Smoke and Mirrors
Air pollution has emerged as the fifth largest killer in India and vehicles are responsible for very high exposures to toxic pollution in cities.
One of the biggest corporate frauds in the global automobile industry – the Volkswagen defeat device case -- and the mounting evidences from Europe that most new diesel cars are emitting much higher than their certification levels, have gone nearly unnoticed in India. Even though Volkswagen cars have been found to be erring, there is no official action; nor is there any attempt to ensure that other models do not emit more than their certification levels.
This exposes a serious weakness in our emissions regulations that compromise emissions performance of vehicles. This makes India extremely vulnerable as it is rapidly motorising and dieselising without a strong compliance framework. Even China has gone ahead to recall 2.0 litre Volkswagen diesel cars.
Without a robust system of emissions monitoring and compliance, the investments in emission control systems in vehicles to meet tighter standards can go waste and negate air pollution control efforts in our cities.
Centre for Science and Environment (CSE) would strongly urge for urgent steps to upgrade the current in-use emissions testing, prepare for real driving emissions testing with portable emissions monitoring systems for Euro VI vehicles and make vehicle manufacturers liable and accountable for emissions performance of the vehicles during their useful life on the road.
The current practice of pollution under control programme (PUC) is rudimentary and ineffective. It is not designed to address complex emissions control systems in new vehicles. This cannot screen inherent technical flaws and frauds for which manufacturers are responsible that compromise the emissions performance in the real world.
The PUC system, the only system to check emissions from on-road vehicles in India is extremely weak in terms of lax norms, poor enforcement and poor quality test procedures. New data from the Delhi Transport Department shows that failure rate is as dismal as 5 per cent -- nearly all vehicles pass the test. There is no data, however, on how many vehicles show up for test.
The PUC norms for on-road vehicles are extremely lax for the older pre-Bharat Stage IV vehicles. While under PUC, petrol cars are tested for carbon monoxide and hydrocarbons along with lambda (that indicates the optimum condition needed for proper functioning of catalytic converters), diesel vehicles are tested only for smoke density. While all norms are lax, those for on-road diesel vehicles are particularly lenient -- smoke density norms are 50 HSU only for the Bharat Stage IV-compliant diesel vehicles. For pre-BS-IV vehicles, the norm is as lax as 65 HSU.
The Supreme Court has recently given directions to the EPCA to audit all the 614 PUC stations. There are serious concerns over quality and credibility of PUC tests across the cities. In fact, a detailed audit that was carried out by the Central Pollution Control Board in 2013 in 76 PUC centres exposed serious anomalies – non-compliance with the code of practice; unavailability of calibration certificate for testing instruments in several centres; poor condition of laboratory; leak test failure; and non-functioning analysers. This clearly brings out the ineffectiveness of the programme.
The smoke test was introduced in the 60s to reduce the visibility problems due to diesel smoke. There is no real correlation between smoke density and particle emissions. Smoke is not a good surrogate for tiny particles. There can be a risk of misclassifying polluters – low smoke emissions can also mean high particulate emissions. Other governments including China, Hong Kong, Singapore, the US, etc now conduct these tests on chassis dynamometer to simulate speed. This makes the emissions test more rigorous, China is further developing a nationwide I/M system for evaluating NOx emissions from in-use HDVs.
The PUC system is not even designed to test tiny particles and NOx on road – the key concerns from diesel vehicles. Volkswagen was caught cheating on NOx emissions. In fact, too much focus on reducing smoke can actually increase NOx emissions as a trade-off. But new generation diesel vehicles will come with advanced emissions control systems to reduce particulate and NOx. If these systems perform sub-optimally, there can be uncontrolled emissions.
The fact that India is totally unprepared to prevent emissions frauds and under performance of emissions control systems on roads was proved a few years ago when the Tavera fraud case of General Motors was exposed. These models passed the certification tests with one set of engines that did not the match those actually sold in the market. But this incident did not lead to any major reform to establish in-use compliance norms and monitoring in India. The Indian government does not have the power to penalise manufacturers for non-compliance and violation. This has serious implications as the next level of Euro V and Euro VI standards will require advanced particulate traps and NOx control systems like SCR to cut toxic diesel emissions. If engineering deficiency reduces the effectiveness of these systems or if these are not properly operated like urea refilling in SCR system, it can lead to uncontrolled emissions and nullify pollution control measures in our cities.
If a problem or malfunction is detected, the OBD II system illuminates a warning light on the vehicle instrument panel to alert the driver. This warning light will typically display the phrase "Check Engine" or "Service Engine Soon," and will often include an engine symbol. The OBD system stores important information about any detected malfunction so that a repair technician can accurately find and fix the problem. It is notified to monitor catalyst, fuel injection system, particulate trap, coolant temperature, EGR, fuel system, emission control systems, etc. Smog check inspections in USA for post-2000 model vehicles are now primarily based on an inspection of the OBD II system -- tailpipe testing is no longer required. It identifies emission-related components covered under warranty; eliminates unnecessary repairs; and gives information about area of malfunction or a specific component. This reduces cost of warranty repairs and ensures customer satisfaction; allows early detection of malfunctions etc. But this system will require strong surveillance and appropriate software to work effectively. In Europe, the OBD system has often failed to detect high emissions from diesel cars.
Consistent with the global best practices, India needs an independent authority to check emissions against standards; issue recall of vehicles by companies if they are found non-compliant; levy fines on defaulting companies; and withdraw approval of sale if vehicles do not conform with the stated emissions targets. An independent authority should monitor this process without being influenced by industry. Only such a system will make non-compliance with regulations more expensive for companies than compliance with regulations and ensure implementation. The Auto Fuel Policy committee has recommended an emissions warranty and recall programme and in-use compliance regulations. But this has not been implemented.
CSE’s review shows that currently, Indian certification agencies do not select vehicle samples for certification tests randomly and independently. In fact, certification agencies give prior notice to manufacturers about the approximate time during which samples will be collected from a given lot. This compromises independent and impartial testing. Legal procedures for the MoRTH to issue mandatory recalls or levy fines have not been established yet.
India will be in deep trouble if massive motorisation happens without strong compliance with emissions limits. This will enhance the public health risk.