12. Only as to model year 2013 and 2014 Ford Mustang vehicles that are
equipped with PSDI-4 driver air bag inflators manufactured by Takata and that are
covered by Recall No. 15V-319, the schedule set forth in Paragraph 39 of the Coordinated

Remedy Order is extended by one month as follows:

Priority Group Sufficient Supply Timelines
Priority Group 2 October 31, 2016

13. GM, Daimler Vans, and Ford shall use their best efforts to complete, to the extent
possible, each milestone set forth in Paragraphs 10, 11, and 12 of this Amendment in advance of
the extended deadline.

14. The deadlines for GM recalls that involve Takata air bag inflators other than the
SPI passenger inflator covered by Recall No. 15V-324 remain unchanged. The deadlines for
Daimler Vans recalls that involve Takata air bag inflators other than the SPI passenger inflator
covered by Recall No. 15V-354 remain unchanged, as does the deadline for Priority Group 3 for
Recall No. 15V-354. The deadlines for Ford recalls that involve Takata air bag inflators other
than the PSDI-4 driver inflator covered by Recall No. 15V-319 remain unchanged, as does the
deadline for Priority Group 3 for Recall No. 15V-319. The remedy programs for all other recalls
remain subject to the sufficient supply deadlines set forth in Paragraph 39 of the Coordinated
Remedy Order.

15. All other provisions of the November 3, 2015 Coordinated Remedy Order remain
in full effect and are applicable to this Amendment.

IT IS SO ORDERED:

Dated: September vv, 2016 By: ORIGINAL SIGNED BY//
Mark R. Rosekind, Ph.D.
Administrator



Mr. Paul A. Hemmersbaugh
September 22, 2016
Page 2

The normal delivery time via airfreight from when parts leave the DAG Parts Center in Germany to
when they arrive at the US Parts Center is 12 — 14 days. Allocation to dealers takes another 2 — 4
days. Sufficient quantities (thirty percent) of parts will be accumulated by the week of October 10,
2016, then allocated to dealers so the launch can commence on October 14, 2016. Daimler Vans
therefore expects to be able to launch the combined Priority Group 2 and DIR 1 recall to the dealers
on October 14, 2016.

Daimler Vans respectfully requests an extension of time in which to comply with the September 30,
2016 deadline specified for Priority Group 2 in Paragraph 39 of the CRO. Daimler Vans is
combining the Priority Group 2 recall with the later-required DIR 1 recall in order to streamline the
recall process and improve recall efficiency. Daimler Vans proposes that its deadline for acquiring a
sufficient supply of remedy parts for Priority Group 2 be extended to October 14, 2016.

Thank you for your consideration of this request. Please let us know if you need any additional
information.

Sincerely,

P (ake Net

R. Latane Montague

Cc: Elizabeth Mykytiuk, Esq.
R. Thomas Brunner
Michael D. Scott


respond to newly obtained facts, scientific data, changed circumstances, and/or other relevant
information that may become available . . .” Examples of such anticipated modifications and
amendments include “allowing for reasonable extensions of time for the timelines contained in
Paragraph[] 39.” See Coordinated Remedy Order at | 48.

9. NHTSA issues this Amendment pursuant Paragraph 48 of the November 3, 2015
Coordinated Remedy Order; and its authority under the Safety Act, 49 U.S.C. § 30101, er seq., as
delegated by the Secretary of Transportation, 49 C.F.R. § 1.95, to ensure that defective vehicles
and equipment are recalled, 49 U.S.C. §§ 30118-30119, to ensure the adequacy of recalls, 49
U.S.C. § 30120(c), to exercise NHTSA’s inherent enforcement discretion, and to compromise
civil penalty liability, 49 U.S.C. § 30165(b). It is hereby ORDERED by NHTSA as follows:

II. TERMS AND CONDITIONS OF AMENDMENT.
10. Only as to GM vehicles that are equipped with SPI passenger air bag

inflators manufactured by Takata and that are covered by Recall No. 15V-324, the schedule

set forth in Paragraph 39 of the Coordinated Remedy Order is extended by three months as

follows:
Priority Group Sufficient Supply Timelines
Priority Group 2 December 31, 2016
Priority Group 3 March 31, 2017

11. Only as to Mercedes-Benz Sprinter and Freightliner Sprinter vehicles that

are equipped with SPI passenger air bag inflators manufactured by Takata and that are

covered by Recall No, 15V-354, the schedule set forth in Paragraph 39 of the Coordinated

Remedy Order is extended by two weeks as follows:

Priority Group Sufficient Supply Timelines
Priority Group 2 October 14, 2016



GENERAL MOTORS LLC Exhibit A
Global Vehicle Safety

September 16, 2016

Mr. Paul A. Hemmersbaugh, Esq. USG 4546
Chief Counsel

National Highway Traffic Safety Administration

NHTSA West Building W41-227 Docket No. NHTSA 2015-055
1200 New Jersey Avenue, SE Coordinated Remedy Order

Washington, D.C. 20590

Re: Request for Short Extension of Coordinated Remedy Order Deadline for 15V-324

Dear Mr. Hemmersbaugh:

This letter requests a short extension to the requirements of the Coordinated Remedy Order
(“CRO”) specified in Paragraph 39, in order to launch repairs with a new desiccated inflator. This
request relates to vehicles recalled under 15V-324 which consists of both Priority 2 and Priority 3
vehicles.

Paragraph 39 of the CRO specifies the date a sufficient supply of remedy parts shall be
available based on Priority groups. Over the last several months, GM has kept NHTSA informed of
its’ progress and challenges encountered in validating a desiccated version of the SPI inflator as a
remedy for 15V-324. GM is continuing validation work but a sufficient supply of parts will not be
available prior to the deadlines specified in Paragraph 39 for Priority 2 and Priority 3 vehicles. GM
expects to have a sufficient supply of desiccated SPI inflators to launch Recall 15V-324 for Priority 2
vehicles by December 31, 2016 and for Priority 3 vehicles by March 31, 2017.

GM, therefore, requests a short extension to the Paragraph 39 requirements of the CRO in order
to launch repairs with a desiccated inflator for all vehicles covered under 15V-324.

Please direct all inquiries and responses to this request to: Michael G Fici, General Motors
LLC, Vehicle Engineering Center, 30001 Van Dyke, Warren, MI 48093.

- -

Brian Latouf, Executive Director
Global Safety and Field Investigation
Regulation and Certification

ce: Ms. Elizabeth H. Mykytiuk, Esq.
Ms. Lucy Clark Dougherty, Esq.
Mr. Scott Yon


EDP

W. E. Bahr, Director Fairlane Plaza South, Suite 400
Automotive Safety Office 330 Town Center Drive
Sustainability, Environment & Safety Engineering Dearborn, MI 48126-2738

September 27, 2016

Mr. Greg Rea, Associate Administrator for Enforcement
National Highway Traffic Safety Administration

1200 New Jersey Avenue SE

Washington, DC 20590

Dear Mr. Rea
Subject: Docket No. NHTSA-2015-0055 Coordinated Remedy Program Proceeding

Ford Motor Company submits this letter to NHTSA at the agency's request following a
telephone discussion on September 14, 2016.

Paragraph 39 of the subject Coordinated Remedy Order dated November 3, 2015,
provides dates when a sufficient supply of remedy parts are to be available for the various
vehicle Priority Groups. Among the vehicles in Priority Group 2 are certain 2013 and 2014
model year Ford Mustang vehicles in the HAH region included in safety recall
45S21/15V/319 for the driver side PSDI-4 inflators. You may be aware that earlier model
year Mustang vehicles in the same recall have a different remedy and have sufficient parts
available.

A non-inflator related manufacturing issue resulted in an unanticipated delay in the first
shipment of parts to Ford, resulting in a subsequent delay in the availability of service
modules. As a result, the launching of the 2013 and 2014 model year Mustang vehicle
service program in the HAH region will likely be delayed by two to four weeks.

Ford expects to have sufficient parts available to launch the program for the Group 2
vehicles by October 31, 2016.

If you have any questions concerning this letter, please feel free to contact me.

Sincerely,

Exhibit C


UNITED STATES DEPARTMENT OF TRANSPORTATION
NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
1200 New Jersey Avenue, SE
West Building, W41-326
Washington, DC 20590

In re:

EA15-001
(formerly PE14-016)
Air Bag Inflator Rupture

Docket No. NHTSA-2015-0055
Coordinated Remedy Program

eemere ere SE YS

SECOND AMENDMENT TO NOVEMBER 3, 2015
COORDINATED REMEDY ORDER

This Second Amendment to the November 3, 2015 Coordinated Remedy Order (the
“Amendment”) is issued pursuant to the authority of the National Highway Traffic Safety
Administration (“NHTSA”, an operating administration of the U.S. Department of
Transportation), to resolve, mitigate, and control risks of harm, and to promote safety. This
Amendment is being issued, pursuant to Paragraph 48 of the November 3, 2015 Coordinated
Remedy Order, for the purpose of modifying the remedy schedules set forth therein, but only to
the extent that those schedules involve the remedy programs for: (1) SPI air bag inflators
manufactured by TK Holdings Inc. (“Takata”), which are installed in motor vehicles
manufactured by General Motors LLC (“GM”), and which are covered by Recall No. 15V-324;
(2) SPI air bag inflators manufactured by Takata, which are installed in certain Mercedes-Benz
and Freightliner Sprinter vehicles, which are covered by Recall No. 15V-354; and (3) PSDI-4
inflators manufactured by Takata, which are installed in certain motor vehicles manufactured by

Ford Motor Co. (“Ford”), and which are covered by Recall No. 15V-319.


Exhibit B

Hogan Lovells US LLP
Columbia Square
555 Thirteenth Street, NW

Washington, DC 20004
Hogan T +1 202 637 5600
Lovells F +1 202 637 5910

www.hoganlovells.com

September 22, 2016

Mr. Paul A. Hemmersbaugh

Chief Counsel

National Highway Traffic Safety Administration
(NCC-111), Room W41-227

1200 New Jersey Avenue, SE

West Building

Washington, DC 20590

RE: Docket No. NHTSA-2015-0055 — Daimler Vans Request for Extension of Takata
Coordinated Remedy Program Sufficient Supply Deadline

Dear Mr. Hemmersbaugh:

On behalf of our client, Daimler Vans, this letter requests an extension of time in which to comply
with the sufficient supply timeline for Priority Group 2 vehicles contained in Paragraph 39 of the
Takata Coordinated Remedy Order (CRO).

Based on the Takata inflator production schedule for Daimler AG (DAG), for efficiency and alignment
between the Priority Grouping of the original CRO and the DIR Phases, Daimler Vans consolidated
plans between these two recalls (DIR 0 and DIR 1) so a launch was possible starting Q4 of 2016 for
both. This plan was originally shared with NHTSA at our June 22, 2016, meeting.

This phase of the Daimler Vans recall includes 6262 Mercedes-Benz Sprinter vehicles in Zone A,
469 Mercedes-Benz Sprinter vehicles in Zone B, and 2 Mercedes-Benz Sprinter vehicles in Zone C.
Further, there are 5749 Freightliner Sprinter vehicles in Zone A, 2631 Freightliner Sprinter vehicles
in Zone B, and 4 Freightliner Sprinter vehicles in Zone C. A total of 15,117 vehicles (6733
Mercedes-Benz Sprinters and 8384 Freightliner Sprinters) are involved in the DIR 1 phase of the
recall. Of this total population, the Priority Group 2 population is as follows: there are 2954
Mercedes-Benz Sprinter vehicles in Zone A, 469 Mercedes-Benz Sprinter vehicles in Zone B, 2
Mercedes-Benz Sprinter vehicles in Zone C, as well as 1733 Freightliner Sprinter vehicles in Zone A,
2631 Freightliner Sprinter vehicles in Zone B, and 4 Freightliner Sprinter vehicles in Zone C.

Daimler Vans had a reasonable plan in place to procure a sufficient quantity of Takata SPI-D
desiccated inflators to launch this recall. Daimler Vans normally launches a recall with thirty percent
of the replacement parts available to dealers. In this case, a sufficient quantity of inflators was
ordered to meet the thirty percent threshold as soon as inflator quantities were available from Takata
to DAG. The first available quantities were ordered from DAG on September 8, 2016, with multiple
subsequent orders continuing in the following weeks.

Hogan Lovells US LLP isa limited liability partnership registered inthe District of Columbia. Hogan Lovells refers tothe international legal practice comprising Hogan Lovells US LLP, Hogan
Lovells Intemational LLP, Hogan Lovells Workiwide Group (a Swiss Verein), and their affiiated businesses with offices in: Abu Dhabi Alicante Amsterdam Baltimere Beijing Berlin
Boulder Brussel Caracas ‘Chicago Colorado Springs Denver Dubai Dusseldorf Frankfurt Hamburg Hanoi Ho Chi Minh City Hong Kong Houston London Los Angeles
Madrid Miami Milan Moscow Munich New York Northem Virginia Pars Philadelphia Prague Rome San Francisco Shanghai Silicon Valley Singapore Tokyo Warsaw
Washington DC Associated offices: Budapest Jeddah Riyadh Zagreb


L BASIS FOR AMENDMENT.

1. On November 3, 2015, after a public administrative proceeding, NHTSA issued a
unilateral Coordinated Remedy Order to Takata, GM, Daimler Vans US LLC (“Daimler Vans”),
Ford, and nine other vehicle manufacturers affected by the Takata air bag inflator recalls.
Therein, the Agency established a prioritization schedule for the remedy of defective Takata
inflators, and set forth the following deadlines by which each of those vehicle manufacturers

shall ensure that it has a sufficient supply of remedy parts:

Priority Group Sufficient Supply Timelines
Priority Group 1 March 31, 2016

Priority Group 2 September 30, 2016

Priority Group 3 December 31, 2016

See Coordinated Remedy Order at { 39.

2. On or about May 19, 2016, GM notified NHTSA that it was encountering
difficulty in its effort to validate an alternative remedy part for Recall No. 15V-324, and that it
might not meet the sufficient supply deadlines for Priority Groups 2 and 3.' Over the next several
months, GM and NHTSA had regular discussions about the status of the alternative remedy part.

3: On September 16, 2016, GM informed NHTSA that it would be unable to comply
with the sufficient supply deadlines in the Coordinated Remedy Order for Priority Groups 2 and
3. See Exhibit A. GM therefore requested a three-month extension of time in which to comply
with the remaining deadlines specified in Paragraph 39 of the Coordinated Remedy Order. GM’s
request is limited to vehicles equipped with SPI passenger inflators that are covered by Recall

No. 15V-324.

' There were no Priority Group | vehicles included in Recall No. 15V-324. See Coordinated Remedy Order at
Annex A.


4, On or about August 29, 2016, Daimler Vans first notified NHTSA that it might
not be able to meet the sufficient supply deadline for Priority Group 2, given the timeframe on
which quantities of replacement inflators would be available from Takata.

5. On September 22, 2016, Daimler Vans informed NHTSA that replacement
inflators became available (and were ordered) beginning on September 8, 2016, with additional
orders continuing in the subsequent weeks. See Exhibit B. However, on this schedule, and with
the added delivery time of twelve to fourteen days from Daimler AG’s Parts Center in Germany
to the U.S. Parts Center, Daimler Vans will not have accumulated sufficient quantities of parts to
launch the recall until October 14, 2016. Accordingly, Daimler Vans requested a two-week
extension of time in which to comply with the deadline for Priority Group 2, as specified in
Paragraph 39 of the Coordinated Remedy Order.

6. On or about September 14, 2016, Ford first notified NHTSA that it had
encountered a non-inflator-related manufacturing issue that may result in a brief delay in the
availability of Ford’s alternative remedy part for Recall No. 15V-319.

7. On September 27, 2016, Ford informed NHTSA that it would, in fact, be unable
to comply with the sufficient supply deadline in the Coordinated Remedy Order for Priority
Group 2, for the reason described in Paragraph 4. See Exhibit C. Ford requested a one-month
extension of time in which to comply with the deadline for Priority Group 2, as specified in
Paragraph 39 of the Coordinated Remedy Order. Ford’s request is limited to certain model year
2013 and 2014 Mustang vehicles equipped with PSDI-4 driver inflators that are covered by
Recall No. 15V-319.

8. Paragraph 48 of the Coordinated Remedy Order permits NHTSA to unilaterally

modify or amend the provisions of the order to, among other things, “account for and timely