restriction, states are not expected to allow self-certification of fleets. Therefore the Coast
Guard will not likely be able to "self-certify" its vehicle fleets and will require off-site testing.
Presently, EPA generally supports off-site testing, which may present logistics problems for
large vehicle fleets. In addition to testing during normal hours, EPA has provided guidance
identifying three options for fleet testing:
1.
Special Hours - The state would assign special hours and test sites for fleet testing.
2.
Compromise - The Coast Guard provides the necessary test facility and the state
contractor provides testing. This is probably not a cost effective option for the Coast
Guard given the size of our vehicle fleets. A variation on this option would be for Coast
Guard to cooperate with other agencies to achieve an aggregate number of vehicles to
justify construction of a separate test facility.
3.
Mobile Testing - The state would have the state contractor test vehicles at the Coast
Guard site with mobile equipment. This is not presently an option for enhanced I/M
equipment. States can exempt private fleets from I/M requirements, however, federal
fleets cannot be exempted.
E.
Demonstrating Proof of Compliance
Coast Guard units may be required to provide documentation of proof of compliance to EPA
or the state air quality control agency. The documentation must include a list of vehicles
subject to I/M requirements, which must be updated periodically (no less frequently than each
inspection cycle). Units may find that the most efficient means of complying with I/M
requirements is to incorporate the compliance into unit security measures. The unit can use
one of the following methods to establish proof of compliance for each vehicle:
1.
Certificate of compliance from the local program.
2.
Certificate from any program at least as stringent.
3.
Certificate from any program acceptable to the state.
4.
Proof of vehicle registration in the I/M area, where I/M is required for vehicle
registration.
5.
Other methods acceptable to the state I/M administrator.
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