DEKRA America Public Hearing Houston, February 2, 2010 

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Public Hearings for Reconsideration of the 2008 National 

Ambient Air Quality Standards for Ozone 

Houston: Tuesday, February 2, 2010. 

Hilton Houston Hobby Airport, Moody 

Ballroom (located on the ground floor), 

8181 Airport Boulevard, Houston, Texas 

77061. Telephone: 713–645–3000. 

Presenter: 

Nguvi Kahiha 

Business Development Manager 

DEKRA America, Inc. 

3901 Roswell Road Suite 120 

30062 Marietta, Georgia, USA 

Office: +1 (770) 971- 3788 ext. 224 

nguvi.kahiha@emissioncheck.com 
DEKRA America Public Hearing Houston, February 2, 2010 

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Good Morning Ladies and Gentlemen, 

First of all, I would like to start by thanking The Environmental Protection 

Agency for giving us the opportunity to express our opinion and comments about the 

proposed revision of the National Ambient Air Quality Standards for Ground-level 

Ozone. As a member of the Inspection and Maintenance (I/M) Industry, and on behalf of 

CITA, the International Motor Vehicle Inspection Committee, DEKRA America supports 

the new proposed revision of Air Quality Standards. We believe that these new 

regulations are necessary to help insure a cleaner and safer environment for our future 

and the future of our children. DEKRA has been in the inspection business for almost 100 

years servicing people and the environment around the world. We understand the effects 

and consequences that ground level ozone has on people and the environment. Literature 

and scientific research states that one of the main emitters of pollutant gas such as 

Nitrogen Oxides or NOx and Volatile Organic Compounds or VOC’s are vehicles. As a 

result, the commitment of the I/M Industry lies not solely in making cars safer, but also 

cleaner. 

The I/M Industry has rolled out very effective and innovative programs to curve 

the output of vehicle emission. For example the I/M program in the Atlanta area tests on 

average 2.3 million cars a year. The projected emissions reduction in 2009 for metro 

Atlanta alone was 316 tons of carbon monoxides, 19 tons of VOCs (volatile organic 

compounds) and 19 tons of NOx per day.1

 Georgia’s management contractor, Georgia’s 

Clean Air Force has identified and repaired more than 1.5 million heavy polluting 

vehicles.” As you may imagine, similar success stories can be found in many other 

metropolitan regions where vehicle emissions is an ongoing health hazard to the citizens 

of these areas. 

Besides, the conventional I/M programs that reduce emissions, there are abundant 

other initiatives to gear America into a cleaner future. These initiatives include RideShare programs, Public Relations campaigns to inform the public on air issues and 

educational programs on proper vehicle maintenance. Air Check Texas, the program 

administrator in Texas, introduced a program titled Drive a Clean Machine that provides 

assistance to remove 10 years or older vehicles with failed emission tests from Texas 

 

1

 Information provided by Pam Earl, Program Manager of the Mobile & Area Sources Program GA EPA 
DEKRA America Public Hearing Houston, February 2, 2010 

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roadways.2 This self-funded program gives subsidies to eligible low income vehicle 

owners which enables them to move into newer and cleaner vehicles. 

The moving public may argue that some of these programs are inconvenient due 

to the cost and time associated with emission testing. Even this argument was taken into 

consideration by the I/M Industry: Technology innovations, such as OBDII testing and 

other alternative programs help reduce motorist inconvenience and helping to keep costs 

down. 

No doubt, the revision of the National Ambient Air Quality Standards for 

Ground-level Ozone will create new challenges for program administrators. One may ask 

how practical new or adjusted programs are to meet the new standards. As mentioned 

earlier, the I/M Industry has a proven track record on how to implement programs 

efficiently, cost effectively and quickly; therefore it can be argued that the industry has 

the competence and experiences to successfully tackle these challenges. An example of 

meeting the new standards could be to expand existing emission test programs into 

suburban areas, where the moving public heavily commutes into the regions with high 

pollution rates. Another, more essential example is the integration of diesel operated 

heavy trucks into already existing federal annual safety inspection programs. 

Heavy trucks make up the majority long-distance highway user, driving more than 

120 thousand miles a year. Trucks use about 14 billion gallons of gasoline and 23 billion 

gallons of diesel fuel annually. Heavy trucks alone, excluding smaller commercial 

vehicles, are responsible for about 3 million tons of NOx emissions annually.3

 The influx 

of commercial vehicles in metro areas causes an increase of emission pollution. 

According to a study by Oak Ridge National Laboratory, about 25 thousand trucks drive 

through Knoxville, TN daily and contribute 40% of NOx emissions in that area.4

 There 

are new regulations for new trucks to meet certain emission standards and several states 

have implemented annual emission inspection programs to oversee and control emission 

output caused by commercial vehicles. Nevertheless, in order to meet the new National 

Ambient Air Quality Standards for Ground-level Ozone, a nationwide test program 

 

2

 http://www.tceq.state.tx.us/implementation/air/mobilesource/vim/driveclean.html 

3

 “Estimation of Fuel Use by Idling Commercial Trucks”, TRB 85th Annual Meeting Washington, DC 

01/26/2006 

4

 “Truck Emission”; ACF News Source; www.acfnewsource.org/science/truck_emissions.html 
DEKRA America Public Hearing Houston, February 2, 2010 

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should be rolled out, maybe in combination with the FMCSA periodic safety inspection 

program section 396, 17 though 23. 

To summarize, the I/M Industry has proven to be the most effective way to reduce 

ground level ozone. Its programs are a vital source to identify and repair gross polluting 

vehicles. Technology innovations and inclusion of heavy truck testing could be a logical 

way to help further reduce harmful pollutants being added to our atmosphere. 

In conclusion, there are significant points of the proposed revision that has direct 

impact on the economy. Firstly, in metro Atlanta alone, inspection providers employ 

more than 2500 certified inspectors and this number would increase if the program is 

expanded into new areas and/or with the addition of heavy diesel vehicle testing. Most of 

the programs service providers are small businesses that use this program to create 

employment opportunities, and economic growth. During the state of the Union address 

on January 27, 2010, President Barak Obama made clear how important small business 

success is to the U.S. economy: “We should start where most new jobs do –- in small 

businesses; when an entrepreneur takes a chance on a dream, or a worker decides it's time 

she became her own boss. Through sheer grit and determination, these companies have 

weathered the recession and they're ready to grow.” 5 The proposed revision would give 

many small businesses the opportunity to expand and grow. 

Secondly, tougher policies on air pollution force other industries to utilize cleaner 

energy. Increased investments into clean energy would lead to more innovations, 

advancement in technology and a cleaner environment but also to economic strength. 

Referencing again President Obama, he stated the effect of clean energy on the economy 

as follows: “because the nation that leads the clean energy economy will be the nation 

that leads the global economy. And America must be that nation.”6

On behalf of DEKRA America, CITA and the Inspection and Maintenance 

Industry, I would like to thank you for your time and the opportunities that lie ahead.

 

5

 http://www.whitehouse.gov/the-press-office/remarks-president-state-union-address 

6

 http://www.whitehouse.gov/the-press-office/remarks-president-state-union-address