On July 13, 2018, EPA issued an Information Request to Full Tilt pursuant to Section 208 of the CAA, 42 U.S.C. ? 7542, seeking information related to Full Tilt?s manufacture, purchase, sale, and installation of parts and components and services which bypass, defeat, or render inoperative any emission control component, element of design, or emissions related part or component (defeat devices) for the period from June 1, 2015 to July 13, 2018. Full Tilt?s responses to EPA?s Information Request included spreadsheet data for parts and components manufactured and/or sold by Full Tilt during this period. Based on this information, between January 1, 2016, and June 30, 2018, Full Tilt manufactured and/or sold at least 516 defeat devices. On April 22, 2022, EPA issued a Finding of Violation (FOV) to Full Tilt alleging violations of Section 203(a)(3)(B) of the CAA, 42 U.S.C. ? 7522(a)(3)(B), related to the Full Tilt?s manufacture and/or sale of aftermarket automotive parts. Full Tilt confirmed that it stopped the manufacture, sale, and offer for sale, of defeat devices in September 2021, after receiving an EPA information request, and before receipt of the FOV. The parties met to discuss the violations alleged in the FOV and subsequently negotiated the terms of this CAFO.
CAFO requires Full Tilt to pay a penalty of $450,000 and resolves the FOV issued to Full Tilt on April 22, 2022. In the CAFO, Full Tilt agrees to not manufacture, sell, or install any defeat devices, and to no l