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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 f uture; however, until go through the process to upd ate 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 foll ow 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 Allia nce with regard to the DFR amendments. Specifically , Mercedes will not object to the amendments to 86.101(b)(1) as cur rently proposed. We also would appreciate if EPA could clarify that manufacturers could still use AC55c guidance (in it s 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 wh en i am back for 3 days in the office

Best regards2 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 conf irmed with him that Mercedes supports the AAM posit ion. You may not be aware though that AAM initially sent us a co mment saying they did not support our amendments in tended to reflect current practice for coastdown procedures, then they reversed their position a few weeks late r. At this point, AAM’s position is to support the coastdown amendmen ts to §1066.305 as drafted. Markus expected that t here 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 thi s 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 positio n 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 Grund ler tomorrow and we want to make sure we have Daiml er's position properly represented.

Thanks,

Mike3

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