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January, 2004

Changes In Bay Area Smog Laws Are Drastic
By Einar Dale

 

    The Bay Area is undergoing some drastic changes in its smog regulations. It is becoming an enhanced smog area, like Los Angeles and Sacramento. The air quality here is actually better than other enhanced areas, not because our cars are cleaner, but because we have less of the air inversion that plagues other locations in California. The California Assembly mandated the changes because people in the Central Valley have complained and filed lawsuits arguing, with some justification, that fumes from the Bay Area substantially contribute to Central Valley smog problems. Eastern Marin County is becoming an enhanced smog area. The following locations will retain their basic smog area status: Bolinas, Dillon Beach, Forest Knolls, Inverness, Lagunitas, Marshall, Nicasio, Olema, Pt. Reyes Station, San Geronimo, Stinson Beach, and Tomales.  

    The transition to enhanced area is coming in phases. The first phase began July 1, 2003. As of that date all smog stations in the affected area that have not purchased new equipment ceased doing smog inspections. July 1 also marked the beginning of the OBDII functional check as part of the smog inspection.

   OBD stands for on-board diagnostics. On-board diagnostics have been around since 1979.  When the computer in the car detects a malfunction, a diagnostic trouble code (DTC) is set and the malfunction indicator light (MIL) comes on. On newer vehicles, the MIL may read "Check Engine," "Service Engine Soon," or consist of a yellow icon that is supposed to look like an engine. It has always been illegal for a smog technician to pass a car when the MIL stays on. It has sometimes happened, however, that the customer has been able to cajole, intimidate, seduce, or bribe the smog technician into overlooking the MIL.

    OBDII differs from earlier on-board diagnostics by being more comprehensive and more standardized. With a single diagnostic connector and generic software, a scan tool can pull a DTC from any vehicle 1996 or later. The new smog machines are equipped with this scan tool capability. The technician plugs in the connector, and the vehicle's computer communicates with the smog machine's computer. If a DTC is found, the vehicle fails the test. The smog technician is pretty much out of the loop. Vehicle owners need to get used to the idea that a vehicle will not pass the smog test if the MIL is not working the way it is supposed to work.  

   It sometimes happens that a new car owner notes that the MIL is on, takes the car to the dealer, and is told that there is really nothing wrong with the car. If such an experience happens to you, you've been had. If the MIL is on all the time, there is a malfunction with the car, and it is the dealer's responsibility to fix the car under warranty. If you let the problem slide, the car will fail the smog test. By that time the car is off warranty, and you'll have to pay for the repair out of pocket.

   A tactic to get cars through the smog test, especially popular with used car salesmen, is to clear the DTC immediately before the smog test. With the OBDII functional test, this tactic will not work. The OBDII computer monitors for engine misfire, monitors the fuel system, monitors the various sensors, and monitors many of the add-on emission components. The generic scan tool can tell if any of the self-tests the car computer is designed to perform have been completed. An incomplete sel-test is called an incomplete monitor. The vehicle will not pass the OBDII functional test if there are too many incomplete monitors. When a DTC is cleared with a scan tool or by disconnecting the battery, all of the monitors are made incomplete. Many of the monitors will be completed after a few minutes of operation, but some monitors will not be completed until after a substantial amount of driving. If one merely clears a DTC without fixing the problem, the DTC will probably return about the same time as enough monitors have run to successfully complete a smog test. We are supposed to repair the malfunctions, not merely clear the codes. The OBDII functional test will be required in basic areas as of January 1, 2004.

   On October 1, the Bay Area began dynamometer testing and the direct measurement of NOx emissions. NOx emissions are various compounds of nitrogen and oxygen formed in the high pressure, high temperature conditions of the gasoline engine combustion chamber. NOx emissions are significant factor in the formation of smog and of acid rain. Directly testing NOx emissions provides a new way for a vehicle to fail the smog test and a new way to be tagged as a gross polluter. The standards for NOx emissions are still more lenient in the Bay Area than in other enhanced areas. Nox standards will gradually be toughened until they are the same as those for Los Angeles.

    Some vehicles that will fail the no-load test will pass the dyno test, and vice versa. Overall, the failure rate is somewhat higher on the dyno test. It is also harder to fudge the results on a dyno test, and an effective pre-test is more labor-intensive and expensive on the dyno test. There tends to be more gross polluters on the dyno test.

   Fortunately, the certification of gross polluters is not as difficult as it used to be. The intractable state-run referee no longer certifies gross polluters. Gross polluters are certified by test-only stations and by gold-shield stations. When I have sent a smog-legal car to a gold-shield station, it has come back with a smog certificate.

    It is arguable that a more stringent, more tamper-proof, smog test, while inconvenient to some, benefits us all by improving air quality. It is also arguable that the dyno test exacerbates the substantial injustice of the smog-check program. Neither the dyno test nor the no-load test measures how much a vehicle pollutes. Neither test even measures conformity to EPA standards. EPA standards are set in grams per mile. The smog test measures parts per million. The smog test measures the concentration of pollutants in the exhaust, not how much pollution is coming out of the tailpipe. If a big SUV and a subcompact both have 80 ppm hydrocarbons in the exhaust gas, but the SUV is burning gas at twice the rate, the SUV's hydrocarbon emissions, in grams per mile, are twice as much as for the subcompact. Many subcompacts that fail the smog test are putting out fewer grams per mile of pollution than SUVs that pass the test.

    The total amount of pollutants emitted by a vehicle in a year is roughly equal to the concentration of pollutants in the exhaust times the rate of fuel consumption times the number of miles driven. The smog check program does not care what kind of gas guzzler you own or how many miles you drive it, as long as you keep your pollutant concentrations in line. When all factors are considered, the poor tend to pollute less than the rich, yet the smog check program comes down hardest on the poor. The dyno test exacerbates the injustice by testing small engines under speed and load conditions suitable only for big torque motors. The owner's manual for my Toyota Corolla recommends that, for economical driving, I keep the engine speed between 2000 and 4000 RPM. If I try to run the 15 MPH portion of the dyno test in 1st gear, the engine speed will be about 3100 RPM, near the middle of the recommended driving range. Yet the smog machine will abort the test for "speed violation" if I go over 3000 RPM on the test. I must shift to 2nd gear and lug the car through the 15 MPH portion of the test at 1800 RPM. Lugging small cars through the dyno test artificially increases their NOx emissions.

   Burning less gas decreases carbon monoxide, hydrocarbon, and NOx emissions just as effectively as burning gas cleaner. Burning less gas also decreases carbon dioxide emissions. The smog check program does little about carbon dioxide emissions. In fact, as hydrocarbon and carbon monoxide emission failures are repaired, the carbon dioxide readings inevitably go up. While carbon dioxide is preferable to hydrocarbons or carbon monoxide, greenhouse gasses are an environmental concern.

    There are in the California legislature multiple "greenhouse gas" bills. One AB1493, requires that CARB address the problem of vehicle greenhouse gas emissions, but severely restricts the way CARB can act. CARB is not allowed to ban SUVs , raise gasoline taxes, limit vehicle weight, or limit miles driven. In short, CARB is not allowed to do anything that might offend the petroleum or automotive industries. The development of fuel cell technology as an environmentally responsible, cost-effective means of powering vehicles may yet prove to be as illusive as the discovery of Iraqi weapons of mass destruction. Thus far, the primary effect of the technology has been to lull people into believing that nothing needs to be done to reduce greenhouse gasses in the present.

    If you happen to be identified as the owner of a "gross polluter," by all means address the issue rationally, but do not take the nasty name too personally. The whole country is a gross polluter. You are just a scapegoat.

   Einar Dale is a regular reader of the Coastal Post and a licensed smog technician since 1979. He currently lives and works in San Rafael.

 

 

 

 

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