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Assessing the Durability of Vehicle Emissions Systems: A Survey of Emission Component-Related Defect Reports in North America

May 2012

Citation: 37 ELR 10385

Issue: 5

Author: Kevin L. Fast

Editors' Summary: EPA imposes strict emissions and durability standards on vehicle manufacturers today. While these standards have become more stringent over time, the regulatory requirements for demonstrating compliance with these standards have relaxed. In this Article, Kevin L. Fast identifies and describes this relevant regulatory framework governing the reporting of emission-related component defects in North America. He provides descriptions and data on nearly 600 defect reports prepared by 6 of the largest vehicle manufacturers currently in the marketplace. Finally, he provides a comparative analysis linking the results of his data analysis to other regulatory programs for monitoring the in-use performance of motor vehicles.

Kevin L. Fast is an attorney with more than two decades of experience, much of which has focused on the regulation of vehicles and fuels under Title II of the Clean Air Act. Prior to commencing an independent practice in summer 2005, the author was a partner for more than 10 years on the environmental and natural resources team in the Washington, D.C., office of Hunton & Williams. Additional information about the author is available at http://www.kevinfastlaw.com.

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