By Robert L. Redding, Jr.
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The EPA is nearing the end of its rulemaking process regarding I/M programs and OBD. ASA has asked the EPA to address several OBD-related issues and the aftermarket should follow it closely.
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The on-board diagnostics (OBD) system has become an essential tool for the automotive repair industry. This has been highlighted by the aftermarket's most important focus, information availability. What has not received as much attention in the past few years has been the impact on emissions testing. For too long after the 1990 Clean Air Act Amendments the industry debated centralized vs. decentralized testing.
The recent U.S. Environmental Protection Agency (EPA) proposed rule regarding Amendments to Vehicle Inspection Maintenance Program Requirements Incorporating the Onboard Diagnostic Check has sparked discussions about the role of new car dealers and how traditional forms of emissions testing will fit as newer vehicles with high-tech emissions systems emerge.
First, let's look at what has been touted as a potential conflict of interest. Twenty environmental and public health organizations signed a letter describing a conflict in having automobile manufacturer-affiliated dealers perform OBD checks. The implication is that manufacturers design and certify their OBD systems, and because the performance of emissions controls is monitored by those systems, there is a conflict of interest in permitting dealers to play a role in the inspection and maintenance (I/M) program by conducting OBD checks.
Note that automobile manufacturers have on numerous occasions engaged in violations of the Clean Air Act, particularly as it relates to emissions controls. To recount some examples that implicated OBD systems, one manufacturer reprogrammed its OBD systems to minimize malfunction indication lamp (MIL) illuminations under certain scenarios. Another manufacturer performed similar acts in the production of its heavy-duty diesel engine. Sources predict the EPA will soon take additional enforcement action against another major automobile manufacturer because its OBD system does not monitor the catalytic converter.
The EPA did not address the conflict of interest issue in its proposed rule on OBD emissions testing. The Automotive Service Association (ASA) hopes that the final rule will include some recognition of the problems that are clearly implied, for the consumer, by allowing the manufacturers of these systems to inspect and maintain them. The independent aftermarket offers a system of checks and balances through the inspection and maintenance process. This needs to be recognized by the EPA in this rulemaking process. In the new OBD environment, the incentive to cheat is so great that OBD checks should only be performed by facilities not affiliated with the manufacturers.
ASA asked the EPA to address several other OBD testing-related issues. This included a request to extend the implementation of mandatory OBD checks at least 12 months, and preferably, 24 months. While the voluntary adoption by states of OBD testing may still take place next year, the mandatory start should be extended to Jan. 1, 2003. The purpose of this delay is to accumulate sufficient data to resolve the substantial environmental and administrative uncertainties.
ASA, in formal comments, also encouraged the EPA to take the next two years to continue its public relations campaign for OBD. There has not been adequate public education, which is reflected in the media. There is a fundamental misunderstanding about the addition of OBD to I/M programs.
The EPA must emphasize that traditional tailpipe tests are still the most appropriate test for pre-1996 vehicles. They should also coordinate with states to provide better public education, particularly with respect to the meaning of the MIL.
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“ASA does not believe that drivers should be encouraged to ignore any malfunction indication lamp illumination.” |
ASA supports the expansion of the failure criteria to include all diagnostic trouble codes (DTCs) because it simplifies program administration and supports the over-arching goal of promoting driver response to the MIL. If these codes are ignored, then the MIL illumination could mask other DTCs that subsequently arise. ASA does not believe that drivers should be encouraged to ignore any malfunction indication lamp illumination. For this reason, ASA supports the elimination of the repair waiver under OBD. Once a repair is not required, the MIL on becomes a fixture in the vehicle, and would mask other problems that develop as well as degrade the driver's inclination to respond to the MIL by seeking an effective repair.
In the proposed rule, the EPA is silent on the issue of eliminating the model-year exemptions or low emitter profiling. ASA supports the elimination of these exemptions because we believe they send the wrong message to drivers. If a driver is excused from the I/M program for the first three, four, or more years of a vehicle's life, he or she may not have developed the beneficial practice of responding to the MIL. In addition, it is likely that the first I/M test will occur after the main part of the vehicle's emissions warranty has expired. By eliminating the exemptions, and subjecting the vehicles to inspections during the warranty period, the EPA will ensure that these vehicles enter the post-warranty period with properly functioning emissions control systems.
New car exemptions raise environmental justice issues, but have been accepted because of the low failure rates and the fact that the exemptions cut down on the total number of vehicles needing tests, resulting in shorter waiting periods for the test. Under the OBD, the check can take less than a minute. Given the fact that the burden of testing under OBD is dramatically less than it is under traditional tailpipe tests, there is less of a reason to exempt these cars.
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“The EPA should take steps, in cooperation with all insterested stakeholders, to ensure that drivers learn to respond appropriately to the MIL.” |
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The EPA should take steps, in cooperation with all interested stakeholders, to ensure that drivers learn to respond appropriately to the MIL. There is still much confusion as to the meaning of the light amongst the motoring public. By requiring cars to be inspected annually or biannually, the Clean Air Act Amendments promote increased responsiveness to emissions-related problems. However, with OBD being as sensitive as it is, there may be cases where the driver's response should be tempered somewhat. The EPA's Technical Support Document notes that about 32 percent of vehicles that had an MIL on had no repairable malfunction or the MIL self-cleared. This could eventually reflect negatively on both the repair facilities as well as the testing program itself.
A broad public education campaign is one possible way to counter this from happening. This will not necessarily reduce the occurrence of these types of false failures, only help the public be more accepting of them. Another possibility would be to redesign OBD to track the number of miles (or time) since the MIL illuminated, and trigger a failure only if a certain number of miles have been accumulated since the illumination. A third possibility would be to give the owner of the vehicle a certain period of time to effect the repair, in view of the possibility that the problem would self-clear.
OBD's durability has not been verified. To the extent that the OBD's useful life is not at least as long as the useful life of the vehicle, there will be a need for tailpipe tests during the vehicle's sunset years. What no one knows at this time is when that would occur. After six, seven or eight years? Indeed, because the vehicles will be much dirtier once they age beyond a certain point, it would be logical and would make good environmental sense to ensure that all of the excess repairable emissions associated with them are promptly identified and repaired.
Repairers receiving assurances that the EPA properly polices automotive manufacturers, to ensure service information is made available, is a necessity. The EPA must continue its data gathering, to determine what impact real-life aging has on OBD system performance. Should OBD prove to be unreliable in the long-term, the EPA should reserve the option to drop OBD checks on aged vehicles in favor of the traditional tailpipe test.
The EPA is nearing the end of this particular rulemaking process. The aftermarket should follow it closely.
