THE WORLD BANK South Asia Urban Air Quality Management Briefing Note No. 9 Making Vehicle Emissions Inspection Effective -- Learning from Experience in India For controlling emissions from in-use vehicles, governments rely on emissions inspection programs with varying success. The most extensive program of this type found in South Asia is Pollution Under Control (PUC) in India. An emissions specialist who has been closely involved in the development of the vehicle emissions inspection program in Mexico City visited Bangalore, Delhi, Mumbai and Pune in India in August and September of 2002 to assess the PUC program and make recommendations for its improvement. R epairing gross polluters to lower vehicular three-wheelers, 3% CO for all other spark-ignition emissions should be one of the most effective vehicles, and an opacity limit for all diesel vehicles of 65 means of addressing transport-related air Hartridge smoke units (HSU) were established in 1986 pollution. But identifying high emitters and ensuring that and have not been revised since. There is a proposal to they are properly repaired is not easy. General lessons tighten the CO limits (including a maximum of 0.5% CO about how to mount effective vehicle emissions inspection for four-wheel vehicles with closed-loop three-way programs can be found in [1] and [2]. catalytic converters) and introduce hydrocarbon (HC) limits for spark-ignition vehicles manufactured after April In South Asia, Bangladesh and Sri Lanka are only now 2000 and equipped with catalytic converters. developing a vehicle emissions inspection program, and Pakistan has test centers on a trial basis. Nepal has been Program implementation itself is left up to each state, operating centralized emissions inspection test centers for which has to meet the minimum requirements specified three- and four-wheelers in the Kathmandu Valley since by the central government. The local State Pollution 1996, supplemented by roadside inspections. Bhutan plans Control Board (SPCB) and Ministry of Road Transport to start an emissions testing program in January 2003 to and Highways can implement a stricter program if they complementitsvehiclesafetyandroadworthinessinspection so desire. Nationally, every vehicle is required to be tested program. India has had a nation-wide inspection program twice a year, and in Delhi four times a year. since the 1980s, called Pollution Under Control (PUC)1. Test centers Therefore, it would be useful to review the PUC program, see what lessons can be learned, and consider what changes Anycompanythatownsanautomotiveworkshoporafilling would be required to make it more effective. This briefing stationcanapplytobecomeaPUCcenter.Therequirements note summarizes the findings of such an assessment [3]. forsettingupacenterarelenient,andthereislittlesupervision ofPUCcenters,whichcanbemobileorfixedunits.Although Current PUC Administration intendedtobetest-onlycentersinprinciple,thePUCcenters inpracticearepermittedtoconductminorengineadjustments TheresponsibilityforsettingupandadministeringthePUC to get vehicles through the test. Test fees vary from city to program is divided between national and state authorities. city, ranging from about Rs 20 (approximately US$0.40) for The Central Pollution Control Board (CPCB) and the two-wheelers to about Rs 70 for trucks. There is no control Central Ministry of Road Transport and Highways are on the number of approved centers. responsible for the equipment and test protocol specifications and for publishing the emissions limits. The Even though there are still not enough test lanes to carry limits of 4.5% for carbon monoxide (CO) for two- and out the mandatory number of tests, there are too many 1Inspection and maintenance refers to a vehicle emissions control system where both the emissions inspection and the vehicle maintenance programs are controlled by the government (as in California). PUC in India is a vehicle emissions inspection system. The term "inspection and certification" (I&C) is used in India to refer to a more formally structured and rigorous vehicle emissions inspection program, under governmental control, that is applied to the more highly polluting vehicle segments to certify the vehicles' compliance with the emission standards, but the government does not supervise the maintenance process directly. 1 centers to supervise given the number of enforcement the ignition timing. This "late and lean" tuning was officers. The problems found at test centers include a historically used extensively in Mexico City and California serious lack of technician training and established by owners of polluting vehicles just to pass the test. Tuning operating and test procedures; the absence of independent late and lean also increases nitrogen oxide emissions, but audits; poor or no calibration of equipment; and near- since they are not measured, this temporary tuning cannot absence of penalties so that centers can issue fraudulent be detected by the current test method. Often, the vehicle certificates with impunity. Test centers are required to engine is tuned back to its former state right after passing have an annual maintenance contract with their equipment the test because tuning late and lean can lead to supplier that includes instrument calibration every six unacceptable loss of power. As such, this test procedure months. In practice, very few centers have contracts cannot achieve the primary objective of an inspection because of the cost. There is no government calibration program: to identify for repair poorly maintained and audit program in place. None of the centers visited during polluting vehicles. The only way to close this loophole is to this assessment study had calibration gases or filters. test vehicles on a dynamometer and impose limits on nitric oxide (NO) in addition to CO and HC. This would require, Certificates in addition to installing dynamometers at test centers, five- The government does not control issuance of certificates. gas analyzers certified for CO, HC, NO, O and CO . 2 2 In Delhi, each center prints its own certificates and For diesel vehicles, a snap acceleration smoke test is windshieldstickers.Inothercities,associationsoftestcenter currently being used. The present test procedure is not owners coordinate the printing of certificates and stickers capable of generating reproducible results. Other problems fortheirmembers.Nodocumentorinformationisgenerated associated with smoke measurements are treated by the centers for government use or supervision. The separately in Briefing Note No. 10 [4]. As in the case of windshield stickers are not designed to facilitate spark-ignition vehicles, dilution of the exhaust gas with enforcement:theirgraphicdesigndoesnotvaryfromperiod clean air can lower smoke readings. toperiod,makingitverydifficultforanenforcementofficer to differentiate between a valid and outdated sticker. Data transfer and recording Test procedures All the data are manually recorded. Technicians can therefore record numbers different from the actual For spark-ignition engine vehicles (gasoline and gaseous readings, or as happens frequently, record "test results" fuels), the vehicle exhaust is tested by measuring without turning the analyzer on. For the small percentage concentrations of CO at low idle (normally between 600 of vehicles that have a current PUC certificate, this is and 1,200 engine revolutions per minute, rpm). HC/CO believed to be one of the principal means of obtaining it. two-gas analyzers certified to measure only CO are used. Other gases or rpm are not measured. The decision over PUC supervision when and how the measurement readings are to be taken Good quality assurance and quality control (QA/QC), is left to each individual tester. essential for any successful program, requires a well- One significant shortcoming of this test procedure, often trained staff with information technology systems in place negatingthevalidityofthemeasurements,isthatgasdilution that both facilitate technical accuracy and minimize is not controlled. Diluting the exhaust gas with clean opportunities for corruption. It also requires a development aireasily achieved by partially withdrawing the probe program to design and implement modifications to test from the exhaust pipelowers the readings and enables protocols, operating procedures and emission standards as needed. There are only four inspectors in Delhi to visit dirty vehicles to pass fraudulently. Furthermore, tail-pipe each of the 430 centers on a bimonthly basis to check extension tubes are not used with two- and three-wheelers sothatitisvirtuallyimpossibletoinserttheprobesufficiently their operationsthis is clearly not physically possible. into the exhaust pipe to avoid air entrainment. The only Vehicle enforcement way to prevent gas dilution is to require measurements of Enforcement of PUC is virtually non-existent, in part oxygen (O ) and carbon dioxide (CO ) to correct the 2 2 because of lack of resources. As a result, the majority readings and to specify threshold values outside of which of vehicles in India have never had a PUC test or the test is automatically invalidated. Hence, as India moves certificate, including most two-wheelers in Delhi. tomandatinglimitsonCOandHCforspark-ignitionengine Detailed information on the size and the composition of vehicles,four-gas(CO,HC,CO andO )analyzerscertified 2 2 the vehicle population is not readily available, as private for all the four gases should be used in idle tests. vehicles are required to report to the authorities only 15 Equally serious, spark-ignition vehicles are tested at low years after the first registration. Vehicle retirement is idle. All the two- and three-wheelers and the vast majority poorly recorded, so that information about old of four-wheelers are carbureted. This means that both vehiclesone of the primary targets of PUCis CO and HC levels can be lowered by tuning the air/fuel particularly inaccurate. These factors contribute to mixture "lean" (high air-to-fuel ratio) and/or by retarding vehicle owners not feeling compelled to comply. 2 Recent Developments in large cities, and one in a medium size cityto operate all the centers for a limited time period. The Society of Indian Automobile Manufacturers (SIAM) hasbeenengagedinaninitiativetoimprovePUC,primarily w RatherthanattemptingtoupgradethePUCprogramfor focusing on automated data entry. SIAM's software can the entire country covering every vehicle, consideration take CO readings from as many as 10 different makes of may be given to concentrating limited resources on analyzer and prints the certificate which includes a establishinganenhancedinspectionandcertification(I&C) photograph of the number plate. This will require that at a system for those vehicles that are likely to contribute most minimum the vehicles actually show up at a test center. to urban air pollution from mobile sources: high annual SIAM recommends requiring PUC centers to possess mileagegrosspolluters.Itisimportanttodesignthesystem extension tubes for the two- and three-wheelers. At the toovercomemanyoftheshortcomingsofthecurrentPUC: moment, SIAM's software is not designed to control the to generate far more reproducible and accurate test results analyzer or the length of the test, and does not include those with strong QA/QC to minimize fraud. Video monitoring functionsnecessaryforQA/QC,suchascalibrationcontrol, ofeachtestlaneshouldbeconsideredintheI&Cprogram. auto-zero and residual checks. SIAM intends to add a data The remaining vehicles can continue to be covered under transmission module at a later stage so that each center can PUC with less stringent modifications. send daily results to the main SIAM server via the Internet. w Another way of strengthening the inspection system while controlling costs would be to decrease the SIAM has installed its computerized data collection system frequency of tests, especially for new, private spark- at over 100 test centers in Bangalore. The response of ignition vehicles that are expected to be relatively clean the public as well as test center owners has been very and accumulate low annual mileage. positive, enhancing PUC's credibility. Testing procedures There is new test development underway. The Automotive Research Association of India (ARAI) is in the process w Tominimizefalsepasses,atestprotocolthatisdifficult of developing a simplified dynamic test for two-wheelers to cheat on or bypass, and strong and rigorous audit and that simulates the Indian drive-cycle. The test uses a supervision schemes need to be established from the simple free-roll dynamometer and current PUC outset. The protocols should be capable of preventing instrumentation. temporary tuning that enables dirty vehicles to pass. w In designing test protocols, substantially reducing In order to ensure that vehicles actually report to test measurement differences among test centers, and centers, there are proposals to link the requirement of improvingreproducibilityandaccuracyshouldbegiven having a valid certificate to vehicle insurance payments a high priority. nationally, and to annual tax in one state. The regulation w Dilutionofgasduringmeasurementsshouldbetightly requiring filling stations to limit fuel sale only to those controlled to avoid entraining clean air into the exhaust vehicles that have a valid PUC certificate (the PUC gas, thereby lowering readings and making it more windshield stickers do not have legal status at present) difficult to identify high emitters. has not been effective, as this approach is operatively complicated and works against the commercial interest w International experience with spark-ignition vehicles of filling station owners. has amply demonstrated that dynamometers are essential to minimize false passes. The dynamometer Conclusions and Recommendations tests should set limits on NO as well as CO and HC. This assessment yields some general conclusions as well w Readingsshouldbetakenafterapre-establishedtime by a computer rather than at arbitrary moments as recommendations for making the Indian PUC program convenient to the tester, as is currently the case. It is more effective. The conclusions and recommendations are also recommended that the test results not be made generalized as much as possible to apply to other countries. available to the test technician until the computer has Redesigning the testing centers entered the results in the database, lest the tester intervenes to modify the results. w Becauseofconflictofinterest,test-and-repairgarages should be phased out in favor of test-only centers. w Thecomputershouldcontrolnotonlythedataentrybut also the gas measuring equipment used. This is the only w Theinspectionprogramshouldbedesignedtogenerate reasonable profits for test-only centersby balancing way to ensure that automatic gas calibration and leak checks are correctly performed every three days at a the numbers of test centers and vehicles to be tested minimum, and that ambient and residual gas values are and allowing reasonable fees to be chargedto ensure within limits before allowing the instruments to be zero- sufficient incentive for the center owners to "police" referenced between tests. Such computer control can themselves. alsobeprogrammedtoallowtheinstrumenttobelocked w Thegovernmentshouldconsideropeningapublicbid out if any functional problems are detected or if processselecting, for example, two or three firms systematic calibration audits are not performed. 3 w Because of the inherent weaknesses of the test publish on the Internet all the test results and protocols that can be used in roadside checks of accompanying databases within a well-defined emissionlevelslackofacceptablereproducibilityand timeframe would not only help in the supervision of the the complexity of adequately supervising their local authorities, but also ensure that the central operationroadside inspection should be phased out government and others can utilize the data collected in a for the most part except as a screening tool to identify pro-active manner. gross smoke emitters and send them to test centers. w It is recommended that a central agency be made responsible for developing and maintaining one The role of government software package (for data transfer, QA/AC, remote w Government must be willing and able to invest the auditing and test operation) for all the test centers and resources, staff and effort in auditing and supervising for all makes of equipment. the program to improve significantly its objectivity and w Local authorities monitoring test centers have been transparency. A small number of multi-lane centers found to engage in fraudulent activities in other in the hands of a few companies are much easier to countries. Therefore, there should be some measure supervise than a large number of small test centers of supervision and compliance for the local enforcing with diverse owners. authority.Governmentshouldseriouslyconsidermaking w Unduly strict standards that generate socially use of remote auditing to distance their staff from the unacceptable failure rates, coupled with lax program temptation of turning a blind eye to fraudulent practices supervision and enforcement, openly invite vehicle in exchange for financial gain. owners to obtain the certificate fraudulently. It is w There should be a legal framework for applying advisable to set emission standards for in-use vehicles penalties to test centers found in violation of test that are achievable, with some effort, by a majority of protocols or engaging in fraudulent practices. vehicles,evenifinitiallythesestandardsmayberelatively w As the enforcement of emission standards for in-use lenient. They can then be tightened over a period of vehicles is strengthened, the black-market value of valid time until the standards that are required to generate the certificates will increase and owners of polluting vehicle desired air quality improvement are finally established. will find new ways of getting around the inspection w Updating the vehicle population database is one of system. Government should be prepared for vehicle the critical steps in making the vehicle-testing program owners' response to increasingly stricter enforcement more effective. and be willing to change test procedures and security w Government should ensure that calibration audits are features frequently to keep one step ahead. performed by independent accredited materials References standard laboratories on each test lane, once every three months at PUC and once a month at I&C centers. 1. M.KojimaandR.Bacon.2001."EmissionControl:Privatizing w There should be a readily identifiable indication of Vehicle Inspection and Reducing Fraud in Mexico compliance by giving the PUC sticker the legal status of City." Viewpoint 238, September. Available at . anofficialdocumentandimprovingthePUCstickerdesign, making its validity readily identifiable by enforcement 2. Asif Faiz, C.S. Weaver and M.P. Walsh. 1996. Air Pollution from Motor Vehicles: Standards and Technologies for officers. Printing and administering pass certificates and Controlling Emissions. World Bank. See Chapter 4. stickers should be brought under central control. 3. John Rogers. 2002. Assessment of the Pollution Under w Computerizeddataentryandtheadoptionofcentralized Control Program in India and Recommendations for databases enable timely collection of the data required Improvement, prepared for the World Bank, October. for the supervision process and for statistical analysis. Available at . The central government should define the database 4. South Asia Urban Air Quality Management Briefing structure and auxiliary tables so that consistent Note No. 10. 2002. "Tackling Emissions from information is produced across all test centers and state In-Use Diesel Vehicles," November. Available at programs. Legally requiring the local authorities to . This briefing note was prepared in November 2002 as part of the South Asia program on urban air quality management, funded in part by the joint UNDP/World Bank Energy Sector Management Assistance Program (ESMAP). The objective of the program is to support the region-wide process of developing and adopting cost-effective and viable policies and efficient enforcement mechanisms to reverse the deteriorating trend in urban air. A full set of briefs and other materials are available at . For further information, contact Sameer Akbar (sakbar@worldbank.org) or Masami Kojima (mkojima@worldbank.org) about this program, and John Rogers (jrogers@trafalgar-mexico.com) about this note. 4