Mr. Stephen Hench June 8, 2018

Ford is committed to continuing to work very closely with NHTSA and the Coordinated
Remedy Monitor team to provide transparent and timely service part supply information on
an ongoing basis for the numerous vehicle programs covered. Ford is submitting an
updated extension request with specific timing for each vehicle program.

If you have any questions, please feel free to contact my office.

Sincerely,

‘Za Desi Ujkashevic

Attachements


Appendix B

Requested Supply and Launch Dates

June 8, 2018

Sufficient Supply & | Owner Letter Mailing

Priority Model Remedy Launch | Start Date Extension
Group Year(s) Make Model Inflator Zone __| Deadline per ACRO5 Request “

5 2007-2009 |Ford Edge PAB A December 31, 2017 _|September 30, 2018

5 2006-2009 |Ford Fusion PAB A December 31, 2017_|September 30, 2018

5 2007-2009 |Lincoln _|MKX PAB A December 31, 2017 |October 31, 2018

5 2006-2009 |Lincoin Zephyr/MKZ |PAB A December 31, 2017_ [August 31, 2018

5 2006-2009 |Mercury__|Milan PAB A December 31, 2017 _|September 30, 2018

i} 2010 Ford Edge PAB A January 31,2018 _|September 30, 2018

6 2007-2008 |Ford Edge PAB Non-A February 28, 2018 _|September 30, 2018

6 2010-2011 |Ford Fusion PAB A January 31,2018 {October 31, 2018

6 2006-2008 |Ford Fusion PAB Non-A February 28, 2018 |September 30, 2018

6 2010 Lincoln MKX PAB A January 31,2018 |October 31, 2018

6 2007-2008 |Lincoln MKX PAB Non-A February 28, 2018 |October 31, 2018

6 2010-2011 |LincoIn__|Zephyr/MKZ |PAB A January 31,2018 [September 30, 2018

6 2006-2008 {Lincoln |Zephyr/MKZ |PAB Non-A February 28, 2018 |August 31, 2018

6 2010-2011 |Mercury _|Milan PAB A January 31,2018 [October 31, 2018

6 2006-2008 |Mercury [Milan PAB Non-A February 28, 2018 |September 30, 2018

7 2012 Ford Fusion PAB A February 28,2018 |November 30, 2018

8 2009 Ford Edge PAB B May 31, 2018 September 30, 2018

8 2007-2008 |Ford Edge PAB Cc June 30, 2018 September 30, 2018

8 2009 Ford Fusion PAB B May 31, 2018 November 30, 2018

8 2006-2008 |Ford Fusion PAB Cc June 30, 2018 November 30, 2018

8 2009 Lincoln MKX PAB B May 31, 2018 October 31, 2018

8 2007-2008 |Lincoln MKX PAB Cc dune 30, 2018 October 31, 2018

8 2009 Mercury __|Milan PAB B May 31, 2018 November 30, 2018

8 2006-2008 |Mercury {Milan PAB Cc June 30, 2018” _|November 30, 2018

9 2010 - 2010|Ford Edge PAB B June 30,2018 [October 31, 2018

9 2009 - 2009|Ford Edge PAB c June 30,2018? |October 31, 2018

9 2009 - 2009|Ford Fusion PAB Cc June 30,2018 [November 30, 2018

9 2010 - 2010]Lincoin MKX PAB. B June 30,2018 |October 31, 2018

9 2009 - 2009|LincolIn _ |MKX PAB Cc June 30, 2018 ® —|October 31, 2018

9 2010-2010|Lincoln _|Zephyr/MKZ |PAB B June 30,2018 _|September 30, 2018

9 2009 - 2009|Mercury _|Milan PAB Cc June 30, 2018 —_|November 30, 2018

“ . These dates include additional contingency timing to account for minor unforeseen
circumstances. As always, Ford will work to notify owners as quickly as possible.


Confidential Business Information

Mr. Stephen Hench June 8, 2018

(iii)

(iv)

(vy)

Sufficient Remedy Part Supply Sourcing

Ford has made a substantial effort to secure dual-stage passenger airbag inflator
(APPS-7) production capacity from Autoliv, Inc. For Ford’s service part needs, Autoliv
is producing four different outputs of the APPS-7 inflator that are used in both inflator
kits and airbag module assemblies.

In some instances, replacing the existing Takata airbag inflator with a new Autoliv
inflator did not deliver acceptable performance, which required redesigning the airbag
cushion and additional development and validation time. Ford secured module

production capacity at Joyson Safety Systems that incorporates the redesigned airbag
cushion

Replacement Part Quantities

Ford is providing the number of affected vehicles and the number of replacement parts
it reasonably believes will be available by the “Supply & Launch Deadline” for the
affected Priority Group 9 vehicles in Appendix A.

Extension Request Date
Ford is providing its extension request dates in Appendix B.


Declaration of Todd M. Fronckowiak

|, Todd M. Fronckowiak, declare as follows:

1. | am Assistant Director, Global Automotive Safety Compliance, Automotive Safety Office
for Ford Motor Company.

2. | submit this Declaration in support of Ford’s Notice of Anticipated Shortage and Request
for Extension (“Extension Request”) pursuant to Paragraph 39 of the Third Amendment
to the Coordinated Remedy Order.

3. The contents of the Extension Request are accurate to the best of my knowledge,
information, and belief.

4. | make no representation beyond these contained in this Declaration and, in particular, |
make no representations as to whether this information my change in the future.
| state under penalty of perjury that the foregoing is true and correct.

Executed this eighth day of June, 2018.

T. M. Fronckowiak


Desi Ujkashevic, Global Director Fairlane Plaza South, Suite 400
Automotive Safety Office 330 Town Center Drive
Sustainability, Environment & Safety Engineering Dearborn, Ml 48126-2738

June 8, 2018

Mr. Stephen Hench

Trial Attorney, Litigation & Enforcement
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE, Room W41-227
Washington, DC 20590

Dear Mr. Hench and Mr. Buretta:

Subject: Ford Motor Company Notice of Anticipated Shortage and Request for
Extension for Certain Priority Group 5 - 9 Vehicles - Supplement

Pursuant to Paragraph 39 of the Agency’s Third Amendment to the Coordinated Remedy
Order (ACRO3) dated December 9, 2016, Ford Motor Company (Ford) respectfully requests
an extension to the Supply & Launch Deadline for the following Priority Groups 5 - 9
vehicles as specified in Amended Annex A:

Priority Model

Group Year(s) Make Model Inflator Zone
5 2007-2009 | Ford Edge PAB A
6 2006-2009 | Ford Fusion PAB A
5 2007-2009 | Lincoln | MKX PAB A
5 2006-2009 | Lincoln | Zephyr/MKZ | PAB A
5 2006-2009 | Mercury | Milan PAB A
6 2010 Ford Edge PAB A
6 2007-2008 | Ford Edge PAB Non-A
6 2010-2011 | Ford Fusion PAB A
6 2006-2008 | Ford Fusion PAB Non-A
6 2010 Lincoln | MKX PAB A
6 2007-2008 | Lincoln | MKX PAB Non-A
6 2010-2011 | Lincoln | Zephyr/MKZ | PAB A
6 2006-2008 | Lincoln | Zephyr/MKZ | PAB Non-A
6 2010-2011 | Mercury | Milan PAB A
6 2006-2008 | Mercury | Milan PAB Non-A
7 2012 Ford Fusion PAB A



Appendix A Remedy Part Quantities dune 8, 2018
Sufficient Supply & Parts
Priority Model Affected Remedy Launch Available
Group Year(s) Make Model Inflator Zone __| Vehicles | Deadline per ACROS | Per ACRO5

5 2007-2009 Ford Edge PAB A 105,875 | December 31, 2017 0 (0%)
5 2006-2009 Ford Fusion PAB A 184,182 | December 31, 2017 0 (0%)
5 2007-2009 | Lincoln MKX PAB A 31,711 December 31, 2017 0 (0%)
5 2006-2009 | Lincoln_| Zephyr/MKZ PAB A 41,555 December 31, 2017 0 (0%)
5 2006-2009 | Mercury Milan PAB A 36,697 December 31, 2017 0 (0%)
6 2010 Ford Edge PAB A 43,053 January 31, 2018 0 (0%)
6 2007-2008 | __ Ford Edge PAB | Non-ATM | 111,741 | February 28, 2018 0 (0%)
6 2010-2011 Ford Fusion PAB A 164,470 January 31, 2018 0 (0%)
6 2006-2008 Ford Fusion PAB Non-A “ | 180,406 February 28, 2018 0 (0%)
6 2010 Lincoln MKX PAB A 7,514 January 31, 2018 0 (0%)
6 2007-2008 | Lincoln MKX PAB Non-A | 30,626 February 28, 2018 0 (0%)
6 2010-2011 | Lincoln _|Zephyr/MKZ| PAB A 18,387 January 31, 2018 0 (0%)
6 2006-2008 | Lincoln | Zephyr/MKZ| PAB Non-A | 42,299 February 28, 2018 0 (0%)
6 2010-2011 | Mercury Milan PAB A 12,613 January 31, 2018 0 (0%)
6 2006-2008 | Mercury Milan PAB_ | Non-A“ | 48,103 | February 28, 2018 0 (0%)
7 2012 Ford Fusion PAB A 103,581 February 28, 2018 0 (0%)
8 2009 Ford Edge PAB B 20,480 May 31, 2018 0 (0%)
8 2007-2008 Ford Edge PAB Cc 48,506 June 30, 2018 0 (0%)
8 2009 Ford Fusion PAB B 47,267 May 31, 2018 0 (0%)
8 2006-2008 Ford Fusion PAB Cc 79,111 June 30, 2018 0 (0%)
8 2009 Lincoln MKX PAB B 4,960 May 31, 2018 0 (0%)
8 2007-2008 | _Lincoln MKX PAB Cc 13,269 June 30, 2018 0 (0%)
8 2009 Mercury Milan PAB B 9,014 May 31, 2018 0 (0%)
8 2006-2008 | Mercury Milan PAB ie 22,320 June 30, 2018 0 (0%)
9 2010-2010| Ford Edge PAB B 53,381 June 30, 2018 0 (0%)
) 2009-2009) Ford Edge PAB Cc 10,086 June 30, 2018 0 (0%)
9 2009-2009] Ford Fusion PAB Cc 25,230 June 30, 2018 0 (0%)
Ec) 2010 - 2010] Lincoln MKX. PAB B 9,471 June 30, 2018 0 (0%)
9 2009 - 2009] Lincoln MKX PAB Cc 2,606 June 30, 2018 0 (0%)
9 2010-2010] Lincoln _|Zephyr/MKZ| PAB B 13,436 June 30, 2018 0 (0%)
9 2009 - 2009] Mercury Milan PAB Cc 4,878 June 30, 2018 0 (0%)

( . NHTSA has clarified the definition of "Non-Zone A" as being Zone B.


Mr. Stephen Hench June 8, 2018

(i)

Priority Model

Group Year(s) Make Model Inflator Zone
8 2009 Ford Edge PAB B
8 2007-2008 | Ford Edge PAB Cc
8 2009 Ford Fusion PAB B
8 2006-2008 | Ford Fusion PAB Cc
8 2009 Lincoln _| MKX PAB B
8 2007-2008 | Lincoln | MKX PAB Cc
8 2009 Mercury | Milan PAB B
8 2006-2008 | Mercury | Milan PAB Cc
9 2010 - 2010 | Ford Edge PAB B
9 2009 - 2009 | Ford Edge PAB Cc
9 2009 - 2009 | Ford Fusion PAB Cc
9 2010 - 2010 | Lincoln_| MKX PAB B
9 2009 - 2009 | Lincoln | MKX PAB Cc
9 2010-2010 | Lincoln | Zephyr/MKZ | PAB B
9 2009 - 2009 | Mercury | Milan PAB Cc

Explanation

Ford previously submitted extension requests for these priority groups on

February 9, 2018, April 20, 2018, and May 14, 2018. As Ford indicated in those
extension requests, there have been several development and supplier production
setbacks that could affect part supply and launch timing. At the time of those previous
extension requests, the overall impact that these setback would have on Ford's timing
for vehicles assigned to Priority Groups 5 - 9 was unknown. Ford is submitting this
updated extension request based on current estimated timing that accounts for these
setbacks, summarized below, as well as Ford’s and our supplier's efforts to recover
from these setbacks:

°

On March 26, 2018, an event occurred at Autoliv’s Promontory, Utah inflator
production facility that halted manufacturing operations. After working to
determine root cause and instituting recommended preventative actions, Autoliv
resumed production of airbag inflators for recalls on May 8, 2018.

During Design Validation / Production Validation testing on the 2010-2012 MY
Ford Fusion/Milan/MKZ airbag module, a stopper plate deformed during static
deployment testing. The purpose of the stopper plate is to retain two airbag
inflator spacer sleeves that are used to hold the replacement airbag inflator. A
detailed engineering investigation was launched with Joyson Safety Systems,
robustness actions were identified, and Ford estimates validation testing on a
redesigned stopper plate will be completed by July 13, 2018.

During Production Validation testing for the 2007-2010 MY Lincoln MKX, Joyson
engineers identified a tear in the airbag cushion side panel due to an interaction
with the instrument panel during static deployment. After evaluating several
design alternatives, Joyson has identified airbag cushion fabric changes to
address the testing issue. Joyson’s estimated completion timing is July 20, 2018.

-2-


Confidential Business Information

Mr. Stephen Hench June 8, 2018

(ii)

e On May 23, 2018, Joyson personnel observed a tear in the airbag cushion that
occurred during static deployment tests as part of its production Lot Acceptance
Testing (LAT) on a batch of production parts for the 2007-2010 MY Ford Edge
Joyson engineers continue to investigate the issue and are in the process of
determining root cause for the LAT failure. Based on the latest information
available, Joyson currently estimates this effort will be completed by
June 29, 2018.

As a result of the above supplier setbacks and constraints, Ford recognizes that
meeting certain owner notification dates, requested in our February 9, 2018 extension
request, may not be possible. Ford is continuing to work with Joyson to correct the
issues previously described and to optimize part production as quickly as possible
Ford notes that these supplier production issues have been communicated and
discussed with the Agency and the Takata Independent Monitor in their regularly
scheduled meetings in April and May 2018.

Remedy Part Selection, Validation, and Development Process

With the unprecedented urgency to provide service airbag inflators, Ford created a
dedicated team of product development engineers, supported by service engineers,
purchasing, and part supply and logistics staff to identify opportunities to reduce the
time to bring inflator service parts to market. Under normal circumstances,
manufacturers require several years to design, develop, and validate original
equipment airbag modules. In contrast, to develop replacement Takata airbag inflator
replacement parts, Ford developed innovative methods to reduce the time to provide

service parts. A brief description of Ford’s recall service part development and
validation process is provided