Notes

1.According to the American Automobile Manufacturers Association, emissions and safety equipment combined are estimated to raise the average price of a new 1996 car by $3,915 (US) or $5,300 (CDN) compared to such a vehicle without the equipment.

2.In the United States, 1994 new vehicle emissions standards of 0.41gpm VOCs, 3.4 gpm CO, and 0.4 gpm NOx are only 5 percent, 4 percent, and 11 percent of the standards for pre-control vehicles before 1968.

3.This quiet but very significant advance has gone largely unnoticed. For example, at one I/M ``stakeholders'' meeting held in Toronto to ``invite your advice,'' a representative of a non-profit organization stated that she did not believe that new cars were cleaner than older cars; nobody corrected her.

4.Newer vehicles are often excused from I/M testing entirely.

5.Although I/M is promoted as being self-financing, taxpayers also contribute in numerous ways.

6.For a discussion on the validity of these claims, see Green 1995.

7.This has happened in a number of American states. For example, in Ohio some incumbents who lost the last election blamed their defeat on their support of I/M (Plain Dealer, November 13, 1996). Authorities understand that the environment cannot vote or go to the media and whatever potential environmental effectiveness there may be in an I/M program may be sacrificed to keep the cost and inconvenience within the range that consumers (who are also voters) will tolerate. To appease motorists, I/M programs offer such consumer-friendly features as fast-pass ``screening'' tests, a ``second chance'' to pass the test, and ``waivers'' that the limit the cost of repair. Such relaxation of the procedure undermines the whole environmental goal of the program because it reduces the number of vehicles that are fully repaired after being identified as producing excessive emissions.

8.For example: ``The engine and exhaust system shall be equipped and adjusted to prevent the escape of excessive fumes or smoke as compared to other motor vehicles of the same or similar types and sizes'' (British Columbia Motor Vehicle Act Regulations. Division 7, Schedule 1, s. 16). This is confirmed in the Radian ``Audit'': ``Radian does not believe it is necessary to actually measure exhaust smoke opacity since any visible smoke indicates a significant problem in a gasoline-powered engine'' (Weyn and Klausmeier 1994: 5-5). This effective enforcement may now be taking place in Ontario.

9.Sometimes referred to as hydrocarbons (HC) though, to be precise, VOCs are a subgroup of hydrocarbons.

10.This fact does not prevent the Canadian Council of Ministers of the Environment (CCME) from using it as a justification for imposing I/M: ``Ambient levels of CO are of concern in Toronto, Edmonton, Calgary, and Vancouver where CO levels have occasionally exceeded the Canadian maximum acceptable 8-hour objective of 13 ppm. However, although CO emissions are still of concern in Canada, the eight-hour Air Quality Objective has not been exceeded since 1990, and ambient CO levels have been decreasing'' (CCME 1996a: 1). GVRD 1994a: 17. The 1-hour ``acceptable'' level of 30 ppm CO has not been exceeded since 1988 (Environment Canada 1994: 26). Perhaps CO is not a problem in Canada because there is sufficient biomass to absorb it. CO tends to get in water and be converted to other compounds through natural biological action (see Griffin 1994: 81).

11.CCME 1995: 2-6. This, of course, does not mean that a further reduction in ambient levels of CO is not desirable but only that the cost of any action should be extremely low or zero.

12.Not to be confused with stratospheric ozone (the ``ozone layer'') that protects the earth from ultraviolet radiation.

13.Another standard of 80 ppb average over 8 hours has been added to the original standard of 120 ppb over one hour but, because ozone levels tend to peak at certain times of the day, this change is considered to be only minor and will have little effect on the total number of exceedence days most regions will experience. See US Federal Register 62, 138 (July 18, 1997): 38855.

14.United States Senate Committee on Public Works, National Air Quality Act of 1970, Report No. 1196 91st Cong., 2d Sess 9 (1970) in 1 Legis.Hist at 410, in Rogers 1994: 158 fn.

15.``Biogenic VOCs, in combination with anthropogenic NOx, are capable of generating ozone concentrations above 80 ppb in favorable meteorological conditions across much of the eastern United States, with values of more than 100 ppb downwind of a number of major cities. Further assessments of control strategies must include biogenic emissions, given their potential for generating ozone concentrations close to the [US 120 ppb] concentration'' (US NRC 1991: 377).

16.Perhaps certain regions in southern Ontario (such as Long Point) should be excluded since they are covered by polluted air (over which the residents have no control) from the United States.

17.Weyn and Klausmeier 1994: 2-11. The anticipated failure rate was 30 percent; the real failure rate found by Radian was 11 percent to 14 percent.

18.Waivers are, in effect, licenses to pollute issued to owners of vehicles that still cannot pass the re-test, even after spending a certain amount of money for certified repairs. Waivers can devastate the effectiveness of an I/M program. The US EPA model I/M program specifies a maximum waiver rate of 1 percent of identified vehicles (vehicles that fail the initial test) for its enhanced program (US EPA 1991a: 30).

19.In the October 1992 issue of NOx/VOC News (its motto is ``Working together for healthy air'') the Canadian Council of Ministers of the Environment (CCME) predicted that AirCare would reduce NOx by 20 percent (CCME 1992: 6). This claim was repeated two years later in the CCME's Environmental Code of Practice for Motor Vehicle Emission Inspection and Maintenance Programs (1994:2). Meanwhile, the 10 percent target still lives! On September 9, 1997, five years into a 7-year contract, the GVRD website claims: ``When fully implemented, AirCare is expected to reduce NOx emissions by 10 per cent'' (www.gvrd.bc.ca/air/bro/aqsmog.html). When exactly will AirCare be ``fully implemented''?

20.``One of the main reasons that Radian was hired to evaluate the program was because of the small sample of `before and after' test data available to calculate an emissions benefit at the time the report was needed. Since a purely scientific calculation of the benefits was not available, a firm with proven expertise in the field was hired to make an assessment of how well the program was working. Although some leaps of faith are made in the report, it was apparent to Radian that the vehicles failing the AirCare inspection almost always had lower emissions on reinspection and that the reductions often lasted into the next inspection year'' (fax from David Gourley, Manager, Emissions Testing and Standards, AirCare Program Administration, to APA President George Iny, May 24, 1996).

21.Even if they did exist, the reductions as the result of their repair would already have been counted.

22.This was only partially done in the Radian report, as can be seen by the fact that Radian reports that NOx emissions increased as a result of AirCare repairs for the group of vehicles manufactured from 1981 to 1987. In the following Technical Review of Year 3 (AirCare 1996b) use of this artful methodology was expanded.

23.I/M repairs often provide little long-term benefit, largely because they a motivated by the owner's desire to pass the test and not to improve the vehicle (see Lawson 1995). Note as well: ``there is no doubt that this [Clean for a Day] phenomenon occurs, but it is an unavoidable part of a program that only looks at a vehicle once a year'' (fax from David Gourley, Manager, Emissions Testing and Standards, AirCare Program Administration, to APA President George Iny, May 24, 1996). Considering the acknowledged day-to-day variability of individual vehicle emissions, the wide range of difference in vehicle usage patterns, and a potential for cheating, this ``unavoidable part of a program that only looks at a vehicle once a year'' (at a time chosen by the owner) is by itself a very serious, and perhaps fatal, flaw in the entire I/M strategy. How meaningful can a single I/M test score be?

24. ``Radian gave no details of the weighting factors they used but they appear to have only considered the number of vehicles and ignored the usage'' (AirCare 1996b: 4-3).

25.So, are older vehicles driven as much as newer vehicles--yes or no? According to AirCare, both yes and no. On the one hand, Radian and AirCare assume that both old and new vehicles are driven the same amount (Aircare 1996: 4-3); otherwise the emission reductions that could be claimed by AirCare would be much less. According to a paper by S.J. Stewart, AirCare Project Engineer for emissions and data analysis, AirCare data revealed that kilometres travelled ``does not drop off with age anywhere near as rapidly'' as was previously estimated and that the most significant factor in determining the aggregate distance travelled for a particular vehicle group is ``simply the number of vehicles in that group'' (Stewart 1996: 28, 32). On the other hand, in an article to justify AirCare's testing of hundreds of newer vehicles (and costing the residents of British Columbia thousands of dollars) to find each vehicle with excess emissions, David Gourley, AirCare Manager for emissions testing and standards, declares that ``[s]tatistics gathered over the first three years of testing [the same statistics used by Mr Stewart] confirm that newer vehicles are driven much further distances than older vehicles'' (AirCare Update, January 1997: 1).

26.The in-house AirCare report was ``peer reviewed'' by the writer of the Radian report (fax from David Gourley, Manager, Emissions Testing and Standards, AirCare Program Administration, to the writer, 1 August 1997).

27.That does not stop AirCare from continuing to quote those benefits.

28.These were the same 248 vehicles used in the internal Technical Review from AirCare plus 20 more that had subsequently been added to the data base by AirCare.

29.The maximum repair cost was limited to the book value of the car.

30.AirCare 1997. Response deadline was August 15, 1997. Jointly sponsored by the GVRD, British Columbia Ministry of Environment, Lands and Parks, Environment Canada, and the Insurance Corporation of British Columbia with a budget of $80,000. Note that the 3 percent target is back again.

31.CO reductions in British Columbia provide little or no significant health or environmental benefit.

32.Fax to the writer from David Gourley, Manager, Emissions Testing and Standards, AirCare Program Administration, 8 August 1997.

33.Letter from Douglas Cope to APA President George Iny, November 23, 1996.

34.Which includes the first draft of the revised code, the final version has not been released at the time of writing.

35.Compared to AirCare, where the cost of identifying each 1988 and newer vehicle with excessive emissions is $968.

36.Sponsored by Environment Canada, Ontario MOEE, Canadian Petroleum Products Institute, Automotive Industries Association of Canada, and Canadian Vehicle Manufacturers Association.

37.The total cost of I/M is rarely mentioned since I/M supporters prefer to express it as ``only $18 a year for your car'' or something like that.

38.As they frequently are, for example in Let's Clear the Air: 7-17.

39.Some emission control system components are also components of the vehicle operating system, so it is difficult to precisely apportion, for example, the cost of the fuel injection system to emissions control or to another purpose. At vehicle emissions conferences, the figure of $1,800 (US) has been used as an estimate. The American Automobile Manufacturers Association claims that an average of $3,915 (US) or $5,300 (Can) of the price of a new vehicle is attributable to the combined cost of emissions control and safety features.

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