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Stout, Alan

From: Stout, Alan

Sent: Thursday, December 04, 2014 3:39 PM

To: klaus.land@daimler.com

Cc: Olechiw, Michael; thorsten.leischner@daimler.com

Subject: RE: AW: DFR coast down

Klaus, 

Thanks for your feedback. We will move ahead with the DFR amendments as discussed. 

We are hoping to update road-load guidance in the future; however, until go through the process to update AC55, it will 

continue to apply under part 1066 as it does today under part 86. 

I hope that helps. Let me know if you need to follow up. 

Alan 

From: klaus.land@daimler.com [mailto:klaus.land@daimler.com] 

Sent: Thursday, December 04, 2014 7:24 AM 

To: Stout, Alan 

Cc: Olechiw, Michael; thorsten.leischner@daimler.com 

Subject: AW: AW: DFR coast down 

Dear Alan dear Mike sorry for the late response . 

Here is our answer to your question:

Mercedes supports the current position of the Alliance with regard to the DFR amendments. Specifically, Mercedes will 

not object to the amendments to 86.101(b)(1) as currently proposed. 

We also would appreciate if EPA could clarify that manufacturers could still use AC55c guidance (in its revised form) 

after MY 2021, under 1066.305. 

Best regards

Klaus

 

Von: Land, Klaus (059) 

Gesendet: Mittwoch, 19. November 2014 15:36 

An: Stout, Alan 

Cc: Olechiw, Michael 

Betreff: AW: AW: DFR coast down

 

Dear alan 

I have to appologize 

I am on am eu business trip since last thursday and i have to dipe deep into that topic together with my team before i 

can answer your question. 

An answer could be possible by end of next week when i am back for 3 days in the office 

Best regards 
2

Klaus 

Von meinem Windows Phone gesendet

Von: Stout, Alan

Gesendet: 19.11.2014 15:19

An: Land, Klaus (059)

Cc: Olechiw, Michael

Betreff: RE: AW: DFR coast down

Klaus,

Mike and I spoke with Markus earlier today and confirmed with him that Mercedes supports the AAM position. You may 

not be aware though that AAM initially sent us a comment saying they did not support our amendments intended to 

reflect current practice for coastdown procedures, then they reversed their position a few weeks later. At this point, 

AAM’s position is to support the coastdown amendments to §1066.305 as drafted. Markus expected that there should 

be no continued objection from Mercedes, but needed to leave that to your judgment. Should we continue to 

understand that you support the AAM position on this issue?

Alan

From: <klaus.land@daimler.com> 

Date: November 18, 2014 at 9:51:16 AM EST 

To: <olechiw.michael@epa.gov> 

Subject: AW: DFR coast down

Hello mike 

Sorry i am travelling this week in eu regsrding rde. 

I eas not able to speak with markus. 

I got a message from him: 

So far our position is in line with the aam position sent to epa. 

Best regards 

Klaus 

Von meinem Windows Phone gesendet

Von: Olechiw, Michael

Gesendet: 18.11.2014 15:38

An: Land, Klaus (059)

Cc: Stout, Alan

Betreff: DFR coast down

Hello Klaus, 

Any update from Markus? We are briefing Chris Grundler tomorrow and we want to make sure we have Daimler's 

position properly represented. 

Thanks, 

Mike 
3

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