The seventh meeting of the Intersessional Working Group on Reduction of GHG Emissions from Ships took place remotely (19-23 October 2020), ahead of the next Committee session, MEPC 75. This framework was followed by a draft Memorandum of Understanding (MOU) released in mid-December that would, in addition to committing participating jurisdictions to implementing the cap-and-invest program, require participants to jointly develop a model rule that achieves the following: establishes and implements a regional cap on CO2 emissions from motor vehicles fueled by gasoline and on-road diesel; develops an emissions allowance auction process; requires regulated fuel suppliers to report emissions and hold allowances; and provides for regualtory flexibilities. Additional revisions to the cap are expected to be made in 2021 through 2025. Md. III. var plc461033 = window.plc461033 || 0; 3, 2017, http://bit.ly/2KGpdyk). —Bob Nagy, “VW Golf TDI Sets Fuel Economy Record,” Kelley Blue Book website, Jul. By Volkswagen’s estimation, complying with the rules meant increased costs and lower fuel economy and road performance, which would potentially detract from sales. California is employing a multi-sector GHG cap-and-trade program, and several Northeast and Middle Atlantic states are participating in the Regional Greenhouse Gas Initiative (RGGI), the first binding cap-and-trade program aimed at reducing GHG emissions from the power sector. Vehicle exhaust emissions are regulated at the EU level, meaning that before vehicles are approved for sale they must meet certain standards set out in EC Regulation 715/2007. There is evidence to the contrary. Starting with the 2015 sustainability report, the auditor makes clear that its assurance, even though limited, should not be relied upon by stakeholders: “The report is not intended for any third parties to base any [financial] decision thereon. As in earlier corporate debacles where the role of the company’s lawyers has come into question (such as the Enron accounting scandal and the General Motors ignition switch case), observers might ask: what duty, if any, did Volkswagen’s lawyers have to report the fraud if they knew of it? Environmental statutes such as the Clean Air Act (CAA) are largely predicated on protecting human health rather than the environment per se. The Regional Greenhouse Gas Initiative (RGGI), formed in 2009, is the nation’s first binding cap-and-trade program aimed at reducing GHG emissions from the power sector. AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 461033, [300,600], 'placement_461033_'+opt.place, opt); }, opt: { place: plc461033++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); Ten states—Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont—currently participate in the program, with New Jersey being the latest state to rejoin RGGI. var plc282686 = window.plc282686 || 0; var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; 26% by 2025; 50% by 2030; 90% by 2050 (2005 baseline). AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 459496, [300,600], 'placement_459496_'+opt.place, opt); }, opt: { place: plc459496++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); This website uses cookies to analyze traffic and for other purposes. To that end, in 2008 Volkswagen rolled out a new technology that it claimed would achieve high fuel economy and performance while meeting the strict new emissions standards—a technology that seemed to require “magical thinking,” at least in engineering circles (Dune Lawrence et al., “How Could Volkswagen’s Top Engineers Not Have Known?” Bloomberg Businessweek, Oct. 26, 2015, https://bloom.bg/2F298zk). Connecticut and Washington also implement a shifting baseline depending on the target year. The two most common assurance frameworks used for sustainability reports are ISAE 3000 and AA1000AS (Sunita Rao, “Current State of Assurance on Sustainability Reports, The CPA Journal, June 2017, https://bit.ly/2m4Eewu). Volkswagen solved its dilemma by engaging in an elaborate fraud. The Volkswagen emissions scandal started on 18 September 2015, when the United States Environmental Protection Agency (EPA) issued a notice of violation of the Clean Air Act to German automaker Volkswagen Group.Volkswagen had intentionally programmed turbocharged direct injection (TDI) diesel engines to activate emissions controls only during emissions testing. All rights reserved. Additionally, multiple states have implemented statutory GHG reduction and reporting requirements, as well as a carbon pricing policy. (function(){ var div = divs[divs.length-1]; Daniel Jacobs, JD is a clinical associate professor of management at the College of Business Administration of Loyola Marymount University, Los Angeles, Calif. Lawrence P. Kalbers, PhD, CPA is the R. Chad Dreier Chair in Accounting Ethics and the associate dean, faculty and academic initiatives at Loyola Marymount. Some states, such as Iowa and Pennsylvania, are statutorily required to compile an emissions inventory but do not have a statutory mandate to reduce statewide emissions. 6], while AA1000AS allows for “high” or “moderate” assurance (AA1000AS, 2008, p. 10). The program is designed to operate in parallel to the RGGI requirements. In 2017, the RGGI states extended the emissions cap out to 2030. var abkw = window.abkw || ''; Indeed, in a landmark unanimous opinion written by Justice Antonin Scalia, the Supreme Court construed the CAA as mandating the EPA to solely consider human health and welfare—and barring it from considering industry implementation costs—in promulgating national ambient air quality standards (NAAQS) for pollutants such as PM and NOx[Whitman v. American Trucking Associations, 531 U.S. 457, 473 (2001)]. California’s current regulations provide for an annual emissions allowance budget (in millions) of 346.3 in 2019, decreasing annually down to 193.8 in 2031. Controlling emissions from automobiles is an important means of reducing air pollution, especially in large cities. This was just the first in an extraordinary series of events that ultimately would lead to costly litigation and criminal charges against Volkswagen and its CEO. AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 459481, [300,250], 'placement_459481_'+opt.place, opt); }, opt: { place: plc459481++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); if (!window.AdButler){(function(){var s = document.createElement("script"); s.async = true; s.type = "text/javascript";s.src = 'https://servedbyadbutler.com/app.js';var n = document.getElementsByTagName("script")[0]; n.parentNode.insertBefore(s, n);}());}. Selective Catalytic Reduction (SCR) is an advanced active emissions control technology system that injects a liquid-reductant agent through a special catalyst into the exhaust stream of a diesel engine. The Transportation and Climate Initiative (TCI) was formed in 2010 by a coalition of Northeast and Middle Atlantic states and Washington, D.C., with the intent of reducing carbon emissions from the transportation sector. Several states—California, Connecticut, Maine, Massachusetts, New York, Oregon, Rhode Island, Vermont and Washington—use a 1990 baseline to measure emissions reductions, while the emissions baseline for Colorado, Minnesota and Nevada is 2005 and Maryland and New Jersey is 2006. So, Volkswagen took it upon itself to use defeat devices to cheat—programming the vehicles so that their emission control systems satisfied emission limits only when in test mode. The new 2020 diesel engine is rated to pull as much as 12,560 pounds, the highest diesel tow rating in the class. The reductant source is usually automotive-grade urea, otherwise known as Diesel Exhaust Fluid (DEF). Participants in RGGI and TCI with no Statutory Reduction or Reporting Requirements, States with no Reduction/ Reporting Requirements or Market-based Policy, Statutory Greenhouse Gas Reduction + Reporting Requirements, Statutory Greenhouse Gas Reduction Requirements, Statutory Greenhouse Gas Reporting Requirements, States with no Reduction/Reporting Requirements. Conversely, several states with statutory GHG reduction requirements also have a statutory mandate to compile an emissions inventory. This conspiracy was not a victimless crime. State percentage reduction requirements range from 10% by 2020 up to 90% by midcentury. ISA 240, The Auditor’s Responsi bilities Relating to Fraud in an Audit of Financial Statements Auditors, states that auditors are “responsible for obtaining reasonable assurance that the financial statements taken as a whole are free from material misstatement, whether caused by fraud or error” (para. Of note, House Bill 1261 requires the AQCC to identify, solicit stakeholder input from, and consider impacts on communities disproportionately impacted by climate change. Auditors should also keep in mind the three points of the fraud triangle: incentive or pressure, opportunity, and rationalization (para. On the way to its findings, the investigation looked into accounts of tampering of emissions controls in Class 2b (medium duty) and Class 3 (heavy duty) diesel pickup trucks from 2010 through 2019. 7700 East First Place var abkw = window.abkw || ''; For light-commercial vehicles the new targets are a 15% reduction for 2025 and a 31% reduction for 2030. Volkswagen, whose conspiracy to hide the emissions of its diesel engine vehicles was first uncovered in 2015, is still trying to repair its reputation. The adjusted allowance cap is 58.3 million in 2019 decreasing to 56.3 million in 2020. Code art. A key part of that strategy was to vastly expand diesel vehicle sales in the United States (Jack Ewing, Faster, Higher, Farther: The Volkswagen Scandal, W.W. Norton & Company, 2017). Should the auditors have exercised additional scrutiny under the circumstances—which included a history of poor ethical corporate culture, weak corporate governance, an aggressive new sales strategy, and bold claims of technological advances? enacted comprehensive climate legislation. var abkw = window.abkw || ''; Meanwhile, all three pillars of sustainability—economic, social, and environmental—collapsed under the diesel fraud, as costs mounted, stakeholders were alienated, and the air was polluted. In 2014, RGGI states adjusted down the regional cap to account for banked allowances. It remains an open question, however, whether Volkswagen’s auditors and lawyers might have missed opportunities to prevent the scandal. Enforcement is critical to protecting human health, especially in major metropolitan areas such as Los Angeles, which sits in the most heavily polluted air basin in the country (American Lung Association, State of the Air 2018, http://bit.ly/2I6gtQp). In 1990, Congress enacted new emissions laws known as Tier 1 standards and required the EPA to review whether further reductions were necessary and technologically feasible to help states meet the NAAQS. When EPA and CARB finally began to catch on, Volkswagen equivocated until regulators threatened to withhold certification of its 2016 model year diesels. Comments to the ABA Model Rules reflect that the scenario is “especially delicate” when the lawyer has been representing a client with the understanding that the conduct was legal, but then discovers the criminal or fraudulent conduct midstream. Other states, such as New Mexico, North Carolina and Pennsylvania, have recently committed to statewide GHG reduction goals through executive action, but do not currently have binding statutory targets. Volkswagen’s own internal auditors—after the fact—recommended 31 measures to improve governance and compliance (Volkswagen Group Annual Report 2016,http://bit.ly/2WsF7in). The effects of corporate scandals can reverberate for years. 5). The program is enforced through independent regulations adopted by participating states and is designed around a regional emissions allowance cap—one allowance provides for regulated entities to emit one short ton of CO2. Signed by Phillip Brooks, director of the EPA’s Air Enforcement Division, the letter was addressed to various Volkswagen and Audi corporate entities and copied to Volkswagen’s outside counsel. Denver, CO 80230 The day before the Notice of Violation, EPA and Volkswagen officials exchanged emails scheduling a high-level conference call the next morning at 9:00 a.m. If the lawyer knows of a violation of law that is likely to result in substantial injury to the corporation, the lawyer must act in the corporation’s best interest (i.e., not necessarily in the best interest of its individual officers and employees), including by reporting the matter up the corporate ladder [Model Rule 1.13 (b)]. The first, the Regional Greenhouse Gas Initiative (RGGI), is focused on reducing GHG emissions from the power sector. Many of these same states also participate in the Transportation and Climate Initiative (TCI), which is committed to developing a cap-and-invest program aimed and reducing transportation sector emissions. Washington, D.C. 20001 Thus, the independent assurance provided for Volkswagen’s sustainability reports became increasingly more limited over time. We do not assume any responsibility towards third parties.” In the 2017 report, the sentence “Our responsibility lies only with the Company” was added to the report between the two sentences above. Note that Pennsylvania Governor Tom Wolf (D), issued an executive order on Oct. 3, 2019, directing the state Department of Environmental Protection to initiate a rulemaking no later than July 31, 2020, to establish a carbon budget consistent with and to facilitate participation in the RGGI program. This project was reviewed and selected through the DERA Option, to match $804,482 awarded by U.S. EPA to Ohio EPA under the Diesel Emission Reduction Act state allocations for 2017 and 2018. 11). document.write('<'+'div id="placement_456219_'+plc456219+'">'); (function(){ The second, the Transportation Climate Initiative (TCI), is aimed at reducing emissions from the transportation sector. The rules would replace an existing, multi-layered legal framework in Europe with one overarching regulation. Knowing that the diesel vehicles would evade U.S. emissions standards, Volkswagen misrepresented them for years in order to get EPA and CARB certifications that allowed the vehicles to be sold in the U.S. Electricity generators and industrial facilities emitting 25,000 metric tons of carbon dioxide equivalent (CO2e) or more were required to comply with the cap during the first compliance period starting in 2013. During the years it perpetrated this fraud, Volkswagen consistently portrayed itself as having an ethical culture, good corporate governance, effective risk management, and a strong commitment to sustainability. document.write('<'+'div id="placement_289809_'+plc289809+'">'); 2019/12: Amendments to the Annex of the Protocol of 1997: 2014/04: Final Rule for Control of Emissions From New Marine Compression-Ignition Engines at or Above 30 Liters per Cylinder: 2010/04: 2008 Amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL) 2008/10 (German authorities searched the law firm’s offices in Munich to seize the information, an action that was subsequently upheld by Germany’s Constitutional Court.). Auditing standards also require auditors to consider a company’s legal and regulatory environment (ISA 250, Consideration of Laws and Regulations in an Audit of Financial Statements), including “undertaking specified audit procedures to help identify noncompliance with those laws and regulations that may have a material effect on the financial statements” (para. Of the 15 states that have enacted GHG reduction targets, seven did so from 2007 through 2009. Read the Fuel Quality Standards (Automotive Diesel) Determination 2019; Biodiesel. A1). In some jurisdictions, if reporting up the ladder does not result in the matter being addressed appropriately, the lawyer may—but is not obligated to—report a clear violation to the authorities if it is reasonably certain to result in substantial injury to the corporation [Model Rule 1.13(c)]. var abkw = window.abkw || ''; diesel particulate filters. The rule, as adopted in 2016, was suspended pending a decision by the Washington state Supreme Court. To evaluate compliance, the emissions are averaged using the moving averaging window (MAW) method. Many feel, one way or another, that emissions … (To be clear, a review of the actions of VW’s auditors and lawyers is beyond the scope of this article.). (function(){ While the Volkswagen Golf TDI diesel was traversing the country in the summer of 2015, so were Volkswagen engineers, to meet with Environmental Protection Agency (EPA) and California Air Resources Board (CARB) officials. var plc461032 = window.plc461032 || 0; ICYMI | When Will We Be Able to Breathe in Accounting? The biodiesel fuel standard describes diesel derived from plant and/or animal matter. Published research spearheaded by MIT scientists predicts that the excess particulate matter (PM) and nitrogen oxide (NOx) emissions produced by the fake clean diesel vehicles will lead to some 60 premature deaths in the United States and 1,200 in Europe (Steven Barrett et al., “Impact of the Volkswagen Emissions Control Defeat Device on U.S. Public Health,” Environmental Research Letters, Oct. 29, 2015, http://bit.ly/2WyLLIP; Guillaume P. Chossière et al., “Public Health Impacts of Excess NOx Emissions from Volkswagen Diesel Passenger Vehicles in Germany,” Environmental Research Letters, Mar. The Volkswagen Diesel Emissions Scandal and Accountability, Additional Coronavirus Relief in the Consolidated Appropriations Act of 2021, ICYMI | Combating Implicit Bias in Accounting Education and Training, Advice for Retaining African American Accountants. div.id = "placement_459496_"+plc459496; (c) Scope 2 refers to indirect GHG emissions from the generation of purchased electricity and steam that is consumed by operated assets (calculated using the market-based method). var abkw = window.abkw || ''; International Accounting Standard (IAS) 315, Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and Its Environment, requires auditors to evaluate whether “management, with the oversight of those charged with governance, has created and maintained a culture of honesty and ethical behavior” (para. Two of the diesel engine's biggest advantages over its gas V-6 and V-8 siblings—aside from fuel efficiency—are off-road and towing performance. Since its creation in 1970, the EPA has been under a congressional mandate to promulgate regulations designed to reduce automobile emissions. Two primary carbon pricing regional agreements focus on limiting GHG emissions from major sectors. document.write('<'+'div id="placement_282686_'+plc282686+'">'); div.id = "placement_461032_"+plc461032; Statutory Reduction Requirements + Market-based Policy. Arguments can be made about whether these restrictions are fair or appropriate. var div = divs[divs.length-1]; Several states have also implemented carbon pricing policies either independently or through regional agreements. Awareness of a toxic corporate culture and poor ownership and corporate governance structures might prompt the auditor to consider how those factors could affect business practices and controls, and potentially lead to fraud. ISAE 3000 is used more often by CPA firms (primarily the Big Four), and AA1000AS is used more often by “specialist assurance providers/technical experts” (Rao 2017). Several standards of the International Auditing and Assurance Standards Board (IAASB) may be particularly relevant as to whether any of the annual audits conducted during the period of the fraud could have detected potential warning signs (2016-17 Handbook of International Quality Control, Auditing, Review, Other Assurance, and Related Services Pronouncements,http://bit.ly/2wO1rIM). The CPA Journal 14 Wall St. 19th Floor New York, NY 10005 [email protected]. This content contains forward-looking statements (within the meaning of the U.S. But they posed a dilemma for Volkswagen if it was to achieve its ambition of becoming the leading automobile manufacturer in the world. When on the road, the systems were disabled. 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