the code they’re testing has painful hardwired dependencies on expensive external resources
I've told this story elsewhere, but I had a coworker who wrote an app to remote-control a baseball-throwing machine from a PDA (running WinCE). These machines cost upwards of $50K so he only very rarely had physical access to one. He loved to write tests, which did him no good when his code fired a 125 mph knuckleball a foot over a 10-year-old kid's head. This resulted in the only occasion in my career when I had to physically restrain a client from punching a colleague.