Renault Trucks working with metal 3D printing to reduce engine size and weight
New Flyer zero-emission bus deliveries increased by 48% to 213 EUs in 2016

EPA and CARB charge Fiat-Chrysler with using undeclared emission control devices in 3.0L diesels

The US Environmental Protection Agency (EPA) issued a notice of violation (NOV) to Fiat Chrysler Automobiles N.V. and FCA US LLC (collectively FCA) for alleged violations of the Clean Air Act for installing and failing to disclose at least eight auxiliary emissions control devices (AECDs) in light-duty model year 2014-2016 Jeep Grand Cherokees and Dodge Ram 1500 trucks with 3.0-liter diesel engines sold in the United States. The undisclosed engine management software results in increased emissions of nitrogen oxides (NOx) from the vehicles, the agencies said. The allegations cover roughly 104,000 vehicles.

EPA is working in coordination with the California Air Resources Board (CARB), which has also issued a notice of violation to FCA. There are about 14,000 of the affected vehicles on the road in California. EPA and CARB have both initiated investigations based on FCA’s alleged actions.

The Clean Air Act requires vehicle manufacturers to demonstrate to EPA through a certification process that their products meet applicable federal emission standards to control air pollution. As part of the certification process, automakers are required to disclose and explain any software, known as auxiliary emission control devices, that can alter how a vehicle emits air pollution.

The presence of an AECD is not necessarily a regulatory violation. An AECD is an element of design (for example, software, strategy, algorithm, hardware, etc.) which in some way alters the performance of the vehicle emissions control system. An AECD is sometimes allowed in situations where running the full emissions control system under extreme conditions could damage the engine.

It is, however, a violation of California and federal regulations for an automaker to include any AECD in a vehicle without notifying the agencies responsible for certification. None of the AECDs in this case were disclosed, and many do not operate during certification testing—only when the car is taken off the required testing procedures in the laboratory. To date none has been finally determined to be a “defeat device” as was the case with VW, but the investigation is still underway.

Of particular concern, said CARB, are AECDs found in these vehicles which reduce or turn off exhaust gas recirculation (EGR) or reduce the effectiveness of selective catalyst reduction (SCR) system. Both EGR and SCR control the emissions of NOx from the engine. The eight AECDs identified in the EPA NOV are:

  1. Full EGR shut-off at highway speed
  2. Reduced EGR with increasing vehicle speed
  3. EGR shut-off for exhaust valve cleaning
  4. DEF dosing disablement during SCR adaptation
  5. EGR reduction due to modeled engine temperature
  6. SCR catalyst warm-up disablement
  7. Alternative SCR dosing modes
  8. Use of load governor to delay ammonia refill of SCR catalyst

The next step in the NOV process will be for FCA to justify the use of the AECDs in the affected vehicles. If the company cannot do that, additional violations may result.

FCA may be liable for civil penalties and injunctive relief for the violations alleged in the NOV. EPA is also investigating whether the auxiliary emission control devices constitute “defeat devices,” which are illegal.

In September 2015, EPA instituted an expanded testing program to screen for defeat devices on light duty vehicles. This testing revealed that the FCA vehicle models in question produce increased NOx emissions under conditions that would be encountered in normal operation and use. As part of the investigation, EPA has found at least eight undisclosed pieces of software that can alter how a vehicle emits air pollution.

Also in September 2015, CARB notified major automakers that diesel vehicles would face expanded emissions testing as part of ARB’s In-Use Compliance Program, which includes modified test procedures in the lab, and testing of emissions while the car is being driven on the road in addition to certification test cycles. This enhanced testing program was developed during the Volkswagen investigation and is now being used routinely by CARB for vehicle certification and in-use compliance testing. The current violations were discovered as a result of the enhanced testing procedures.

FCA response. In response to the notices of violation, FCA US said that it was “disappointed that the EPA has chosen to issue a notice of violation with respect to the emissions control technology employed in the company’s 2014-16 model year light duty 3.0-liter diesel engines.

FCA US intends to work with the incoming administration to present its case and resolve this matter fairly and equitably and to assure the EPA and FCA US customers that the company’s diesel-powered vehicles meet all applicable regulatory requirements.

FCA US has spent months providing voluminous information in response to requests from EPA and other governmental authorities and has sought to explain its emissions control technology to EPA representatives. FCA US has proposed a number of actions to address EPA’s concerns, including developing extensive software changes to our emissions control strategies that could be implemented in these vehicles immediately to further improve emissions performance.

FCA US looks forward to the opportunity to meet with the EPA’s enforcement division and representatives of the new administration to demonstrate that FCA US’s emissions control strategies are properly justified and thus are not “defeat devices” under applicable regulations and to resolve this matter expeditiously.

FCA US LLC is a wholly owned subsidiary of Fiat Chrysler Automobiles N.V., a multinational corporation.



The benefit of doubt rule should apply when

"The presence of an AECD is not necessarily a regulatory violation. An AECD is an element of design (for example, software, strategy, algorithm, hardware, etc.) which in some way alters the performance of the vehicle emissions control system. An AECD is sometimes allowed in situations where running the full emissions control system under extreme conditions could damage the engine."

It is in no ones interest for engines under management strategy to self destruct and these type of safeguards have always been.

If a manufacturer makes a product incapable of operating within regulated standards under 'normal usage' then the product is faulty.
IMO no amount of software fixes can achieve the disparate objective.

To be fair, everyone understands the desirability of increased fuel efficiency etc and these sort of engine reliability compromising problems have been well known in the industry since the 70's oil crisis and emissions control became essential to reduce pollution.

The original emissions'fix' was really only a temporary masking of the most visible photochemical smog.

The increase in fleet numbers and associated emissions only continued to increase.

Sulphurous compounds were importantly one of the few bright spots.

We also see that fuel economy improvements have in many cases been a figment of the advertising departments imagination.

While these AECD's are (apparently) required to be reported by law, they are not known to be designed to deceive the previous emissions testing procedures.

Many manufactures have used defeat strategy specifically to deceive testing over many years.

The proposed fixes from Volkswagen are equally unlikely to achieve their objective.
The U.S. $4.2,000,000,000 (that could go a long way towards investing in decarbonising solutions) in penalties and buybacks and similar penalties waiting on the books in other countries for the deceit is just the start as no one should be thinking the same problems are solved for gasoline engines. That is just wishful thinking.

Criteria pollutants and their control strategies have been shown to become more problematic across the entire fossil fuel industry as predicted in the 80's
to the point of seriously compromising all levels social cohesion.

No one can expect to escape the consequences of following the old paradigm.

We also see Italian legislators backing their manufactures claims that the new emissions standards are unrealistic.
At the same time as pollution in many European Asian US and other countries is causing millions of premature deaths.

It isn't rocket science to see that the internal combustion engine belongs in a history museum along with the dodo.

The good news is that there are alternatives and solutions if the legislators consumers and public can find the backbone to just say no.

Dr. Strange Love

The EPA and CARB are not staffed by men.

Dr. Strange Love

"Chestnuts roasting on an own fire...". Kids, go outside and fetch some logs.

The comments to this entry are closed.