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Car and Driver: Volkswagen Submits 4-Cyl TDI Fix for EPA and CARB Scrutiny


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VW TDI logo, on a BeetleOwners of TDI-badged Volkswagen or Audi models with the 2.0-liter turbo-diesel four-cylinder engine may soon see some resolution to an emissions scandal that’s effectively left them hanging for nearly a year. With last week’s preliminary approval, it’s now nearly a done deal that hundreds of thousands of owners will be able to sell back their cars, beginning this fall.

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Not every owner will want to give up their vehicle—and the cars that remain on the road are going to rehab. Volkswagen’s estimated $10.033 billion remedy cost hinges on the approval of a plan to fix a portion of these models—tens of thousands of them—to bring them close to emissions compliance. If that plan isn’t approved, VW’s settlement costs could go significantly higher.

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It’s in Volkswagen’s interest to put its best effort into a modification that will bring these cars down to the emissions levels at which U.S. Environmental Protection Agency (EPA) and California Air Resources Board (CARB) will accept them; and it now appears that the automaker has done exactly that, with the submission of a plan for the so-called Generation 3 TDI four-cylinder that was sold in a range of 2015-model-year vehicles.

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“The agencies have started to receive information from Volkswagen regarding a proposed emissions modification for the 2.0-liter Generation 3 vehicles,” confirmed EPA spokesperson Julia Valentine.

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If the plan was submitted in full last Friday—which was all but officially confirmed—that starts a 45-day evaluation period, as stipulated in the settlement documents, in which EPA and CARB will use their “best efforts to either approve or disapprove each complete proposal.”

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That sets the wheels in motion for the California Air Resources Board (CARB) to go through several months of data-gathering and durability testing to make sure that the remedy works. “We will review data and do our own tests to ensure the modifications comply with the stringent requirements outlined in Appendix B,” explained CARB spokesman Stanley Young, referring to the standards outlined in settlement’s massive Consent Decree.

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A Whole Semester of TDI Reform-School Deadlines

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This first four-cylinder fix is especially important, as the agencies will either approve or reject of this solution by October 14—just before the final hearing of the class-action suit to be held October 18, 2016. Plans for the other two engines are expected November 11 for Gen 1 (the 2009-2014 Jetta, Jetta SportWagen, Golf, Beetle, and Beetle Convertible, and the 2010-2014 Audi A3), and December 16 for Gen 2 (the 2012-2014 Passat), and the same evaluation period will follow in both cases.

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VW is expected to have the easiest time with the 2015-model-year Gen 3 cars, as they use a more comprehensive selective catalytic reduction (SCR) system, with one catalyst close-coupled to the engine and another one under the floor. It has long been suggested that the fix for this engine will include software changes only, but in light of last month’s rejection of VW’s proposed V-6 TDI fix—one that had looked particularly straightforward—the automaker has been tight-lipped about what the four’s fix entails.

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The Generation 1 cars employed a lean NOx trap and skipped the SCR system entirely—during an era when it was becoming the norm for meeting U.S. emissions standards. Generation 2 cars have a single SCR system, packaged under the floor.

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One potential challenge for the Gen 3 cars is that their fix will be held to 150,000-mile durability standards, whereas the Gen 1 and Gen 2 cars need to show their emissions levels can be maintained for 120,000 miles.

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Cleaner, but Still Not in Compliance

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Owners who are on the fence about keeping their cars should know that these fixes do involve compromise, and won’t necessarily bring all the vehicles all the way into compliance. CARB and EPA will allow these vehicles to be called fixed if they meet standards that were set within the settlement paperwork—which are within 80 to 90 percent of the pollution standards (as shown in this CARB graph below).

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2.0-liter TDI fix emissions reduction (CARB)

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Following last week’s preliminary approval, a final approval hearing for the plan is set for October 26, and the reception given to the fix by these agencies could play a part in the outcome of that.

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The program requires Volkswagen to “remove from commerce” (buy back) and/or perform the emissions modification on at least 85 percent of the vehicles by June 30, 2019; otherwise at that time it owes additional funds to the Environmental Mitigation Trust.

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The buyback program is slated to begin very soon after final approval of the scheme, which is likely on October 18. After that, owners have two years to decide if they want to take the deal, but after they decide they do VW is required to pay the owner the full buyback amount within 15 days.

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VW faces substantial additional penalties if it doesn’t buy back or modify at last 85 percent of affected vehicles within two years; that’s broken down individually for California and for all other states. It’s in VW’s interest to get the fix approved, because if one isn’t approved the automaker may be required to buy back the remainder of registered vehicles—at far increased costs.

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