 and has three or more unset, non-continuous readiness codes or is MY 2001 or newer and has two or more unset, non-continuous readiness codes.

As discussed in the Technical Support Document for the FRM, this amendment is based upon EPA’s findings regarding readiness codes from Wisconsin’s OBD-I/M data and also reflects a FACA workgroup recommendation. Since August 1998, Wisconsin’s I/M program contractor has been sending to EPA OBD scanning and IM240 test results data collected on MY 1996 and newer vehicles coming through the Wisconsin I/M test lanes. In analyzing the Wisconsin data, EPA made the following observations regarding the readiness status of the OBD-equipped vehicles presented for testing :

· The majority of vehicles showing up at the I/M lane with readiness codes reading “not ready” were from MY 1996; the “not ready” rate for MY 1996 vehicles was 5.8%.

· The frequency of vehicles with readiness codes reading “not ready” dropped off with each successive model year – to 2.2% for MY 1997 and 1.4% for MY 1998.

· If an exemption were allowed for up to two readiness codes to read “not ready” before a vehicle would be rejected from further testing, the rejection rate drops – to 2.2% for MY 1996 and to 0.2% for MY 1997 and MY 1998, for a three model year average of 0.9%.


The intention behind EPA’s decision to allow limited exemptions from the readiness rejection criteria is exclusively to avoid inconveniencing motorists on the basis of vehicle conditions that are beyond their control, that are currently the subject of discussion between EPA and various manufacturers, and that, in some cases, may result in potential enforcement action. The purpose of the limited readiness exemption is not to relieve manufacturers of their responsibility to design and market OBD systems that comply with existing OBD certification requirements . Nothing in this guidance in any way changes or otherwise impacts these obligations on the part of vehicle manufacturers. In fact, EPA has already initiated several investigations which may result in enforcement actions related to these requirements.

Because of the small number of vehicles involved, EPA believes that the environmental impact of the limited readiness exemption will be negligible, especially given the likelihood that at least some of these readiness codes will have been set in time for subsequent OBD-I/M checks, and the fact that an unset readiness code is not itself an indication of an emission problem. EPA believes that allowing limited exemptions from the readiness code requirement as described above makes the most sense at this time, while EPA, CARB, and the manufacturers work to clarify system function requirements with regard to I/M. Lastly, EPA does not believe that allowing these limited exemptions will interfere with the use of readiness codes to help deter possible fraud because such fraud would inevitably lead to more monitors being set to “not ready” than are allowed under EPA’s limited exemptions.

In addition to the above exemptions, EPA also recommends that I/M programs waive the readiness requirement or otherwise accommodate specific makes, models, and model years of vehicles with known readiness design problems, in accordance with applicable technical service bulletins and/or EPA guidance. EPA has compiled a list of such vehicles and included it in Appendix D.


Even with these vehicle-specific accommodations and the above exemptions, however, some vehicles will still need to be rejected based upon readiness code status. In the case of a vehicle rejected for unset readiness codes (which does not otherwise meet the failure criteria described in this guidance), the motorist should be given the option of operating the vehicle for a week under normal operating conditions in an attempt to evaluate the necessary monitors without being required to visit a repair facility prior to retesting. If the monitors still have not performed an evaluation by the first retest, the motorist should then be advised to visit a repair facility where the monitors can be set based upon vehicle-specific, manufacturer guidance. Alternatively, states may decide to allow such vehicles to default back to the traditional I/M tests performed on the vehicles in question prior to introduction of the OBD-I/M test requirement. EPA recommends that states that choose to use back-up tailpipe testing in lieu of rejection track this activity carefully to ensure that the practice does not lead to an inadvertent loophole through which motorists routinely avoid the OBD-I/M inspection in favor of the tailpipe test.

In all cases, it is important to emphasize that lack of readiness is a special status particular to OBD systems and that the vehicle is not necessarily producing excess emissions. Instead, the vehicle’s emissions status is officially “Unknown,” due to a failure to meet certain monitoring conditions prior to the inspection. In order to minimize confusion, EPA recommends that states provide a written statement about OBD and readiness status to motorists who are rejected based upon an excessive number of unset readiness codes. Such a statement should make the following key points:

1) A vehicle rejected as “not ready” is not necessarily “dirty.”

2) “Not ready” just means the vehicle’s computer has not had an opportunity to fully evaluate the vehicle’s performance.

3) Many circumstances can lead to a vehicle being “not ready,” including recent vehicle repairs and/or battery replacement.

4) In most cases, a week’s worth of continued vehicle operation under normal operating conditions will be sufficient to make a “not ready” vehicle “ready.”

5) In a very limited number of cases (less than 1%), a “not ready” vehicle may need to be taken to a repair facility, where the readiness codes can be set based upon vehicle-specific, manufacturer guidance.


Readiness Status: Retest After Repairs -- Non-catalyst-related DTCs


OBD-I/M programs also must address the readiness code status of vehicles returning for retesting after repairs have been performed to correct an initial OBD-I/M failure. Even if the vehicle showed all readiness codes as “ready” on the initial test, vehicles returning to the I/M lane immediately following repair will likely have just had the fault code memory cleared by the repair technician (the proper step following a repair). Upon clearing the fault code memory, however, all readiness codes will also be cleared and set to “not ready.” If the vehicle returns for retesting immediately after repair, it is possible that one or more readiness codes will register as “not ready.” To address this possibility, EPA recommends that the vehicle be held to the same readiness criteria as are applicable for an initial test (i.e., if the vehicle is MY 1996-2000, a maximum of any two unset readiness codes may be allowed, while for MY 2001 and newer vehicles, no more than one unset readiness code is allowed).

To help minimize the potential for vehicles showing up for their retest with an excessive number of unset readiness codes, outreach to the repair community should stress the importance of confirming vehicle readiness prior to returning a repaired, OBD-equipped vehicle to its owner. Motorists should also be informed that they should plan to allow a week’s worth of ordinary driving between receiving repairs and getting a vehicle retested, to avoid being rejected based upon an excessive number of unset readiness codes. If, despite these caveats, a vehicle is presented for retesting with an excessive number of unset readiness codes after repair, EPA believes that the submission of repair receipts as proof of repair is an adequate method for establishing that the necessary repairs have been performed. EPA appreciates that the ability of inspectors to confirm repairs prior to retesting will vary, depending upon whether the I/M program is a test-and-repair or test-only program. In the case of test-only programs, outreach efforts to the repair community should stress the importance of including an indication on the repair receipt that the repairs in question are OBD-related (i.e., by including the diagnostic scan in an itemized list of services performed). A repair receipt (as opposed to a repair estimate) including evidence of a diagnostic scan and dated either on the same day as the initial test or sometime thereafter may be considered adequate for establishing proof-of-repair for retest purposes in test-only programs. In the case of owner-performed repairs, the program should require the submission of appropriately dated parts receipts prior to retesting, and these receipts should be reviewed by the test station manager, who in turn should be trained to determine whether the parts in question are relevant to the cause of failure. EPA believes that the number of vehicles falling into this last category (i.e., OBD-equipped vehicles that fail the initial test and return for retesting with owner-performed repairs and an excessive number of unset readiness codes) should be relatively small .


In commenting on an earlier draft of this implementation guidance, some commenters raised concern that it would be possible for repair technicians to selectively clear DTCs without performing repairs and without setting the remaining monitors (i.e., those without DTCs recorded) to “not ready.” If this were possible -- the commenters argued -- then vehicles that should be failed could be fraudulently passed on the retest (even without receiving repairs) because of the readiness exemptions allowed by EPA (assuming the number of DTCs resulting in the initial failure did not exceed the number of readiness exemptions allowed for the model year in question). In reality, it is not possible to selectively clear DTCs or to only set some readiness monitors to “not ready” while leaving the remaining monitors “ready.” As currently designed, the feature which allows the clearing of DTCs is an all-or-nothing proposition -- specifically to avoid fraud such as that suggested by the commenters .


Readiness Status: Retest After Repairs -- Catalyst-related DTCs (P0420 - P0439)

Based upon an analysis of data from the Oregon OBD-I/M program EPA recommends that vehicles which fail the initial OBD test for any of the catalyst monitoring codes (P0420 through P0439) be held to a higher standard for the retest than is the case with other failure codes. EPA recommends that initial catalyst failures follow one of the following steps at the time of retest:

6) If the catalyst monitor is “ready” at the time of retest, then the vehicle should be treated like any other vehicle returning for retest after failing for any non-catalyst-related DTC.

7) If the catalyst monitor is “not ready” at the time of retest, then the owner should be required to provide proof of repair, or the vehicle should be required to pass a tailpipe test to verify catalyst function.

8) Alternatively, at the program’s discretion, if the catalyst monitor is “not ready” at the time of retest, the vehicle should be rejected until the catalyst monitor has been set to “ready.”


Readiness Status: Continuous Monitors

As previously mentioned, EPA has found that a small number of vehicles may be flagged as “not ready” or “not supported” for one or more of the continuous monitors (i.e., misfire, fuel trim, and/or comprehensive components). EPA recommends that programs exclude these continuous monitors from consideration when establishing the initial readiness status of the vehicle. This exclusion is for readiness determination purposes only; a vehicle with a MIL commanded on for continuous monitor based DTCs should continue to be failed in compliance with the test procedure discussed earlier in this guidance. EPA is working with state programs and OBD software suppliers to address this issue and will provide revised guidance as warranted.


In the case of vehicles which fail the initial OBD-I/M check exclusively for DTCs related to the continuous monitors, repair technicians should be instructed to not clear the DTCs electronically after performing the necessary repairs. Instead, the success of repairs based upon continuous monitor related DTCs should be confirmed by letting the OBD system detect the repair and reset itself to “ready” (a process which should occur naturally after 3 engine key-on/key-off cycles, provided the repairs were performed correctly). In the case of initial failures for a mix of continuous and non-continuous monitor related DTCs, the DTCs should continue to be cleared, post-repair, as recommended elsewhere in this guidance.


Evaporative System Testing and OBD

EPA’s analysis of the Wisconsin I/M lane data suggests that OBD-I/M testing can be supplemented by including a separate gas-cap check. When EPA compared failure rates for the evaporative portion of the OBD-I/M test to the failure rate for the stand-alone gas cap test we found that the separate gas cap test was able to identify a substantial number of leaking gas caps that were not identified by the OBD monitors due to the different failure thresholds.

The seeming disparity described above is a result of the different detection thresholds for the two tests. The stand-alone gas cap test was designed to detect a leak as small as 60 cubic centimeters per minute (cc/min) at a pressure of 30 inches of water, while OBD systems were designed to detect leaks equal to a circular hole 0.040 inches in diameter. The 0.040 inch hole equates to a flow rate in excess of 2,600 cc/min at 10 inches of water column (i.e., the maximum allowable internal tank pressure using the enhanced evaporative emission test) . As a result, an OBD system can reliably detect a loose or missing gas cap, while a properly tightened but leaking gas cap that can easily be identified by the gas cap test will probably not be identified by OBD.

Since the gas cap test is able to identify an excessive emission condition not identified by OBD, EPA recommends including this additional testing element in those areas that need substantial reductions in hydrocarbon (HC) emissions from mobile sources as part of their ozone attainment plans. For states with more modest air quality needs with regard to mobile sources, EPA is leaving it to the states to assess their needs regarding whether or not gas cap testing is added to the OBD testing regime. EPA is reserving judgement at this time because we still do not have sufficient data to draw reliable conclusions concerning the frequency of leaking gas caps in the in-use fleet. Our efforts in these areas have been complicated as a result of pre-inspection replacement of the gas cap and, in some cases, a failure by inspectors to record the initial gas cap failure as a failure. During informal audits of such programs, EPA has found that the faulty gas cap is frequently replaced on the spot, or the owner is directed to simply replace the cap later without being required to return for a retest .

Implementation Issues for Centralized vs. Decentralized OBD-Based Testing

While EPA recommends that I/M programs integrate OBD-I/M test procedures into an overall, PC-based, real-time data-linked testing system, we understand that some programs which do not currently require test stations to be linked to a real-time database may opt to use generic, stand-alone, handheld scanners that do not generate automatic test reports and are not tied to a real-time data-linked system. While the use of stand-alone scanners is not barred by I/M regulations for those areas not otherwise required to employ a real-time database, EPA nevertheless sees several drawbacks to the stand-alone approach to OBD-I/M testing. For example, the lack of a real-time data link will mean that program oversight will necessarily be more costly, more labor intensive, and also less comprehensive, leaving the program perhaps more vulnerable to fraud. This decrease in program oversight effectiveness would come at a time when a significant portion of the program itself is reverting to what is, in effect, a manual test program, where test reports are filled out by hand from information read off a handheld scanner’s screen. Historically, programs that rely upon a non-automated process for making pass/fail decisions have been found to be even more difficult to oversee than traditional decentralized programs, since no electronic record is produced, making auditing more difficult. Furthermore, the use of computer matching to identify non-complying vehicles would be seriously restricted under such a system, assuming that such a system would not result in an electronically searchable testing database. And while it is possible that manually-completed test reports could be made computer-scannable and collected during site visits or sent to the state, the inherent time lag between the test and inclusion in the state database makes this a challenging implementation issue (i.e., a negative hit could equal data lag, not necessarily non-compliance). Lastly, the individual station’s access to extensive and important program information (for example, DLC location databases and technical service bulletins regarding program updates, pattern failures, etc.) would be limited, both in terms of availability and timeliness.

At a minimum, EPA believes that for an OBD-I/M test program to be most effective -- whether centralized or decentralized -- it should be designed in such a way as to allow for:

· Real-time data link connection to a centralized testing database;

· Quality-controlled input of vehicle and owner identification information (preferably automated, for example, through the use of bar code); and

· Automated generation of test reports.


OBD and Inspector Fraud


As is the case with all other I/M test types, the OBD-I/M check is vulnerable to inspector fraud, and program managers need to be on guard to limit the opportunities for this kind of activity. For example, it is currently possible for an unscrupulous inspector in a tailpipe-based program to engage in a practice known as “clean piping,” where a known-clean vehicle is tested while the vehicle identification information for another (presumably dirty) vehicle is entered into the test record. Similarly, there is a limited opportunity for an inspector to “clean scan” an OBD-equipped vehicle, but there are also methods for keeping this type of activity in check. The opportunity for “clean scanning” exists because the vehicle identification number (VIN) is not currently included in the data stored in the vehicle’s onboard computer. Unlike “clean piping,” however (where almost any known-clean vehicle will do), the opportunity for large-scale “clean scanning” can be greatly reduced through the use of identity-limiting information which is currently available from the vehicle’s OBD system. For example, programs could tally the number of Parameter Identifications (PIDs) supported by the vehicle, which can be used as a check against the other vehicle information entered into the test record. Another important number to capture and track for quality control purposes is the Powertrain Control Module (PCM) diagnostic address . While these numbers do not identify a vehicle down to the level of an individual registration and owner, they do allow for the separation of vehicles into different makes, models, and engine families. Put another way, the PID count and PCM diagnostic address for a Honda Accord will be different from that of a Ford Escort. Therefore, programs can limit the potential for fraud via “clean scanning” by comparing the PID count and/or the PCM diagnostic address to the other vehicle information in the test record. EPA is working with manufacturers and states currently implementing the OBD-I/M inspection to gather the data necessary to interpret PID count and PCM diagnostic address information so it can be used for this purpose.

In commenting on an earlier draft of this implementation guidance, some commenters suggested that even though the use of PID counts and PCM diagnostic addresses could limit the potential for fraud via “clean scanning” among garages and service stations, it does not pose much of a deterrent for dealerships, which have a readily available supply of vehicles of the same make and model as vehicles being tested. While this may be the case, EPA does not believe that the potential for fraud among OBD-equipped vehicles is any higher than the current potential for fraud via clean piping. Furthermore, if a state is concerned that dealerships pose a greater fraud threat than other service providers, the state certainly has the discretion to monitor the compliance of those dealerships and take appropriate enforcement action, should fraud be detected.


Repair Cost Waivers and OBD


Though for equity reasons it may be difficult for states to eliminate the waiver option for OBD-tested vehicles, EPA recommends that states consider at least modifying waiver requirements for such vehicles. The reason for wanting to avoid granting a waiver to a vehicle with an illuminated MIL is two-fold: 1) it reinforces bad behavior (i.e., ignoring illuminated MILs) and 2) once lit, a MIL that was illuminated for a relatively minor problem effectively eclipses new, major problems, should they develop. At a minimum, the state’s public education efforts regarding the OBD inspection should stress the importance of responding to illuminated MILs in a timely manner.


Public Outreach

In recognition of the pivotal role repair technicians and the public play in the success of I/M programs, EPA recommends that all states required to perform vehicle OBD system checks begin public outreach and technician training six months to a year prior to the beginning of mandatory OBD testing . Therefore, another reason for issuing this guidance at this time is to give states the opportunity to consider the various issues raised by and addressed in this guidance in the development of their public outreach and technician training efforts. The need for public outreach is also one of the reasons EPA has provided states several options for postponing the deadline for mandatory OBD testing beyond January 1, 2001 as part of its April 5, 2001 rulemaking.

To facilitate a smooth incorporation of OBD-based testing of OBD-equipped vehicles into I/M programs states should not underestimate the importance of effective public outreach campaigns to inform motorists and the repair community about OBD and how it works, what the MIL is and how to respond to it, and the environmental and consumer benefits of OBD. Thorough explanation of the OBD system within the context of I/M testing may guard against the negative public perception which accompanied the introduction of loaded mode testing in many areas. Extra care may need to be taken in areas where loaded mode testing made the state emissions testing a "hot button" issue.


Once developed, public educational materials should be disseminated as widely as possible. Relevant distribution points include: Trade organizations, dealerships (service writers as well as technicians), AAA and other insurance-provider newsletters, private garages, owners manuals for MY 1996 and newer vehicles, EPA publications, auto shows, drive-time radio advertisements, automotive magazines, and environmental public service announcements. In pursuing their public outreach efforts, states should be sure to involve all relevant parties in the process of developing and distributing materials. These include: State legislators, local leaders, automobile manufacturers, automobile enthusiasts, scan tool manufacturers, EPA regional offices, emission inspection contractors, environmentalists, health professionals, AAA and other automotive insurance providers, technical colleges, service writers, private garages and repair chains.

Technician Training

The success of a state’s OBD-I/M effort will also depend on making sure that the repair community is prepared to address the sorts of vehicles that are identified by the OBD scan as needing service and/or repair. States should work with their local educational institutions, OBD equipment vendors, and other training providers to ensure that the necessary training is available to repair technicians in the field well in advance of mandatory OBD-I/M testing. In addition, states should also work with the various organizations representing the repair community to stress the need for repair technicians to take advantage of the training opportunities that are available.

In I/M programs where repair technicians are licensed or certified by the state to participate in the program, OBD-specific repair technician training should be required as a prerequisite to such licensing or certification. Such training should address the following topics, at a minimum:

· The basics of OBD (i.e., theory, terminology, legal requirements, etc.)

· The differences between OBD I and OBD II

· The OBD-I/M inspection procedure

· The pass, fail, and rejection criteria for OBD-equipped vehicles

· Readiness, the setting and clearing of codes, and MIL-triggering vs. pending DTCs

· The link between the OBD-I/M check and the environment, and

· Proper diagnostic procedures and available sources of diagnostic materials (i.e., manufacturers, hotlines, web sites, etc.).

APPENDIX A

Glossary of I/M- and OBD-Related Terms


Basic I/M: A vehicle inspection and maintenance program designed to meet the basic I/M performance standard which includes performance of an idle test on 1968+ passenger cars. Under the 1990 Amendments to the Clean Air Act, basic I/M is required in moderate nonattainment areas, as well as those areas already implementing or required to implement a basic I/M program prior to passage of the 1990 Amendments.

“Check Engine” Light: See the definition for Malfunction Indicator Light (MIL) below.

Diagnostic Trouble Codes (DTCs): An alphanumeric code which is set in a vehicle’s onboard computer when a monitor detects a condition likely to lead to (or has already produced) a component or system failure, or otherwise contribute to exceeding emissions standards by 1.5 times the certification standard.

Enhanced I/M: A vehicle inspection and maintenance program designed to meet one of three enhanced I/M performance standards – high, low, and ozone transport region (OTR) low. The high enhanced standard is designed around IM240 tailpipe testing and purge and pressure evaporative system testing. The low enhanced standard is similar to the basic I/M performance standard, but includes light-duty trucks and a visual anti-tampering inspection. The OTR low enhanced performance standard is designed for areas which would not be required to do I/M at all, save for their location within the Northeast Ozone Transport Region. The OTR low enhanced standard is based upon tailpipe testing using remote sensing devices and visual anti-tampering inspections. Serious and worse nonattainment areas are required to implement enhanced I/M, as well as all areas within the OTR with populations over 100,000, regardless of attainment status.

Evaporative System Test: A test of a vehicle’s evaporative control system to determine if the system is 1) leaking and/or 2) purging properly.

Malfunction Indicator Light (MIL): Also known as a Check Engine light, the Malfunction Indicator Light of MIL is illuminated on the dashboard when conditions exist likely to result in emissions exceeding standards by 1.5 times or worse. Alternatives include “Service Engine Soon,” as well as an unlabeled picture of an engine.

Onboard Diagnostics (OBD): A system of vehicle component and condition monitors controlled by a central, onboard computer running software designed to signal the motorist when conditions exist which could lead to a vehicle’s exceeding its emission standards by 1.5 times the standard.


OBD Data Link Connector (DLC): The interface – usually located under the dashboard on the driver’s side – between a vehicle’s OBD computer and the OBD scanner. Connecting an OBD scanner to the DLC allows I/M inspectors and vehicle repair technicians to read the readiness status of the vehicle’s various onboard monitors as well as any diagnostic trouble codes (DTCs).

Readiness Code: A status flag stored by a vehicle’s onboard computer which is different from a DTC in that it does not indicate a vehicle fault, but rather whether or not a given monitor has been run (i.e., whether or not the component or system in question has been checked to determine if it is functioning properly).

Scanner or Scan Tool: A PC-based or handheld device used to interface with a vehicle’s onboard computer for the purpose of reading DTCs and monitor readiness status.

Test-and-Repair: An I/M program which allows the same people who test a vehicle to also repair the same vehicle and retest it to determine whether or not the repairs performed were adequate. Test-and-repair programs are also generally decentralized, though not all decentralized programs are necessarily test-and-repair.

Test-Only: An I/M program – usually, though not exclusively centralized – which requires that the functions of testing and repair be performed by different, financially unrelated parties.

zoneblock

In LA county they also require a dyno test to be performed while you are hooked up to their computer. :U