June 2, 2004
Leonard R. Trimlett
EMAIL: [email protected]

Mark Carlock
California Air Resources Board
9528 Telstar Ave.
El Monte, CA 91731-2908
(626)575-6608
FAX: (626) 459-4343
Email: [email protected]

Subject: Extended Letter on Test-Only

Dear Mark,

Once I get started researching an issue, the questions never quit. I am trying to validate the perceived-flawed-process by which I was sent to test-only. It doesn�t compute.

DIFFERENCE BETWEEN TEST-ONLY & TEST&REPAIR STATIONS

• Your words were that the failure rate at the �Test-Only� stations was 25% vs. 9% at �Test &Repair��Can you identify what emission system failures you are picking up in �test-only� that you are not picking up in �test & repair� and why? The difference between 9% and 25% is very significant. It must have some pattern.
• Page 1 paragraph 1 of the Radian Report of October 1997 on the High Emitter Profile says �target high emitters and require that they be inspected at closely scrutinized inspection facilities. How does scrutinization of vehicles differ between �Test-Only� and �Test & Repair� stations? Is there a difference in cut points between �Test-Only� and �Test & Repair�?
• It is my recollection that my 1990 chevy G20 van has a good history of passing its smog checks. At the smog check prior to the last one (about two years ago), I did a tune-up as part of the smog check. In approximately October 2003 I had a catastrophic engine failure resulting from loss of two bolts holding the serpentine belts in place. I ended up replacing the engine with a new long block at 175000 miles
• In January I received a notice to go to Test-Only for my smogcheck. I did and the car passed. As a result of that experience I raise the following issues in an attempt to understand why I was denied the choice to go to my favorite mechanic for a routine smog check.
  • What difference in scrutiny of a vehicle emission system exists between �Test-Only� and �Test and Repair�? In my case (I was watching) I saw none.
  • What emission system failure modes are being identified at �Test-Only� that are not being identified at �Test&Repair� and why? What in the process identifies them? Is there any difference in cutpoints between �Test-Only� and �Test & Repair�?
  • Contrary to claims I have heard, the measure of performance of the Smog Check program is not the number of cars failed but the number of �Tons/Day� of pollutants prevented from getting into the air through improperly functioning emission systems. Therefore I would underscore �b� above and add �If indeed you are finding �emission system failures� in �test-only� that you are not finding in �test & repair� �.. What are you doing to make that known to the consumer required to repair the vehicle who must pay the bill for your �EXPERIMENTATION� on the public.
  • How many �Tons/Day� of pollutants has �Test-Only� (absent the test and repair stations who fix the vehicles) removed from the air? I believe that number would be ZERO!!!!!

STATISTICS TO SUPPORT CONTINUED �TEST-ONLY� EXPERIMENTATION ON PUBLIC

Statistics I believe you have available:

1. Vehicles Directed through DMV registration to go to a �Test-Only� station for smog check (HEP results)
2. Smog check results at �Test-Only� stations
3. Smog check results at �Test & Repair� stations
4. Smog check results at �Gold Shield� stations
5. Pretests that were run

Questions I have Based On Those Statistics

1. I did an exercise for myself based on Quarterly Statistics from the BAR Reporter (Statistics were from the July 2002 to September 2002 time frame). Parameters were as follows:
   • I assumed a California fleet of 32.5 million vehicles
   • I assumed 1-4 year old vehicles 18% of the California Fleet
   • I assumed 5-6 year old vehicles 13% of the California Fleet
   • I assumed pre-74s as 500000
   • I assumed clean screening at 15% of the California Fleet
   • Then I took those numbers and calculated the percentage of the fleet going to test only at 28%.
   • The four percentages I got were 47.05% (test & repair), 28.16% (test-only), 15.86% (Gold Shield Guaranteed Repair) and 8.93% (Gross Polluter Certification).
   • I will make this spreadsheet available to you if you would like it.
2. Based on that spreadsheet and reading the Radian �High Emitter Profile� Report, I wish to raise some additional questions.
   • I believe the Health & Safety Code says 2% random and 13% based on the �High Emitter Profile� are to go to test-only. The 28% is much higher than what Health & Safety Code Requires. I recognize that people who voluntarily go to test-only skew that number.
   • What I would like to know for any recent Quarter is the following:
     1. What percentage of vehicles directed to �test-only� got an official pre-test before going to test only?
     2. What percentage of fleet vehicles were directed to test only?
     3. What percentage of directed vehicles actually went through test-only?
     4. What percentage of test-only vehicles were volunteers?
     5. What percentage of those directed to test-only are NO-SHOWS? Is there any follow-up or follow-up data?
     6. What percentage of vehicles directed to �Test-Only� never got a final certification?
     7. What percentage of vehicles went from �Test-Only� to �Test & Repair� then back to �Test-Only� because �Test & Repair� can�t certify the repair? i.e. paid for 3 smog checks to get one�.That is Ping-Pong!!!!
     8. What percentage of vehicles went from �Test-Only� to �Gold Shield�? i.e. they paid for two smog checks to get one�.Again, double dipping.

HEP Comments Based on the Radian Report

• The HEP Model as discussed in the Radian Report 1997 appears to weigh heavily on why I was sent to �Test-Only�
• I quote from page 8 last paragraph �The standards for each individual vehicle (based on model year) were not taken into account in this calculation, because the goal of the model was to target High Emitters of Total HC and NOx . Conceptually, this reflects the idea that an older vehicle should not necessarily be expected to contribute more total emissions to the airshed than a new vehicle. An older vehicle could have smaller grams/year than a new vehicle by being driven fewer miles per year, even if it has more emissions per mile. Of course, many older vehicles are gross polluters and, despite lower annual vehicle miles traveled, should still be targeted for inspection. The categorization technique used by Radian would target these vehicles.� � ��THIS IS A VERY DANGEROUS STATEMENT TO MAKE.
• We both know that advancements in �Emission System Design� between 1970 and 2004(catalytic converter, unleaded gas, fuel injection, OBDI, OBDII, engine operating temperature have made new vehicles very clean relative to earlier models. It is my opinion that there is no way an older vehicle is going to be able to match the emission cut points of a new vehicle�Nor should it!!!! Nor can cut points be ignored. You can�t force an old car to meet new car limits. That is potential Class Action Lawsuit Material!!!!
• I also quote from the fourth conclusion on page 28. �The performance of the HEP will be significantly enhanced when data are available on large numbers of loaded-mode tests on California Vehicles.� That data should be available now�
• I also quote from page 1 paragraph 1 of the Radian Report �This is the fundamental theme of the California Smog Check Program � target High Emitters and require that they be inspected at closely scrutinized inspection facilities.
• I see no difference in the scrutinization that my van got from my regular mechanic and that which my van got at test-only. Yet I see in the above statement from page 8 the implication that because my van is an older vehicle (high mileage � 175K) it got sent to test-only.
• I recognize that the HEP model has changed since the Radian Report so I ask the question �What are the primary elements (in the current HEP) that govern the selection algorithm in the High Emitter Profile?� My Chevy 350 V8 van certainly does not have a pattern of Emission System Failure. It does have 175000 miles.
• Does the EMFAC2000 model make any assumption that an old car should put out no more pollution than a new car? I ask this question because it seems that the CARB evaluation blames old cars for most of the pollution(annual inspection and tighter cutpoints recommendations). There are statutory limits to how tight the cut points can be pushed.

Please help me with any input you can provide.

Thank You,

__________________
Leonard R. Trimlett

Cc: California Inspection & 
    Maintenance Review Committee