Se sei curioso ecco qui la lettera del CARB -
Matthew Rodriquez
Secretary for
Environmental Protection
Air Resources Board
Mary D. Nichols, Chair
9480 Telstar Avenue, Suite 4
El Monte, California 91731 •
www.arb.ca.gov Edmund G. Brown Jr.
Governor
Reference No. IUC-2015-007
September 18, 2015
Volkswagen AG
Audi AG
Volkswagen Group of America, Inc.
Through:
David Geanacopoulos
Executive Vice President and General Counsel, Government Affairs
Volkswagen Group of America
2200 Ferdinand Porsche Drive
Herndon, VA 20171
Stuart Johnson
General Manager
Engineering and Environmental Office
Volkswagen Group of America
3800 Hamlin Road
Auburn Hills, Ml 48326
Re: Admission of Defeat Device and California Air Resources Board's Requests
Dear Mr. Geanacopoulos and Mr. Johnson:
In order to protect public health and the environment from harmful pollutants, the
California Air Resources Board (CARS) rigorously implements its vehicle regulations
through its certification, in use compliance, and enforcement programs. In addition to
the new vehicle certification process, CARB regularly tests automobiles to ensure their
emissions performance is as expected throughout their useful life, and performs
investigative testing if warranted. CARS was engaged in dialogue with our European
counterparts concerning high in use emissions from light duty diesels. CARB deployed
a number of efforts using portable measurement systems and other approaches to
increase our understanding for the California fleet. In 2014, the International Council for
Clean Transportation (ICCT) and West Virginia University (WVU) identified through their
test program, and brought to the CARB's and the United States Environmental
Protection Agency's (EPA) attention, concerns of elevated oxides of nitrogen (NOx)
emissions over real world driving. The ICCT actions were consistent and
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.
For a list of simple ways you can reduce demand and cut your energy costs, see our website:
http://www.arb.ca.gov.
California Environmental Protection Agency
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Mr. Geanacopoulos and Mr.Johnson:
September 18, 2015
Page 2
complementary to our activities. This prompted GARB to start an investigation and
discussions with the Volkswagen Group of America (WV) on the reasons behind these
high NOx emissions observed on their 2.0 liter diesel vehicles over real world driving
conditions. As you know, these discussions over several months culminated in VW's
admission in early September 2015 that it has, since model year 2009, employed a
defeat device to circumvent GARB and the EPA emission test procedures.
VW initiated testing to replicate the IGGT/WVU testing and identify the technical reasons
for the high on-road emissions. VW shared the results of this testing and a proposed
recalibration fix for the Gen1 (lean NOx Trap technology) and Gen2 (Selective Catalytic
Reduction (SGR) technology) with GARB staff on December 2, 2014. Based on this
meeting, GARB and EPA at that time agreed that VW could implement the software
recall; however, GARB cautioned VW that if our confirmatory testing showed that the fix
did not address the on-road NOx issues, they would have to conduct another recall.
Based on this meeting, VW initiated a voluntary recall in December 2014 which,
according to VW, affected approximately 500,000 vehicles in the United States (-50,000
in California). The recall affected all 2009 to 2014 model-year diesel fueled vehicles
equipped with Gen1 and Gen2 technology. This recall was claimed to have fixed
among other things, the increased real world driving NOx issue.
GARB commenced confirmatory testing on May 6, 2015 to determine the efficacy of the
recall on both the Gen1 and Gen2 vehicles. GARB confirmatory testing was completed
on a 2012 model-year Gen2 VW, test group GVWX02.0U4S, to be followed with Gen1
testing. GARB staff tested this vehicle on required certification cycles (FTP, US06 and
HWFET) and over-the-road using a Portable Emission Measurement Systems (PEMS).
On some certification cycles, the recall calibration resulted in the vehicle failing the NOx
standard. Over-the-road PEMS testing showed that the recall calibration did reduce the
emissions to some degree but NOx emissions were still significantly higher than
expected.
To have a more controlled evaluation of the high NOx observed over the road, GARB
developed a special dynamometer cycle which consisted of driving the Phase 2 portion
of the FTP repeatedly. This special cycle revealed that VW's recall calibration did
increase Diesel Exhaust Fluid (DEF) dosing upon initial startup; however, dosing was
not sufficient to keep NOx emission levels from rising throughout the cycle. This
resulted in uncontrolled NOx emissions despite the SCR reaching sufficient operating
temperatures.
GARB shared its test results with VW on July 8, 2015. GARB also shared its results
with the EPA. Several technical meetings with VW followed where VW disclosed that
Gen1 , Gen2 and the 2015 model-year improved SCR vehicle (known as the Gen3) had
a second calibration intended to run only during certification testing. During a meeting
on September 3, 2015, VW admitted to GARB and EPA staff that these vehicles were
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.
For a list of simple ways you can reduce demand and cut your energy costs, see our website: http:llwww.arb.ca.gov.
California Environmental Protection Agency
Printed on Recycled Paper
Mr. Geanacopoulos and Mr.Johnson:
September 18, 2015
Page 3
designed and manufactured with a defeat device to bypass, defeat, or render
inoperative elements of the vehicles' emission control system. This defeat device was
neither described nor justified in the certification applications submitted to EPA and
GARB. Therefore, each vehicle so equipped would not be covered by a valid federal
Certificate of Conformity (COC) or GARB Executive Order (EO) and would be in
violation of federal and state law.
Based upon our testing and discussions with VW, GARB has determined that the
previous recall did not address the high on-road NOx emissions, and also resulted in
the vehicle failing certification standards. Therefore, the recall is deemed ineffective
and is deemed unapproved. VW must immediately initiate discussions with GARB to
determine the appropriate corrective action to rectify the emission non-compliance and
return these vehicles to the claimed certified configuration. GARB program and
enforcement staff is prepared to work closely with VW to find corrective actions to bring
these vehicles into compliance.
GARB has also initiated an enforcement investigation of VW regarding all model-year
2009 through 2015 light-duty diesel vehicles equipped with 2.0 liter engines. We expect
VVV's full cooperation in this investigation so this issue can be addressed expeditiously
and appropriately.
Annette Hebert, Chief
Emissions Compliance, Automotive Regulations and Science Division
cc: Mr. Byron Bunker, Director
Compliance Division
Office of Transportation and Air Quality
Office of Air and Radiation
U.S. Environmental Protection Agency
Mr. Linc Wehrly, Director
Environmental Protection Agency
Light-Duty Vehicle Center
2000 Traverwood Drive
Ann Arbor, Ml 48105
Dr. Todd P. Sax, Chief
Enforcement Division
California Air Resources Board
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption.
For a list of simple ways you can reduce demand and cut your energy costs, see our website:
http://www.arb.ca.gov.
California Environmental Protection Agency
Printed on Recycled Paper
