TCS Daily

Emission Improbable

By Bob Collins - July 21, 2003 12:00 AM

It's a Saturday morning in summer, and I'm going back and forth to the local Ohio E-Check station, getting emissions tests for the two family cars. The Environmental Protection Agency has just reported that the United States achieved a dramatic improvement in air quality over the past 30 years, but I don't think this is how it was done. This feels like a punishment, and it appears to do as much good as writing "I won't pollute the air" a hundred times.

It's hard to find any clear evidence that automobile emissions inspection and maintenance (I/M) programs are a cost-effective way to improve air quality. What is crystal clear is that there is no reason to put owners of late-model cars through the testing ordeal. But earlier this year, Ohio's governor vetoed legislation to exempt newer cars. His veto had nothing to do with clean air, but it illustrates perfectly how vehicle emissions testing is an environmental regulation without a cause. If the goal is cleaner air, what's working for us is better automobile technology, not testing.

First, some background: I need an OK from E-Check every other year to renew my license plates. That's because Cincinnati is in a "non-attainment" area under the Clean Air Act, and the I/M program is one of the things we can do to keep the U.S. EPA from lowering the boom. Ohio also operates E-Check programs in the Dayton/Springfield and Cleveland/Akron areas. Ohio inspects a total of about two million vehicles a year, and there are similar programs in some 35 other states.

E-Check costs me $19.95 a car -- and more time than I'll spend all year deleting spam. Both my cars pass, but then 91 percent of all cars tested in Ohio pass -- and wait till you hear the figure on newer models.

Where Are the Facts?

Is it worth it? Let's look at the facts -- or lack thereof.

In June, the Cincinnati Enquirer reported on a local county commissioner who has been fighting to eliminate E-Check. When he requested statistics on the program from the Ohio EPA, its spokeswoman responded: "We don't have the information at our fingertips because U.S. EPA has recently come out with new software. So we're using the new software, which is more accurate, to get the information." (Let me interject here that Ohio has been testing vehicle emissions since 1988.) But not to worry, she added: "We do have statistics that show the program is working."

So, what might those statistics be? If you look at Ohio EPA's
most recent annual report on E-Check, you'll find a graph showing a decline in ozone levels in E-Check counties, and this vague assertion: "The graph shows a decrease in ozone levels in the areas that had emissions testing compared to the remainder of the state. ... The reductions are due in part to the vehicle emissions testing program. Other air quality programs adopted as part of a comprehensive air quality plan also helped improve air quality in these areas."

Not exactly an airtight case for E-Check. How do you do a cost/benefit analysis on that basis? Instead, what you're presented with are graphs on the number and percentage of cars that failed the test, by model year, and the reduction in hydrocarbon and carbon monoxide emissions in cars that were repaired and re-tested. Ohio EPA touts "an average emission improvement of 77 percent for hydrocarbon." The agency estimates that E-Check removes about 950,000 tons of hydrocarbons from the environment.

Unfortunately, these estimates are based on a model that vastly overstates emission reductions from I/M programs, according to the National Research Council. In a
report requested by Congress, the NRC found that EPA's "flawed computer models ... overestimate the reduction in vehicle emissions that is attributable to inspection and maintenance programs. Actual emissions are typically reduced by less than half of what was projected."

Last year, the American Lung Association trumpeted a
report on the benefits of vehicle emissions testing in reducing air toxics. The problem was that the ALA used the same EPA model, already found to vastly overstate emissions reductions from I/M programs, to estimate their impact on air toxics.

Why Test Newer Cars?

What jumps out from Ohio's E-Check graphs is the futility of testing late-model cars. Ignoring the two newest model years (which generally aren't tested because E-Check is biennial), less than 1 percent of cars from the previous five years fail E-Check. And for those newer cars that do fail, the failing emissions levels are comparable to the passing levels for older cars that are repaired and re-tested. So the opportunity for emission reductions from late-model cars is slight indeed.

Yet late-model cars represent a very large percentage of all cars tested. Exempting all cars under five years old, as approved by the state legislature this year, would have eliminated 1.2 million emissions tests over a two-year period. That's about 30 percent of the tests. But Ohio EPA estimates that the exemption would eliminate only 1.6 percent of the total emission reductions from E-Check. In fact, the NRC report criticized I/M programs for "expending too many resources to inspect 'cleaner' low-emitting vehicles."

So, why did Gov. Bob Taft veto the exemption? Because it would have left the state holding the bag for $29 million in fees under the current contract with the emission testing company. Ohio, like a lot of other states, faces a severe budget crisis this year. So more than a million Ohio residents will have to take time during the next two years to drive their cars to a pointless emissions test so the state can collect the fee. I'll bet most of them wish they had been given the option of mailing in the $19.95.

What's Really Driving Vehicle Emissions Inspections?

It appears that vehicle emissions inspections are about everything except clean air. In 1998, the Fraser Institute found that I/M programs in British Columbia "provided a less than one percent return in environmental and health benefits." Twisting the knife a bit, the report noted that its cost/benefit analysis did not include "the environmental damage from two million extra vehicle trips, or diversions, to and from testing and repair facilities per year."

In Ohio this year, the real issues were fee revenue and a state budget deficit. Across the country, state and local officials sign on because they fear the loss of federal highway funds or draconian restrictions on economic development. Business is happy with overestimating emission reductions from I/M programs, because it keeps industrial sources out of the cross hairs. The automobile aftermarket industry has a particular stake in inspections.

The good news is that this is a problem that should solve itself. As cars with improved technology gradually replace older vehicles on the roads, any justification for emission testing will wither away. The bad news -- as Ohio proved this year -- is that testing may not be easy to kill off. (Indeed, Ohio EPA is considering expanding the program.)

The other bad news is that some regulators seem interested in new technology more for monitoring emissions than for reducing them. Remote sensing of auto emissions and on-board diagnostic (OBD) systems, which monitor environmental equipment on newer cars, are potentially useful technologies. But they also hold the potential to become higher-tech versions of I/M harassment.

Why Hasn't There Been a Revolt?

If you read through the regulatory and legislative analysis, you see lots of fretting about public resistance to emissions testing. And it's true that legislators behind the new-car exemption in Ohio this year were voted into office on the strength of the E-Check issue. But millions of Americans submit to vehicle emissions testing every year with very nary a whimper. In fact, in what can only be described as a manifestation of the Stockholm syndrome, a survey in Illinois found that motorists were "generally satisfied with the emissions testing process" and gave it an overall rating of 4.12 on a 5.00 scale.

Why no revolt? I have two theories:

The first is an analogy to tax withholding. Americans have thousands of dollars subtracted from their paychecks, yet cheer at the money they "got back from the government." At E-Check, 90-plus percent of the victims are grateful that their vehicles passed, even though this only goes to show that it was all a waste of time.

The second theory really goes to the heart of the issue. By now, most Americans have been beaten into submission, convinced that we need to do penance for our impact on the environment. We expiate our guilt by separating glass and plastic trash, or by sitting in line at the E-Check station -- whether or not it has any real, positive effect.

And, yes, there are environmentalists who believe that Americans should pay the price of their profligacy. It's not fair that Americans should benefit from the improvement in air quality provided by advanced automobile technology -- we should have to earn it. These environmentalists get lots of support from a wide range of interests that have nothing to do with clean air. And millions of Americans like me will be spending more time at the vehicle emissions testing station.

Bob Collins is a writer and owner of a 1997 Nissan Quest and a 1987 Toyota Camry.

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