ARA Comments to Justice Department on Volkswagen Partial Consent Decree

In an August 5, 2016 comment letter to the U.S. Department of Justice regarding the Partial Consent Decree for Volkswagen diesel vehicles, ARA urged the Department to adopt language that allows the owners of VW engines, not just the entire vehicle, to be “Eligible Owners” eligible for remedy under the recall program.

Each day over 500,000 recyclers OEM parts that were designed and built to meet the automakers’ original requirements for fit, finish, durability and safety are sold by professional automotive recyclers to consumers, repair facilities, and automobile dealers.  ARA’s letter pointed out that the value of these recycled OEM components was recognized in June when a settlement was reached between the United States, the State of California, and Volkswagen that stated all eligible vehicles “may be, to the extent possible, recycled to the extent permitted by law.”

ARA believes that the Partial Consent Decree is significantly deficient in providing equitable remedy for “engine owners” such as the professional automotive recyclers throughout United States that have thousands of these engines in their inventories.