Vehicle Inspection

DEQ is aware there are many questions surrounding the recent Notice of Violation that the Environmental Protection Agency issued to Volkswagen. While the violation is a national EPA and auto manufacturing issue, Oregon locally operates Low Emission Vehicle and Vehicle Inspection programs. DEQ will update these questions and answers as we learn more. Some of the answers provided are from EPA’s website.
The test is referred to as the Federal Test Procedure which is a pre-market test. When any vehicle is manufactured for sale in the U.S., the EPA and California Air Resources Board require a comprehensive emissions test. Instead of testing millions of cars, EPA and CARB test a representative sample of vehicle fleets. These comprehensive certification tests are conducted in a laboratory setting with a probe measuring tailpipe emissions at various speeds and loads using a dynamometer (think of a treadmill for cars).
All vehicle emission systems are made up of multiple components that are always on to help control and minimize various pollutants. This is true of Volkswagen except for one component that’s turned off. In order to pass the test, Volkswagen’s software temporarily turns on that single component only during the Federal Test Procedure. For all other driving conditions, that single component is left off.
​The component that reduces Nitrogen Oxides (NOx) is off in these Volkswagen vehicles.
​NOx emission levels are 10 to 40 times higher than emission standards.
​NOx pollution contributes to nitrogen dioxide, ground-level ozone, and fine particulate matter. Exposure to these pollutants has been linked with a range of serious health effects, including increased asthma attacks and other respiratory illnesses that can be serious enough to send people to the hospital. Exposure to ozone and particulate matter has also been associated with premature death due to respiratory-related or cardiovascular-related effects. Children, the elderly and people with pre-existing respiratory disease are particularly at risk for health effects of these pollutants.
​In 2013, a clean-air advocacy group, The International Council on Clean Transportation, conducted independent testing in partnership with West Virginia University. They studied diesel emissions in BMW and Volkswagen vehicles under real roadway conditions. In 2014, they alerted the California Air Resources Board and EPA about the excessive NOx emissions they discovered with some of Volkswagen’s vehicles. The discovery was not shared with other agencies, like DEQ, until this month.
​On Sept. 18, 2015, the EPA issued a Notice of Violation to Volkswagen and expects the auto manufacturer to issue a recall of all the vehicles to correct the problem.  Volkswagen also has stopped selling any of these vehicles until this issue resolved.
​Depending on the complexity of the repair, it could take up to one year to issue recall notices. The notice will come from Volkswagen. It will provide you with information about the recall and with instructions about how to get your car repaired at no cost to you.
​Jetta 2009-15, Jetta Sportwagen 2009-14, Beetle 2012-15, Beetle Convertible 2012-15, Audi A3 2010-15, Golf 2010-15, Golf Sportwagen 2015, Passat 2012-15.
​Owners of cars of these models and years do not need to take any action at this time.  EPA’s Notice of Violation announcement makes it clear these Volkswagen cars are safe and remain legal to drive and resell.
​No states’ (or professional mechanics’) onboard diagnostic equipment would catch this fraud. It took a special study using real driving conditions to catch it.

Volkswagen’s software ensured that NOx emissions were within required limits during the federal test so EPA and CARB certified the vehicles. At all other times Volkswagen’s software ensures the NOx control component is turned off. Normally the vehicle’s computer would relay via the states’ onboard diagnostic test that the NOx control component isn’t working as certified and the vehicle would fail the test. However, for these Volkswagen vehicles, whenever the onboard diagnostic port is plugged into by a state inspector (or a mechanic), the NOx control component appears to be operating as certified.
​No, your last inspection is still valid. The fix will be accomplished with the vehicle recall.  Until that time, EPA’s Notice of Violation announcement makes it clear these Volkswagen cars are safe, remain legal to drive, and do not require any action at this time. This means the timing of your DEQ inspection will not change. It remains connected with your normal vehicle registration renewal process when your license plate tags expire.
​As recalled vehicles are repaired across the entire state of Oregon, they will receive a certification sticker. For those vehicles registered within DEQ’s test boundaries (Medford and Portland), DEQ will confirm the presence of the certification sticker as part of the test. This means the timing of your DEQ inspection will not change. It remains connected with your normal vehicle registration renewal process when your license plate tags expire. For vehicles outside the test boundaries, it has not been determined how certification stickers on vehicles will be confirmed.
​No. Instead, EPA has changed its national Federal Test Procedure so it’s no longer predictable for auto manufacturers to circumvent. It will now include a random dynamometer drive cycle. A random drive cycle was used to discover and confirm that Volkswagen’s NOx control component was not meeting the standard.
​The onboard diagnostics plug-in test that states conduct is considered the most efficient, beneficial and cost-effective test for the millions of cars tested. To run a test like EPA does for original certification on dynamometers on every motorist’s car would take several days for each vehicle and cost thousands of dollars per test. Also, for this Volkswagen NOx fraud, testing on a dynamometer didn’t work for the Federal Test Procedure, so it would not work at a DEQ Clean Air Station either. And probing the vehicle without the vehicle under a loaded condition (dynamometer) would not produce enough NOx to fail the test.
​The Federal Test Procedure is a national certification test performed in a laboratory setting with a probe measuring actual tailpipe emissions at various speeds and loads using a dynamometer. When a vehicle is certified it includes certification of the vehicle’s onboard diagnostic system. Instead of testing every car, EPA and CARB test a representative sample of the fleet. Once certified, then they can be sold in the U.S.

States like Oregon, conduct an onboard diagnostic test by plugging into a vehicle’s onboard computer. This test does not look directly at emission levels, it looks at what the vehicle tells us about how well emission components are operating; components that help with NOx reduction, oxygen sensors, catalytic converters, etc. These tests are periodic (every two years in Oregon) and are conducted on every car registered within DEQ’s inspection boundary.
​Yes. The Federal Test Procedure sets the original certification emissions standard and the onboard diagnostic test periodically ensures that standard is maintained throughout its life. In fact, when a vehicle is Federal Test Procedure certified, it includes certification of the onboard diagnostic test system. All combustion engine vehicles cause air pollution, even as they come fresh off the assembly line. The Federal Test Procedure immediately ensures they do not pollute excessively over certain standards. The Federal Test Procedure requires manufacturing changes at the outset, when vehicles do not pass the national certification test.

After Federal Test Procedure certification, when states’ periodic onboard diagnostic tests identify that a vehicle’s emission components are no longer working properly, then higher emissions are being produced than the Federal Test Procedure originally certified for that vehicle. The onboard diagnostic test requirement helps ensure that vehicles are properly maintained as they age so they do not pollute excessively.
​In the last year (September, 2014 through August, 2015), DEQ tested 666 of these Volkswagen diesel vehicles. This represents one-tenth of one percent of all the 529,957 vehicles tested during the year. Of the 666 Volkswagen vehicles, 23 failed DEQ’s test for improperly functioning emission control components.
​Remember, Volkswagen’s software only tampered with one control component; for NOx. There are multiple emission control systems that states, like Oregon, test besides NOx. The other components help reduce hydrocarbons, particulate matter, carbon monoxide, air toxics, etc.  The below chart shows the maximum limits for each pollutant under the Federal Test Procedure.

Notes: 
  1. 40 times the NOx limit would make NOx the longest bar on this chart; extending to about 2.8 grams per mile.
  2. The top emissions coming from a vehicle is Carbon Dioxide. CO2 emissions from a passenger car are typically around 370 grams per mile.
Since Volkswagen’s fraud affected only one of several emission control components, it makes sense that some of these Volkswagen vehicles would fail DEQ testing for other parts of the emissions system. And since it is only one system component that was not functioning properly, it makes sense that the Volkswagen failure rate during the last year (3.45%) is only slightly less than the failure rate for all other similar diesel vehicles (4.92%). These failure rates are only for 2009 and newer model years as those are part of EPA’s Notice of Violation issued to Volkswagen.
​Today’s vehicles are manufactured with a Check Engine Light. When DEQ’s onboard diagnostic test recognizes that this malfunction indicator is commanded on, the vehicle will fail the test.  However, as intended, some motorists respond to their Check Engine Light by seeking repairs earlier than waiting for DEQ’s two-year periodic inspection.  Such early action prevents excess air pollution and, along with cars now being manufactured much cleaner, is why the vehicle failure rates of VIP programs across the country are so low for the newer model years. The auto manufacturers, the Federal Test Procedure certification emissions test, DEQ’s onboard diagnostic test, the preventative nature of the Check Engine Light, the motoring public and local auto repair facilities all work together to properly maintain cars and reduce air pollution.
​Yes, the Oregon Department of Justice is actively investigating VW’s conduct and consumer compensation/restitution, environmental penalties, and remedies to offset the excessive pollution VW’s caused.