For those of you who have not read the Clean Air Act in detail (which I recommend to no one) you may not realize that it does not require states to clean the air, rather it requires them to propose a program that satisfies the EPA computer model that it will clean the air by sometime in the future. If a state wants to carry out a program that is not in the model, then they get no credit from the model so they might as well not do it. An example that may have been rectified by now is auto mechanic training. All the evidence points to the fact that repairs are the Achilles' heel of I/M programs, yet states that tried to better train their mechanics got no emissions credit because such credits were not in the model.

The second step in the interpretation comes in the EPA I/M rulemaking (about 150 pages of which were generated from about 15 pages of the Clean Air Act). In this rulemaking, it was spelled out that on-road monitoring must be used on 0.5% of the eligible vehicles, or 20,000, whichever is the least, and still no credit was available. For obvious reasons, most states have yet to do any of this "required" on-road monitoring. When asked at a public hearing why only 0.5% (which could easily be done for the whole U.S.A. by one mobile remote sensor!) was the required number, the EPA representative replied that any more than 0.5% would be too expensive for the pull-over or on-board programs and since EPA did not want to force a narrow, remote-sensing-only interpretation of the act, 0.5 was the number-a clever interpretation since the Congress itself clearly intended remote sensing to be used since, on the day the amendment was voted on, we were demonstrating the remote sensing system on the driveway outside their hearing rooms. That program identified a Washington taxi that emitted more than its own weight of pollution per year. An Exxon master mechanic hired the vehicle for the rest of the day and fixed its problems for $450. A journalist for Wards Automotive Report once asked at the EPA Mobile Source Division in Ann Arbor why they were