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The initial ICCT India team webinar on India's vehicle emissions and fuels policies, broadcast April 26, was well received. We had a little trouble with recording the webinar, so we can't make the audio available, but the presentation is embedded below, and can also be downloaded here. (If you'd like to be informed of future webinars in the series, sign up to our mailing list.)
Our purpose in producing these webinars is partly to foster conversation. One question during the webinar, concerning our outline of India's conformity of production measures (slide 15), led to a helpful exchange, worth summarizing here.
The initial question was directed at our statement that "manufacturers are advised on COP testing." The commenter noted that "in our case a third party Test Agency comes to our plant and picks up vehicles at random from our stock area and asks for them to be tested," which seems contradictory.
The confusion stemmed in part from imprecise language. While vehicle selection for COP is random in India, manufacturers learn in advance when and from which facility vehicles will be selected (as described in more detail on the ARAI website here). This differs from US practice, where the EPA can select vehicles at any time from any facility.
In an exchange of e-mail after the webinar, the commenter followed up with this clarification:
Based on our experience, I think our system is more stringent than the European system. Europe follows a self certification system. Manufacturers internal data on COP is provided to the agency for compliance.
In our case, it is a fact that the date of arrival of agency is pre decided to take care of the facility availability for testing etc. It should not be misconstrued as some kind of a relaxation.
In case of vehicles produced in our plants, we make vehicles of each type every day. Except AT vehicles which are very low in demand. So a test agency person can easily go on to the off line storage area and pick vehicles at random.
In case of imported vehicles, since there is a very less no of vehicles that are imported in a batch, it could be considered as a lot. However I would say that it should be treated as an exception as it could be one or two models in our case out of 15 or 16 models that we make. The same cannot be generalized.
Europe has indeed not been at the forefront of compliance and enforcement activities in general, despite having tough emission standards. That is why we compare compliance and enforcement in India to the US in our presentations and reports. The US has the most extensive and experienced compliance and enforcement program.
The US initially (before the late 1970s) had a program based largely on testing of prototypes and pre-production vehicles, much like India has today. This program was successful for the most part, but the EPA found that some models were still being produced that didn't meet emission standards. That led to the Selective Enforcement Auditing (SEA) program, which started random and surprise inspections of new vehicles without any prior notice or intimation. The SEA program identified many problematic vehicles, which were rectified over time. As manufacturers compliance with the SEA program became more consistent, the EPA moved to manufacturer conducted in-use testing under the IUVP and IUCP programs.
While the SEA is not generally conducted for LDVs these days, the EPA reserves the right to use it if necessary. The SEA program is still actively used for HDV compliance testing. Furthermore, the EPA still conducts randomized surveillance testing of in-use vehicles to verify manufacturer supplied IUVP and IUCP data.
China, too, has recently began conducting randomized testing of two- and three-wheelers without prior notice to manufacturers as to when and from where the vehicles will be selected. While the majority of vehicles pass tests, a number of problems have been identified.
So our representation of COP testing in India was not intended to be entirely critical of the system. There are key successes to COP in India. But the system, as well as industry, stand to gain by learning from international best practices (particularly those of the US).