Comment Log Display

It has been proposed that consumers wishing to participate in the
EFMP submit to an ASM test to ascertain sufficient vehicle
functionality.  In the conduct of the EFMP pilot program in the
South Coast Air Basin, requiring an ASM test, even though free to
the potential participant, was seen as significant obstacle to
participation.  There is also no data correlating the ability to
complete an ASM with either the remaining useful life of a vehicle
or the mileage accrual rate.  As you indicate on the chart provided
in the ISOR, that the differential in the emissions of older
vehicles compared to newer ones can be substantial and it would be
counter to the stated objectives of the program to omit these
older, higher-emitting vehicles due to uncertainty regarding usage.
 It is respectfully suggested that the state consider using their
official on-road emission inventory model(EMFAC) to establish an
actuarial table predicting remaining useful life of a vehicle
according to model year and odometer reading.  Such an approach
would be more consistent with Moyer Guidelines as well as the
modeled effectiveness of programs like EFMP.  Staff might consider
limiting the ASM requirement to those vehicles that have a project
life expectancy of less than 2 years - which would suggest that
they would not survive until their next scheduled inspection. We
believe that such a consideration will help improve upon the low
participation rates achieved in the past as well as save funds that
might be better spent on other aspects of the program.

Thanks for your consideration in this matter.