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This all seems rather puzzling, as the hybrid system has nothing whatsoever to do with emissions - at least in any way that could be tested without a dynamometer or road test.
Don't know what California's testing involves*, or why they'd only start testing hybrids this year, since they've been around since 2000, but the only thing I can think of that seems at all realistic is an automatic failure if the OBDII system has thrown a code that turns on the Check Engine light. On my Insight (2000 model), that happens fairly often - say once a month or so on average - for reasons involving the battery and/or DC-DC converter. Nothing to do with the IC engine or its emissions, IOW.
*Nevada's smog test for my Insight is to simply plug a scanner into the OBDII port.
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