The VW case illustrates the vast differences between the emissions certification process in the U.S. and Europe. Lee describes the U.S. process as “interactive” and says California regulators routinely ask for detailed engine-control algorithms, the logic behind them, the supporting data and all the calibration.

“It’s a diagnostic, so they have the right to ask for it,” he says. “It’s back and forth.”

However, in Europe, Lee says there’s no such process. “There are rules, but there’s no checking, no asking, ‘Is this OK?’ There’s no going through algorithms like… in California. None of that.”

When the VW story broke, Lee ordered his engineers to scour the engine-control algorithms for similar “defeat device” codes. “We looked at 2 million lines of software code in the last month,” he says.

In his discussions with colleagues at rival automakers, Lee finds everyone’s in the same boat. “We’ve all been through the same exercise. We’ve all looked and dug and scraped, and we probably know our systems better in the last month than we’ve known them for the last few years.”

FCA engineers have been looking for software that could be calibrated to violate the rules. “It’s not against the rules to have something (used for test procedures) that could be turned into a defeat device,” Lee says. “You’re only guilty if you have used the defeat device, which was the case at VW.”

The internal audit at FCA was extensive. “What is our software-control process? Are we as good as we think we are? This is the right time to ask that question. Second, do we have any software that could be misused if you could find the requisite number of people to make it happen?”