EMISSIONS TESTING

EMISSIONS TESTING

I went to the emissions testing center this morning. Registered vehicles in Connecticut that are more than four years old must be tested biennially. We own two such vehicles, so emissions testing is a more or less annual event in our household.

The whole process worked pretty smoothly. Connecticut sent us a postcard reminding us that one of our cars must be tested before a certain date. The test facility is a couple of miles from our house. It used to be the case that our facility did only a limited number of tests per day, so it was important to get there first thing in the morning, before they reached their limit. I don’t know if they still operate with that restriction, but this time I didn’t try to find out; I just showed up before 8 a.m. to get the job done.

I paid $20 to have the test administered and took a seat in the waiting room. A technician drove the car into the facility (I knew it was in there because it showed up on a closed-circuit television monitor), administered the test, returned the car to the parking lot, and returned the key to me with a report that listed test results and said that the car passed the test.

As I sat in the waiting room, I wondered why this testing is necessary. I answered my own question: To preserve air quality in Connecticut, of course. Then I wondered if the testing has an actual positive impact on air quality, and if the cost of this testing regime is worth the air quality improvement that results. I returned home from the testing facility and did a little googling.

Before we go on, I will readily admit that I began my search in complete ignorance, that I did very little googling, and that at best I write now with something best called incomplete ignorance. What I’m about to say is not advocacy, because I don’t know enough to be an honest advocate. And I apologize in advance for taking you deeper into the weeds than you may want or need. With that said, here is a perspective on the emissions testing system:

Connecticut emissions testing improves our air quality only negligibly, if at all, and the cost and inconvenience of the program almost certainly outweighs the benefit to the State. Emissions testing made sense when the program began in the 1980s, but it probably has outlived its usefulness. The entire system now seems to be a waste of time and money, except for the organizations that share the $20 fee I paid.

Remember, I’m a novice here, but that’s what it looks like to me.

Why might I think emissions testing is a waste? Don’t I want clean air? Sure, I do, but the question isn’t whether I want clean air. The question is whether the emissions testing system contributes to clean air by repairing or taking off the road vehicles that exceed the emissions limits established by the federal and state governments.

Let’s start with a little history. If you’re old enough, you remember cars from the ‘60s and ‘70s and ‘80s. A new car drove beautifully, made relatively little noise, and blew no visible emissions out the exhaust pipe. However, within 20,000 or 30,000 miles, the engine wasn’t running so smoothly, or there was black or white smoke coming out the exhaust pipe, or the gas mileage had dropped. Then it was off to the garage for a tune-up to clean or replace spark plugs, regap the points, adjust the functioning of the carburetor, and do other kinds of good stuff to get the car running sort of like it did when it was new. I say “sort of” because the whole process was part science and part art, and some mechanics were better artists than others. Every year or two, it was the same drill.

In those days, when we drove around town we saw cars with ugly emissions, cars that ran loudly or backfired, all because the engine hadn’t gotten the attention necessary to keep it running reasonably well. Those were the vehicles that the original testing system was designed to identify and bring into compliance.

Those were the cars of the past. Thanks primarily to the engineering revolution sparked by the Japanese in the 1980s, modern cars require very little maintenance other than oil and filter changes, and vehicles run just as well at 60,000, 70,000, even 100,000 miles as they did when the first owners drove them off the lot. We don’t have spark plugs or carburetors that require repair, replacement, or adjustment. Most importantly, we have cars that burn gasoline much more efficiently than old cars, which means that modern cars emit lower amounts of pollutants than older cars.

All of our newer cars operate efficiently and within emissions limits because the law requires that manufacturers build only vehicles that meet well defined standards. How do we know that manufacturers comply with those standards? Remember when Volkswagen got caught cheating? Every developed country in the world sanctioned Volkswagen. In the U.S. alone, Volkswagen paid several billion dollars in penalties and fines, and they also settled a class action lawsuit for $15 billion. Building non-compliant vehicles is a losing proposition, so the auto manufacturers don’t cheat; they comply with the requirements.

The dramatic improvement in automobile quality over the past four decades probably meant this: There are very few cars on the road that do not comply with the automobile emissions standards. How do I know this? It’s a reasonable assumption that cars that are five to ten and even fifteen years old continue to comply with air quality standards. Why? Because the cars were in compliance when they were sold, and our experience tells us that cars at 100,000 miles are running more or less the same as when first purchased: Same gas mileage, same sound, same absence of black or white smoke, etc. Tune-ups are no longer necessary. Very few cars have any engine work done in the first 100,000 mile. If cars are running just as well as when they were new, it’s reasonable to assume that the cars continue to comply with air quality standards.

In fact, Connecticut’s own data seems to substantiate this fact. Here’s where we head into the weeds.

Turns out that the Department of Motor Vehicles hires a consultant every two years to report on the effectiveness of the emissions testing program. I looked at the 2022-2023 Biennial Report, and if I understand the data, we’re probably wasting our time and our money on testing.

In 2023, 1,058,831 vehicles (cars and trucks) were inspected, which is about one third of the total number of vehicles subject to testing. Fewer than 80,000 cars and trucks failed the emissions test. Of those that failed the test, well over 90% passed when retested after repairs, and of the few that failed after repairs, 90% passed after a second repair. In other words, all but about 3,000 vehicles that didn’t meet the test standards initially were brought into compliance.

It’s important to recognize that those 3,000 vehicles that failed repeated testing probably stayed on the road. Why? Because the owner can get a waiver for non-compliance if they’ve paid for repairs and the repairs didn’t fix the problem. In other words, the non-compliant vehicles are still out there, driving around. If we’re going to allow those non-compliant vehicles to stay on the road, one might ask why we bother to test a million compliant vehicles a year?

Well, one might argue that the testing brings about 70,000 other vehicles into compliance with the testing standards, so that must improve air quality, right? Sure, but how much? It’s not easy to know, because just about all of those 70,000 vehicles never actually had their exhaust emissions tested. Why? Because only vehicles from model years before 2008 are tested for actual emissions. If you have a car built after 2008, check your last emissions report—you will see that the vehicle’s actual emissions were not checked.  

Newer vehicles, 80% of the vehicles subject to emissions testing, simply have their On-Board Diagnostic (OBD) systems checked. The OBD system is part of the computer system in vehicles. The OBD system checks the health and operation of the emissions control devices in the vehicle. Check your report again, and you will see that that is what is being checked. When the OBD system determines that something isn’t operating properly, the Check Engine Light comes on. We’ve all experienced the Check Engine Light at one time or another, although I must admit that it’s been ten years or more since I’ve seen one in any of our cars. (Why haven’t I seen a Check Engine Light lately? For the same reason discussed above: the quality of manufacturing has improved, and cars generally don’t develop problems that we experienced 20 years ago.) When the Check Engine Light does appear, the mechanic most often replaces a small part, resets the light, and advises that no additional repairs are necessary. Rarely does the mechanic do anything that affects how the engine actually is performing or the quality of the exhaust emissions.

Most of the vehicles that fail the emissions test have a problem in the OBD system, a problem in their electronics. When an OBD problem is identified, it does not mean that noxious fumes are streaming into our air. Instead, Google tells me that common failures in OBD systems are dirty or faulty connectors, damaged wires, corrupted software, and malfunctioning sensors. That means the most likely reason vehicles fail the emissions test is because the electronics aren’t working properly, not because the vehicle is emitting too much bad stuff. The owner whose vehicle fail the tests take their car to a mechanic, who cleans checks and repairs connectors, wires, etc., and voila! The vehicle passes its retest, but the air we breathe is no cleaner than it was before the repair.

Bottom line: It’s likely that only a small fraction the 70,000 vehicles that fail the emissions test would fail an actual test of the exhaust gases coming out the tail pipe.

The Biennial Report data also support the notion that modern cars continue to run efficiently and within federal emissions standards. Not surprising, of course, because newer cars are, well, newer. But consider this: Vehicles built in 2007, 2008, and 2009 failed their initial emissions test at rates between 5% and 10%; vehicles built from 2018 through 2020 failed their initial tests at a rate less than 5%. Thus, it seems likely that as manufacturing has improved, the need for state testing of vehicles has declined.

All of this probably means that (1) fewer and fewer vehicles on the road are polluting the air in excess of federal standards, and (2) the emissions testing regime in Connecticut does very little to identify and remove from service those few vehicles that do exceed those standards.

Finally, consider this: All vehicles contribute to air pollution, including those that comply with federal limits. Connecticut requires that all vehicles more than four years old be tested every other year, about one million vehicles per year. That means we’re adding to the pollution of our air by driving one million cars to the emissions testing facility east year.

Just as an example, assume that the federal emissions limit is 10 Korber Imaginary Units (KIUs) per mile driven. Assume that the average car that passes the test emits 8 KIUs per mile. Assume that cars that fail the test emit, on average 12 KIUs per mile, and that if identified and repaired those vehicles could pass the test at 10 KIUs, thereby saving 2 KIUs per mile per car. If 2,000 such cars are identified and repaired and if those cars travel 10,000 miles per year, the state would save 40 million KIUs (2,000x2x10,000). However, if the million cars that pass the test have an average round trip of five miles to the testing facilities, those vehicles collectively are traveling 5,000,000 miles, and they would emit 40 million KIUs (1,000,000x8x5) driving to the facilities. If those were the actual numbers, it would mean that the net improvement in air quality would be zero, since the emissions saved by testing would equal the extra emissions generated by driving to the test. On these assumptions, there would be no improvement in air quality.

Emerging from the weeds, it seems that the benefit we get from finding and fixing air pollution caused by a few thousand cars in Connecticut is minor, maybe even so small as to be immeasurable. And yet, year after year we drive our vehicles to the testing facility, pay our $20, put the report in our glove box, and go on with our days.

I asked Google how the emissions testing program is funded. Answer: It doesn’t cost the State a nickel. The program runs at a profit. $20 per vehicle, about a million vehicles a year equals—do the math—$20 million! According to Google AI, that $20 million is divided as follows:

$14 million is retained by the private emissions test centers.

$2.95 million is paid to the state’s emissions program administrator, Opus Inspections, Inc.

$3.05 million is allocated to the state and deposited into a combination of the Emissions Enterprise Fund and the General Fund.

Looked at from a somewhat skewed perspective, what we have is a system where local garages have a guaranteed stream of customers for a small and not very meaningful service. The State guarantees the stream of customers by requiring car owners to obtain the service lest they lose the right to register their vehicle. (It’s odd that you can lose the right to register your car if you don’t get the test done, but you can get a waiver and continue to register your car if the vehicle fails the test. In other words, the system threatens to take more compliant vehicles off the road than noncompliant vehicles!)

The local garage is required to charge $20 and no more for the service. From the proceeds the garage must pay for the entire cost of a paid private consultant of the State’s choosing; the consultant presumably makes certain that the program is running as required. In addition, the local garage, which would otherwise have collected and paid to the State sales tax of about $0.90 per test, pays the State $3.05. The entire arrangement is a good deal for the garage, a good deal for the consultant, and a good deal for the state. It’s not such a good deal for Connecticut citizens, who seem to be paying $20 million a year and getting no material benefit in exchange.

Wouldn’t it be simpler to require every car owner to pay $10 a year per car for the privilege of not having an emissions test? In fact, if we did that—stopped testing altogether—the State could cut out the test centers and the consultant and keep the whole $20 million! And Connecticut would eliminate air pollution caused by its vehicles traveling an unnecessary five million miles a year.

I went back to Google one more time. The cost to build and install a land-based wind turbine ranges from $2.5 to $4 million; each turbine can generate two to three megawatts. With $20 million, Connecticut could install five to eight turbines and produce from ten to twenty megawatts, enough to power a town with 15,000 homes. That electricity capacity operates with no emissions and no bad stuff polluting our air. I tried to calculate how much carbon dioxide would be put into the atmosphere by burning natural gas to produce that much power, but the numbers got so big I couldn’t believe what I was seeing. Call it a lot.

Wind turbines seem to me to be a better deal than emissions testing.