Exhausting Practices

it was bandied as a strategy to promote good vehicle maintenance and help curb pollution. But India's inspection and maintenance ( i&m ) programme -- in other words, the Pollution Under Control ( puc ) certificate scheme -- has turned into a major farce. After almost a decade of checking tailpipe emissions, the effectiveness of the programme has not been assessed. Yet, it continues to be prescribed as the panacea for all vehicular pollution ills, by the government as well as the automobile industry. This, at a time when other countries such as the us , which obviously has more sophisticated i&m programmes, are beginning to doubt the scheme's effectiveness in controlling pollution. In India it has grown into an attractive scheme with its own lobby and political influence. It is easy to pin the blame on the hapless consumer rather than the powerful industry.

i&m strategy in India hinges on checking tailpipe emissions -- carbon monoxide ( co ) in four-wheelers and hydrocarbons ( hc ) in two-wheelers. In 1990, irrespective of the age and weight of the vehicles, uniform exhaust emission norms were introduced. It mandated tailpipe co levels in car exhaust at 3 per cent by volume and hc levels in scooter exhaust at 4.5 per cent by volume. For diesel vehicles, smoke density limit was set at 75 Hartridge smoke unit, a unit for testing smoke, at full load. These tests are conducted in more than 400-odd testing stations scattered all over Delhi where the scheme was first introduced. In a city like Delhi, any i&m programme would have to target a vehicle population of more than three million. The sheer volume of the tests, low compliance levels and weak enforcement of the programme have made it ineffective.

The reality is that i&m has not made much difference to any city's air quality. The us has the most composite i&m programme and stringent exhaust emission norms depending on the age and weight of the vehicles. Despite all this, various studies have pointed out that even the us $1 billion project has made negligible impact on us air quality. Contrary to expectations that i&m would reduce co and hc emissions by 30 per cent, some studies indicate higher emissions in states with i&m facilities than in others where no such facilities exist.

The US experience: I&M doesn't help
When in the early 1990s, the us Environment Protection Agency ( usepa ) asked state environment agencies to enhance their i&m programme, not everybody was convinced about its effectiveness. The California Air Resources Board ( carb) conducted a series of roadside surveys in 1989, 1990, and 1991. They showed that i&m programmes had not achieved the calculated and modelled reductions in pollution levels as required by law, irrespective of the annual smog check programme. Random roadside survey of 11,000 vehicles in California revealed that the programme had little effect on emissions from in-use vehicles. Average co concentration, for instance, remained nearly constant in Los Angeles since 1983 and stayed that way throughout the rest of the decade. In fact, ambient co concentration in Los Angeles dropped dramatically from the mid-1960s, when controls were first mandated for the motor vehicle fleet, until the early 1980s. From 1983, however, average co concentration and the number of times the air quality went above the standard remained nearly constant throughout the remainder of the decade.

In view of these findings, Douglas R Lawson of the Desert Research Institute in Nevada, usa, cautioned that it was important to evaluate the programme before usepa embarked on enhancing it further.

Tampering, the easy way out
All along, the i&m concept in the us has been based on ideal conditions. The real world is a different ball game altogether. Manipulation and corruption hinder its effectiveness. The roadside surveys conducted by carb also showed that nearly all vehicles eventually "pass the test". Any competent owner or mechanic can adjust a vehicle so that on the required day a given vehicle can pass the test. The next day, however, the vehicle can be tuned back to its original state or simply left to deteriorate.

Says Michael Walsh, an automobile consultant and editor of Carlines , " i&m will always be controversial because they directly impact every vehicle owner and driver and with so many people involved it is easy for corruption to seep in." The rate of tampering in the us has been found to be as high as 25 per cent (see table: Not tamper proof ).

Says Lawson, "It appears that motorists do not perceive the smog check programme as beneficial to air quality and they avoid vehicle repair costs. This implies that i&m programmes must confront the human behaviour problem and not just the technological problems." Lawson identifies several problems: inspection centres do not screen problem vehicles; corruption and fraud; about half the cars repaired after inspection have increased emissions; and motorists tamper with cars to make them clean on the required day.

Hence, when the usepa proposed to make i&m programmes stricter with time-consuming and costly emission tests for in-use vehicles, there were grounds for apprehension. As many vehicles were already "passing the tests", this would mean only continuation of the programme, not effectively reducing emissions. When usepa pressured about 35 states to adopt i&m tests, some of them protested. The June 25, 1999, issue of the daily usa Today reported that officials balked at the cost and effectiveness of a programme that required every car to be tested to catch some 10 per cent big polluters. Similarly, a study in Minnesota found almost no effect where usepa models predicted there should have been roughly a 30 per cent decrease. Colorado found that 29 per cent of the cars, which failed initially in 1995, failed again in 1997. Even those who follow rules end up polluting more over time. In Arizona, pollution from failing cars increased after they had been fixed, wiping out much of the improvement. Based on this evidence, usa Today criticised usepa, saying, "Despite the findings, the epa doggedly defends its testing programme, saying it is fine tuning its pollution forecasts. Worse, the epa lets states off the hook by giving them credit for pollution cuts that aren't actually occurring."

Despite the criticism, California enforced an enhanced i&m programme in 1998. This included, among other thing, more sophisticated biennial acceleration simulation mode test under two engine loads on dynanometer. As a result the measurements were more representative than the normal idle speed testing as was done under earlier basic i&m programme. Emission cut-off point varied according to the vehicle weight and age. This was further related to the mass emission standards on the basis of which the car was manufactured. If a vehicle exceeded the second higher cut-off point then it was classified as "gross polluter". Owners of vehicles falling in this category could receive either a repair cost waiver (if the owner first spends at least us $450 in emission-related repairs) or an economic hardship extension (if the owner meets the low income criteria and spends at least $250 in emission repair). This gives the owner another two years to fully repair his or her vehicle.

But in view of the doubts already cast on the programme, the California state legislature set up an i&m review committee that contracted Lawrence Berkeley National Laboratory of the University of California, to evaluate the state's current programme on enhanced smog check. The report, submitted to the committee in June 2000, claims that with enhanced smog check programme average emissions of the overall fleet reduced by 5 per cent for hc and oxides of nitrogen ( no x ) and 20 per cent for co , up to two months after the test. In terms of quantum of pollution, 40-86 tonnes of hc , 864-1,686 tonnes of co and 59-83 tonnes of no x exhaust emissions were reduced per day.

The study claims that there is substantial benefit in the case of vehicles that fail the initial test and then pass the second test. The reduction in co , for instance, can be as high as 70 per cent. But emissions of those vehicles that pass the first test increase steadily and substantially over the next six months. Therefore, the net gain is not so much. The report does point out that an initial limited remote sensing study suggests a much smaller emission reduction benefit from enhanced smog check programme than is measured under the programme test conditions or at the roadsides. The remote sensing data indicates that benefits of the programme can be seen for six-nine months for hc and co and just three months for no x .

i&m programme in California state costs about $850 million. In fact, enhanced smog check costs about $5,400 per tonne of pollution load reduction and i&m committee still considers this to be cost-effective as compared to other strategies like low emission vehicles and vehicle retirement.

Explains Walsh, "Because California has done so many other things, including having the most advanced new car control programme in the world with second generation on-board diagnostic centres and manufacturer recall liability, it is difficult for them to find additional programmes to reduce emissions by even a few per cent. Rather than just looking at percentage reductions on individual cars and comparing it to millions of dollars, I think the dollars should be compared to the tonnes reduced and ask if the money were spent in a different way, how many more tonnes can be reduced."

The i&m review committee report has looked into the human behaviour factor as well. The report admits that at least 10 per cent of vehicles failing the initial tests never receive a passing test. In fact, one-third of these vehicles were spotted while being driven in areas with i&m programme even one year after testing.

If corruption level is high in the us how much worse would it be in India? The poorly designed decentralised system of checking tailpipes in itself is flawed. It provides far greater scope for corruption and evasion and is based on extremely weak exhaust emission standards. The us has both centralised and decentralised systems in place, and yet there have been reports of tampering. Centralised programmes require all tests to be done mostly in government-owned stations specialised in emissions testing, while in a decentralised system a large number of private garages are involved. Despite the high costs involved with the former, it is perceived as more credible and honest. Decentralised systems may lack the accuracy of the automated centralised stations and would need surveillance to check corruption even in the us .

It is just about anybody's guess how futile the puc scheme is. Says Walsh, "It is much easier to do a poor programme than a good one and, in my view, it is better to do nothing than to do a poor programme."

There is significant evidence suggesting that not the entire fleet but only a small fraction of badly-maintained vehicles with technical flaws contribute disproportionately to air pollution. The challenge is how to isolate them from the rest of the vehicles and weed them out. Due to the sheer volume of periodic checks required and the added problem of public nuisance, city authorities in several other countries are focussing more on the smaller number of most polluting vehicles for more effective results. The Financial Times Automotive Environment Analyst reports that a survey by oil giant Shell indicates that 20 per cent of vehicles emit more than the remaining 80 per cent combined. It has also been estimated that 50 per cent of noxious pollutants is caused by only 10 per cent of motor vehicles.

Furthermore, the most unexpected findings from the 1989-1991 roadside surveys undertaken in California are:

• on an average, idle emissions increase as vehicles age because older vehicles have more lenient norms and they emit more due to deterioration;

• About 40 per cent of the oldest vehicles have low emissions. In other words, not all old vehicles have high emissions;

• High emitters are found in all model years, not just in oldest vehicles; and

• 60 per cent of low idle co and hc emissions each were emitted by 10 per cent of the fleet. This essentially means that a small percentage of vehicles are responsible for disproportionately large emissions and high emitters can be spotted across all model years.

While the proportion of gross polluters in the vehicle fleet is likely to be small in industrialised countries where the overall technology of the fleet is more advanced, the proportion will be larger in developing countries with polluting technology. A World Bank study states that the average polluting vehicles are higher in developing countries than industrialised countries. If weeding out of 10 per cent of vehicles in the industrialised countries can reduce emissions by 60-70 per cent, more would have to be dumped in India for similar results. This will mean more problem for the consumer and harassment unless the industry is forced to move towards better standards fast.

A similar pattern has been observed in other countries as well. The highest emitting 20 per cent cars in Bangkok, Thailand, accounted for about 50 per cent of measured co emissions. Likewise, 20 per cent of the buses accounted for 50 per cent of the measured smoke emissions.

Even in India, limited surveys show that vehicles that need major repair for controlling pollution are very small. The Indian auto industry's own attempt at checking pollution lends credence to this concept. Emission testing camps organised by Bajaj Auto Ltd ( bal ) during 1996-1997 have shown that the proportion of vehicles that need to be put off the road is as low as 6 per cent. The majority of vehicles on road meet emission norms. According to N V Iyer, bal 's general manager, of the 60,000 vehicles checked in their camps, about two-thirds met emission norms. "A fairly large percentage of the vehicles that did not meet norms could be rectified with minor engine tuning. Only 6 per cent had to be dealt with in garages," he says.

But officials and scientists in India do not read their own data. In a World Bank-sponsored workshop in April, 1998, Automotive Research Association of India ( arai ), Pune, had presented emission data of in-use vehicles to prove how i&m programme can help to reduce emissions in India. As expected, the industry-supported organisation argued that i&m programmes work.

arai is the most unabashed pro-industry organisation in the country and yet the government of India has given it the responsibility to certify the emissions of the new vehicles. Interestingly, a more detailed scrutiny of the same data by the Centre for Science and Environment (cse ), a New Delhi-based non governmental organisation, showed that there is no direct correlation between age and emissions and that even new vehicles pollute more than old vehicles. Thus, even the arai data proves the concept of gross polluters (see box: Small is dangerous ). When cse sent its analysis to arai , there was not even an acknowledgement from this "prestigious" organisation overseen by the ministry of surface transport and the ministry of industry.

There are good reasons to feel sceptical about the effectiveness of i&m schemes, especially the high cost it entails and widespread inconvenience it causes only to isolate a few big polluters. The countries that are now wiser are, in addition to removing gross polluters from the fleet and disciplining consumer behaviour, netting in the manufacturers as well to make them accountable for the emission performance of the vehicles they produce. Using remote sensors and on-board diagonistics, they are already able to identify gross polluters (see box: Catch the culprit).

In India, Sections 56 and 59 of the Indian Motor Vehicles Act, 1989, govern i&m of vehicles. A certificate of fitness is issued under Section 56 annually to all vehicles and under Section 59 the government has the power to fix the age of vehicles. i&m got a kickstart when vehicle exhaust emission standards were laid down for the first time in 1990 and the puc programme began.

While no official effort has been made to assess the effectiveness of this programme, the government continues to propagate the myth that it works. Both the government and private companies have issued huge ads encouraging people to go in for the puc certificate. The Delhi government has even funded ad agency, Tulika Advertising Ltd, to secure children's help in influencing their parents to get puc certificates.

The poorly-designed decentralised system of checking tailpipes in India is still conducted on the basis of extremely weak and outdated in-use emission standards. But the government still has no plans for revising emissions standards. Central Pollution Control Board ( cpcb) officials confirm that this is still not a part of the mandate of the committee, which is now looking into the revision of mass emission standards for 2005. So both old and new generation vehicles are tested using the same parameters, but the new vehicles get considerable leeway and could get away with higher emissions that could be due to malfunctioning pollution control devices.

The success of the present puc system relies more on fine tuning the carburettor to keep the air-fuel ratio at the optimum level. To pass the puc tests, the engine must be a very lean engine. The roadside mechanic can conveniently tune the engine accordingly to pass the test. But a lean engine tends to stall and does not have good acceleration. So most drivers resent it when the vehicle stalls at traffic signals and takes time to start again. Drivers also complain of power loss. So there is a tendency to pass the test by adjusting the old carburettor engine to make it lean before the test and thereafter readjusted once again to get a rich air-fuel mixture for more power. Several complaints have also been reported about fake certificates issued by puc centres on payment of extra money.

Even the Delhi transport department's puc compliance status shows that in 1998 as much as 87 per cent of the total vehicles did not have puc certificates. The level of compliance is so low that the highest percentage of vehicles with valid puc recorded was 23 per cent in 1997, when a special drive was launched to enforce the order requiring certificates.

Yet another report, prepared by the Automobile Association of Upper India ( aaui ), an organisation of vehicle users, based on its campaign to verify the genuineness of the puc tests alleges that it is impossible to test the large numbers of vehicles per day as recorded in the puc centres. aaui estimates that any pollution test would take 2-3 minutes for parking and positioning of the vehicles and another 6-8 minutes for testing and adjusting the carburettor. Accordingly, only six vehicles can be tested properly per hour. Based on this estimate, the aaui report comments, "It raises doubts about the genuineness of the testing, when more than 100 vehicles are tested by any service station in one day, assuming and eight-hour work day."

While, on the one hand, the public is harassed, on the other, the government has done nothing to keep its own house in order. A surprise check on the Delhi Transport Corporation ( dtc ) central workshop in Okhla in 1995, following orders of the then environment minister Rajesh Pilot, showed that dtc had only four smoke metres to test a fleet of 2,950 buses in 33 depots. These testing machines were not even calibrated before measuring emissions. Subsequently, in a random check carried out by the Environment Protection Control Authority on the transport department in 1999, a majority of the dtc buses were found to be polluting. Of the 12 dtc buses checked at the Ashram Chowk, 10 failed to pass the test. Buses are usually "gross polluters". People can easily see the smoke public buses belch out. It was even worse in Chennai where the state government tried to exempt all state transport vehicles from any traffic rules and regulations including puc tests (see box: Acting on whims ).

Vatavaran conducted some random tests and organised visual inspection of vehicles on the capital's roads in January 1998 in Delhi. The result was startling. About 52 per cent of the cars, 98 per cent of tempos and trucks, 66 per cent of three-wheelers, 98 per cent of two-wheelers, 82 per cent of taxis, 100 per cent of 8 seaters, and 94 per cent of buses tested were unable to pass the test.

A feeble attempt at looking into the problem of emissions from in-use vehicles was made when cpcb set up a sub-committee under the chairperson of P V Sardesai of arai to recommend an i&m regime for in-use vehicles. This committee, though set up in 1997, has held only one meeting in May 1998. It is yet to provide a firm plan of action. On the basis on one meeting, some loose recommendations were submitted to the cpcb . These include, among others, a centralised inspection system, rigorous audit of the existing puc centres to stop malpractices, organising vehicle-owners' awareness programmes, and administrative measures to penalise non-compliance and training of staff at regional transport offices and improvement in infrastructure. But nothing has happened since.

In the meantime, the automobile industry led by the siam has jumped into the fray to initiate a pilot project on i&m to supplement the official effort. They have come up with a draft proposal and submitted it to the Delhi government. siam has earmarked Rs 1 crore for a model i&m centre in Delhi to test 50,000 vehicles annually. Initially, they will test only commercial vehicles and subsequently extend the facilities to private vehicles as well. Like arai, siam is also proposing a centralised system with the state-of-the-art automated equipment and trained personnel to carry out inspection. But the siam proposal has not taken off as the Calcutta High Court has imposed a stay, restricting private participation in i&m programmes. Unless this order is vacated, private parties cannot participate in i&m .

In need of a strategy
It is not easy to abandon a programme unless there is political pressure or it becomes an embarrassment for the government. In India, i&m enjoys strong political patronage. Neither does anyone in the government consider the dismal failure an embarrassment. It is another matter that the puc regime in its present state will never make any difference to any city's air. Considering the fact that a relatively small numbers of vehicles are major contributors to the air pollution load, it would make more sense to identify gross polluters through visual inspection and immediately deal with them. A visual inspection programme together with an emission warranty-cum-recall system would create fear and provide support to vehicle owners and ensure that both parties -- manufacturers and consumers -- take appropriate responsibilities.

The Supreme Court has ordered advancement of Euro ii norms from April 1, 2000, for the National Capital Territory and the subsequent revisions must soon follow. But if we are interested in clean air we have to ensure that vehicles once bought continue to have low emissions for a long time. This calls for going beyond the existing certification system with which regulation of norms stops at the factory gate.

In India, a company has to get a certificate from the arai . But the certification process is far from reliable (see box: Testing in secrecy ). Since it is not possible to know the actual emission levels at the time of the purchase, it is also not possible to compare the rate of deterioration that the vehicle undergoes once a vehicle is on the road. The rate of deterioration can be quite rapid, depending on how well it is maintained (the consumer's responsibility) and how well it was produced (the manufacturer's responsibility). As seen from the experience of other countries, emissions of vehicles can increase fast even after proper maintenance if standards have not been maintained for the vehicle's manufacturers. Only an emission warranty-cum-recall system can help to deal with this problem. But emission warranty will have to be accompanied with comprehensive in-use emission regulations and a transparent certification system with civil society representation. Spreading resources to check the tailpipe of each and every vehicle can neither ensure compliance nor clean air.

The writer is coordinator, Right to Clean Air Campaign, Centre for Science and Environment, New Delhi