Smog Check contingency measure for the San Joaquin Valley
In October 2025, the U.S. Environmental Protection Agency (EPA) issued a finding that the San Joaquin Valley failed to attain the 80 parts per billion (ppb) 8-hour ozone standard established under the federal Clean Air Act. This determination triggered a Smog Check contingency measure included in California’s State Implementation Plan (SIP).
Following the EPA finding, the California Air Resources Board (CARB) notified the Bureau of Automotive Repair (BAR) and Department of Motor Vehicles (DMV) that the contingency measure had been triggered and requested that the agencies begin preparing for implementation in the affected area.
At the January 29, 2026 BAR Advisory Group meeting, CARB provided an overview of the measure, explaining how it fits within California’s broader strategy for achieving and maintaining air quality standards.
State Implementation Plan and contingency measures
Under the Clean Air Act, states must meet health-based standards for air quality, as established by EPA. Each state is required to develop and adopt attainment plans for each area that does not meet one or more standard and submit them to EPA for inclusion in the SIP. Attainment plans outline how each area will achieve and maintain those standards.
The Clean Air Act requires that areas submitting an attainment plan have contingency measures in place—emission reduction strategies that are adopted in advance and held in reserve. When EPA finds that an area fails to meet required air quality milestones or attainment deadlines, these measures are triggered to achieve additional emissions reductions and help the nonattainment area continue to make air quality progress.
Smog Check Program changes under the contingency measure
For vehicles registered in the San Joaquin Valley nonattainment area, the triggered Smog Check contingency measure would reduce the new vehicle Smog Check exemption from eight model years to seven. This would increase the number of vehicles subject to Smog Check inspections in the San Joaquin Valley. Bringing these vehicles into the biennial inspection program earlier is intended to identify emissions-related failures that, when repaired, result in further emissions reductions.
The Smog Check contingency measure has two triggers available per area. If the San Joaquin Valley fails to meet required air quality standards, a second EPA determination could activate the second available trigger. This second trigger would reduce the new vehicle Smog Check exemption from seven model years to six model years.
Affected areas in the San Joaquin Valley
The current trigger of the Smog Check contingency measure would only apply to the San Joaquin Valley. CARB has identified the following counties that would be affected:
San Joaquin
Stanislaus
Merced
Madera
Fresno
Kings
Tulare
Western Kern
Preparing for implementation
CARB is working closely with DMV and BAR to prepare for the implementation of the Smog Check contingency measure. Planning efforts include system updates, stakeholder outreach, and public information materials to ensure vehicle owners and industry are informed before any changes take effect.
To stay informed about implementation timelines and program updates:
See the CARB presentation at the January 2026 BAR Advisory Group meeting and watch the meeting webcast recording.
Visit CARB’s website for information about the California State Implementation Plan and the Smog Check contingency measure and subscribe to CARB’s email updates.
Subscribe to BAR’s email list to receive notifications about Smog Check Program changes and related guidance.