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newsrel -- UPDATE: Volkswagen submits recall plan for 2-liter diesel cars to California Air Resources Board

Posted: 20 Nov 2015 16:12:26
Please consider the following news release from the California
Air Resources Board: http://bit.ly/1Mt3jYq


November 20, 2015


Stanley Young
(916) 956-9409

UPDATE: Volkswagen submits recall plan for 2-liter diesel cars to
California Air Resources Board

SACRAMENTO - Today the Volkswagen Group of America (VW) submitted
a recall plan to the California Air Resources Board responding to
the violations described in ARB’s September 18, 2015 letter
(available here: http://bit.ly/1MZmxlz) to VW concerning illegal
defeat devices in their 2-liter diesel-powered vehicles, model
years 2009-2015.  

This submission initiates a review by ARB of up to 20 business
days of all elements of the plan.  Based on ARB’s review, VW may
be required to revise and resubmit all, or specific elements of
the recall plan. ARB will also consult with U.S. EPA during this
process to develop a national recall plan. 

Required elements of a recall plan include, but are not limited
to, the projected timeline of the full recall process from
initiation to completion (including how owners are located), the
content of a company’s communications with them about the recall,
and a plan for following up on the progress of the recall
campaign. The recall plan must set out the projected time to fix
each vehicle. 

The remedy proposed in the recall must not only fix the violation
in question, it must also address the safety, drivability,
vehicle durability and fuel efficiency of the cars involved. 

Detailed Legal Requirements:

The required elements for an approvable recall plan are detailed
in the California Code of Regulations (13 CCR 2113-2121 and 40
CFR §85.1803) and include but are not limited to:

a.	The description of the vehicles and affected California and
U.S. population 
b.	Description of the nonconformity and the specific
recalibration and hardware corrective actions to return the
vehicles to the certified configuration (i.e., no defeat device
and emission compliant)
c.	A description of the method by which the manufacturer will
determine the names and addresses of vehicle owners and the
method for notifying the service facilities and vehicle owners of
the recall
d.	A description of the procedure to be followed by the vehicle
owner to obtain correction.  This shall include the date on or
after which the owner can have the nonconformity remedied, the
time reasonably necessary to perform the labor, and the
designation of the facilities that can perform the work
e.	A copy of the owner’s notification letter
f.	A description of the system by which the manufacturer will
assure adequate supply of parts
g.	A copy of all instructions that will be sent to those
performing the repair
h.	A description of the impact of the proposed repairs or
adjustments on fuel economy, drivability, performance and safety
of each vehicle recalled and a brief summary of the data,
technical studies, or engineering evaluations which support the
i.	The estimate of the capture rate from the proposed recall and
registration tracking of repaired and unrepaired Vehicle
Identification Numbers at the DMV.
j.	A description of the impact of the proposed changes on the
average emissions from the vehicle to be recalled.  The
description shall include:
i.	Average noncompliance emission levels
ii.	Average emission reduction per pollutant from the recall
iii.	An estimate of the average emission level per pollutant for
the vehicle adjusted for the capture rate
k.	A repair label shall be affixed to each vehicle that is
corrected per the approved recall plan (13 CCR 2116)
l.	A description of the impact of the proposed changes on the On
Board Diagnostic (OBD) system performance on the vehicle to be
recalled.  The description shall include:
i.	OBD demonstration testing for all major monitors 
ii.	Identification and disclosure of all OBD monitoring
requirements that are not met in the recall calibration
m.	The manufacturer shall require those who perform the repair to
provide the owner for each vehicle or engine with a certificate
indicating that a noncomplying vehicle or engine has been
corrected under the recall program (13 CCR 2117)
n.	The manufacturer shall report on the progress of the recall
campaign by submitting subsequent reports for six consecutive
quarters commencing with the quarter after the recall campaign
begins. Such reports shall be submitted no later than 25 days
after the close of each calendar quarter (13 CCR 2119)

California is in a drought emergency.
Visit www.SaveOurH2O.org for water conservation tips.

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