Volkswagen of America temporarily withdraws application for US certification of MY 2016 vehicles; AECDs
07 October 2015
In his prepared testimony for the House Committee on Energy and Commerce Subcommittee on Oversight and Investigations hearing tomorrow (earlier post), Michael Horn, President and CEO of Volkswagen Group of America, says that in discussions with EPA and the California ARB, Volkswagen said that its emissions control strategy also included a software feature that should be disclosed to and approved by the agencies as an auxiliary emissions control device (“AECD”) in connection with the certification process.
AECDs are allowed by the EPA, but they must be disclosed. As a result, Horn says, Volkswagen has withdrawn the application for certification of its model year 2016 vehicles. The company is working with the agencies to continue the certification process, he adds.
EPA defines an AECD as “any element of design that senses temperature, motive speed, engine RPM, transmission gear, or any other parameter for the purpose of activating, modulating, delaying, or deactivating the operation of any part of the emission-control system.”
On electronically controlled engines, AECDs are calibrations—not devices or sensors; on a modern engine, the entire emissions control system is an AECD, EPA says.
An acceptable AECD is emphatically not a defeat device, according to EPA. Although almost all AECDs reduce the effectiveness of the emission control system (in most cases, increasing NOx as HC or PM is reduced), the reduced effectiveness may be allowed under certain conditions.
Typical AECDs include controls for:
- Cold temperature: cold coolant and/or cold intake air
- Engine overheat
- Extended idle
- Transient operation: air/fuel control during accelerations
- Altitude: air density; turbocharger protection
- EGR modulation: protect EGR valve or cooler; condensation protection
- Diesel particulate filter regeneration: automatic or manual
- SCR dosing control: dosing threshold; thermal management
- Sensor failure: how failure effects emission control
AECDs with dual maps—for example, city and highway maps—are allowed if both maps are substantially included in a test cycle.
The AECD to which Horn refers is distinct from the hidden software “defeat device” in the four-cylinder diesels from model years 2009-2015 that could recognize whether a vehicle was being operated in a test laboratory or on the road. That software, as revealed in September, allowed those diesels to emit higher levels of NOx when the vehicles were driven in actual road use than during laboratory testing. (Earlier post.)
In the prepared testimony, Horn says that in the spring of 2014 when the West Virginia University study that brought the emissions issue to the fore was published, he was told that there was a possible emissions non-compliance issue that could be remedied.
He says that he was also informed that EPA regulations included various penalties for non-compliance with the emissions standards and that the agencies can conduct engineering tests which could include “defeat device” testing or analysis. He says he was also informed that the company engineers would work with the agencies to resolve the issue. Later in 2014, he says he was informed that the technical teams had a specific plan for remedies to bring the vehicles into compliance and that the company was engaged with the agencies about the process.
These events are deeply troubling. I did not think that something like this was possible at the Volkswagen Group. We have broken the trust of our customers, dealerships, and employees, as well as the public and regulators. Let me be clear, we at Volkswagen take full responsibility for our actions and we are working with all relevant authorities in a cooperative way. I am here to offer the commitment of Volkswagen AG to work with this Committee to understand what happened, and how we will move forward. EPA, CARB, the US Department of Justice, State Attorneys General, as well as other authorities, are fulfilling their duties to investigate this matter.
We are determined to make things right. This includes accepting the consequences of our acts, providing a remedy, and beginning to restore the trust of our customers, dealerships, employees, the regulators, and the American public. We will rebuild the reputation of a company that more than two million people worldwide, including dealers and suppliers, rely upon for their livelihoods. Our immediate goal is to develop a remedy for our customers.—Prepared testimony of Michael Horn
Horn outlines 5 initial points:
Volkswagen is conducting investigations on a world-wide scale into how these matters happened. Responsible parties will be identified and held accountable. Thorough investigations have already begun, but any information developed at this stage is preliminary.
As the EPA has said, these vehicles do not present a safety hazard and remain safe and legal to drive.
Technical teams are working to develop remedies for each of the affected groups of vehicles. These solutions will be tested and validated, and then shared with the responsible authorities for approval. There are three groups of vehicles involved, each containing one of the three generations of the 2.0L diesel engine. Each will require a different remedy, but these remedies can only be the first step.
Volkswagen will examine its compliance, processes, and standards and adopt measures to make certain that something like this cannot happen again.
Volkswagen commits to regular and open communication with our customers, dealers, employees, and the public as we move forward. As first steps, Volkswagen of America has set up a designated service line and website to be a channel for this communication, and Horn has sent a letter to every affected customer.
Volkswagen Group has a deep commitment to preserving our environment. As one of the world’s largest automobile manufacturers, our commitment to the environment extends throughout every aspect of our business in the more than 150 countries in which we operate. For example, here in the United States, Volkswagen’s manufacturing facility in Chattanooga, Tennessee serves as a model for Volkswagen plants around the world for increasing energy efficiency and reducing emissions, water, and materials usage and waste. In recognition of the plant’s efficiency, Volkswagen Chattanooga received a platinum certification from the US Green Building Council’s Leadership in Energy and Environmental Design (“LEED”) program. The facility is the first and only automotive manufacturing plant in the world to receive the Platinum Certification. As environmental protection and sustainability are central to Volkswagen’s core values, these events have been particularly troubling. Our conduct in the events that bring us here today belittle the efforts of Volkswagen to lead in environmental responsibility.—Prepared testimony of Michael Horn
I find it appalling that VW has not yet been ordered to take back their 11 million extremely polluting cars. They pollute as much as nearly 500 million compliant cars. VW should replace them ASAP with loaner cars from VW or other makers until they get the polluting cars fixed. This massive global pollution has to stop ASAP. We cannot wait for over a year. It should to be done on a global scale before dec 31 this year. Then VW can spend 2016 fixing and returning the fixed cars to VW owners. VW should also be forced to pay VW owners for all of their trouble. 5k to 10k USD each would be relevant. In addition to that let VW pay the governments up to 35 k USD per car they have cheated with. What VW has done is mass murder and unforgivable. Numerous of engineers and managers knew about it and participated in updating the cheating software to fool countless of monitoring agencies around the world every year since 2008. They need to go to prison for a vey long time all of them. I want to recall that 7 million people dies every year prematurely because of air pollution. VW is a big part of that because of their cheating.
WHO on 7 million air pollution death.
Posted by: Account Deleted | 08 October 2015 at 12:44 AM
It is not just diesel engines that legislatures are criminally lax on enforcing standards on, and not just VW:
'New Gasoline Direct Injection (GDI) petrol engines for cars emit more cancer-causing particles than modern diesel engines, a new study by independent vehicle researchers TÜV Nord revealed today. While GDI engines make petrol cars more fuel-efficient and emit less CO2, the findings show that these new petrol engines typically release around 1,000 times more harmful particles than traditional petrol engines and 10 times more than new diesels.
As the ‘EU Year of Air’ draws to a close, air pollution in Europe is estimated to contribute to 406,000 deaths annually and cause over 100 million lost days of work – costing the EU economy €330-940 billion per year. Small particles in the air pose the greatest risk to health, penetrating deep into the lungs and being absorbed into the blood. This causes a range of illnesses, including cancer, and even deaths.
The cost of a filter to eliminate particle emissions from GDI cars is low (around €50), with no loss in fuel efficiency and a big societal benefit. Despite this, carmakers are delaying fitting filters on GDI cars.''
The VW criminality is just the tip of a very dirty iceberg, with legilatures compliant in sacrificing public health on a wink and a nod basis.
The director of VW America admits that they continued to sell non compliant vehicles for 18 months after he was aware of it.
Why should he and his directors not do jail time for this?
Posted by: Davemart | 08 October 2015 at 03:36 AM
Dave GDI in Europe is a different animal than GDI in the U.S. Different cycles and modes, they'll burn leaner and hotter in Europe. Though that's rapidly changing with new standards.an older Boschs gdi has like 6diffrent modes (from a really shaky memory here) and several are just not used in the US because of emissions but the majority were taken advantage of in Europe.
Also, modern diesels are cleaner than almost all gasoline cars. So... Its just kind of a moot point. Eventually we will install all those extra catalysts and urea on GDIs and probably go crazy enough to do natural gas and propane too.
Posted by: CheeseEater88 | 08 October 2015 at 05:58 AM
You're using the 40x figure to arrive at 500 million car figure, but the excess NOx levels are '10 to 40' times over, not '40'.
Keep in mind that the excess pollutants from all the non-compliant VW's comes to about the same amount of pollution as a single coal fired power plant. They're building a new coal-fired power plant every week in China alone.
Also keep in mind that the worst VW pollutes far less than the AVERAGE diesel on the road right now. And big rigs, garbage trucks, bulldozers? No comparison.
Passenger cars account for 5% of the NOx pollution on the planet, non-compliant VWs accounts for a tiny fraction of that.
Also keep in mind the 11 million drivers who need a car.
Also keep in mind that much of the present fleet of cars (all cars) don't comply perfectly with the regulations. So, supercop, calm down.
Posted by: The Lurking Jerk | 08 October 2015 at 08:01 AM
Also keep in mind that if you are behind a VW diesel in city traffic YOU are breathing that air.
Posted by: SJC | 08 October 2015 at 09:59 AM
The more I learn about diesel, the more I like electric drivetrains.
Posted by: electric-car-insider.com | 09 October 2015 at 08:32 AM
Non-compliant (over 80%) of large cargo trucks and buses in USA pollute up to 100 times more than a VW but they get away with minor penalties, if any?
Posted by: HarveyD | 09 October 2015 at 12:49 PM