Desi Ujkashevic, Global Director 

Automotive Safety Office 

Susta inability, Environment & Safety Engineering 

Fairlane Plaza South, Suite 400 

330 Town Center Drive 

Dearborn , Ml 48126-2738 

April 20, 20 18 

Ms. Arija Flowers 

Trial Attorney , Litigat ion & Enforcement 

National Highway Traffic Safety Admin istration 

1200 New Jersey Avenue , S.E. 

Wash ington , DC 20590 

Dear Ms. Flowers : 

Subject: Ford Motor Company Notice of Anticipated Shortage and Request for Extens ion 

In accordance with Paragraph 39 of the Agency's December 9, 20 16, Third Amendment to 

the Coordinated Remedy Order ("ACRO"), Ford Motor Company (Ford) is updating its 

request for an extension to the Supply & Launch Deadlines for certa in vehic les in Priority 

Groups 5 - 8. 

On February 11, 2018, Ford notified the Agency that owner notification letter mail dates may 

be delayed due to difficulties identified during production line validation tria ls and that Ford 

was in the process of dete rmining the effect on its extension request dates. This letter 

amends Ford's February 9, 2018 extension request subm ission with updated timing. 

(i) Explanat ion (Validation & Supply Updates) 

2007-2010 MY Lincoln MKX 

During reca ll service part design validation testing, Ford identified a tear in the airbag 

cush ion due to interaction with the instru ment panel during deployment. Ford and 

Takata are invest igating severa l modifications to eliminate the cond ition , including 

revis ing the cushion folds or adding an extra layer of protect ive fabr ic. Presently Ford 

estimates that the validation testing of required countermeasures will be completed by 

May 11, 2018, and Ford has adjusted owner letter mailing dates accordingly . To 

minimize the effect of this delay on othe r vehicle lines, Ford has asked Takata to 

produce additional 2007 - 2010 MY Ford Edge passenger airbag modules during the 

time MKX module production was origina lly scheduled. 
Ms. Arija Flowers - 2 - April 20 , 20 18 

2006 -2009 MY Lincoln MKZ 

During production line validation trials , Takata ident ified a feature on the 2006 - 2009 

MY Lincoln MKZ airbag module housing stamping that could damage the airbag 

cush ion pack during the final module assembly process. Ford requested revisions to 

the airbag module housing to eliminate the risk of damage to the airbag cushion pack 

during assembly. 

For both of these issues, Ford is work ing diligent ly with Takata to validate 

countermeasures and to minimize the impact of these delays . 

(ii) Remedy Part Selec tion, Validation , and Development Process 

Ford's design, development , and validation process for the effected serv ice parts has 

been previously provided to the Agency. 

(iii) Sufficient Remedy Part Supply Sourcing 

Ford has secured dua l stage airbag inflater production capacity from Autoliv and airbag 

modu le assembly capacity from Joyson Safety Systems (Takata) in order to 

man ufacture updated passenger airbag modules with new Autol iv APPS-7 inflators . 

(iv) Replacement Part Quantit ies 

Ford is providing the number of affected vehicles as reported in the January 19, 2018 

Monitor Dashboard and the number of replacement parts it reasonably believes will be 

available by the "Supply & Launch Deadl ine" specified in the Fifth Amendment in 

Append ix A. 

(v) Extension Request Date 

Ford is provid ing an update to the Requested Supply & Launch Dates in Appendix B. 

Inflater Production Concerns 

Add itiona lly, as the Agency is aware , on March 26, 2018, an tragic event occu rred on one of 

two mixing stations at Auto liv's Promontory , Utah, airbag inflater product ion facil ity. After 

halting man ufacturing operat ions, Autoliv , in conjunction with multiple governmental 

agencies , began investigating the root cause of the event and dete rmining prevent actions . 

It is Ford's understand ing that Autoliv has resolved the issues identified during the 

investigation and has also purchased replacement mixing station equip ment to allow 

resumpt ion of manufacturing . Ford and Autol iv cont inue to eva luate this production 

disruption to existing plans and will keep the Agency app raised of any part supply or launch 

timing impacts as details become available . 

If you have any quest ions concerning this response, please feel free to contact me. 

Sincerely , 

Desi Ujkashev ic 

Attachements 

r
Declaration of Todd M. Fronckowiak 

I, Todd M. Fronckowiak, declare as follows : 

1. I am Assistant Director, Global Automotive Safety Compliance , Automotive Safety Office 

for Ford Motor Company. 

2. I 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. I make no representation beyond these contained in this Declaration and, in particular , I 

make no representat ions as to whether this information may change in the future. 

I state under penalty of perjury that the foregoing is true and correct. 

Executed this Twe ntieth day of April, 2018. 

T. M. Fronckowia k 
Appendix A Remedy Part Quantities 

Sufficient S

Priority Model Vehicles Remedy L

Group Year(s) Make Model Inflator Zone Affected Deadline per 

5 2007-2009 Lincoln MKX PAB A 31,711 December 3

5 2006-2009 Lincoln Zephyr/MKZ PAB A 41,555 December 3

6 2010 Lincoln MKX PAB A 7,514 January 31

6 2007-2008 Lincoln MKX PAB (1) Non-A 30,626 February 28

6 2010-2011 Lincoln Zephyr/MKZ PAB A 18,387 January 31

6 2006-2008 Lincoln Zephyr/MKZ PAB (1) Non-A 42,299 February 28

7 2012 Lincoln Zephyr/MKZ PAB A 12,781 February 28

8 2009 Lincoln MKX PAB B 4,960 May 31, 

8 2007-2008 Lincoln MKX PAB C 13,269 June 30, 

8 2009 Lincoln Zephyr/MKZ PAB B 7,966 May 31, 

8 2006-2008 Lincoln Zephyr/MKZ PAB C 18,209 April 30, 

(1) NHTSA has clarified the definition of “Non-Zone A” as being Zone B.
Appendix B Requested Supply and Launch Dates 

ACRO5 Sufficient O

Priority 

Group

Model

Year(s) Make

Model, Inflator Position 

(Zone)

& Supply & Remedy 

Launch Dates

S

5 2007-2009 Lincoln MKX PAB (A) December 31, 2017 

5 2006-2009 Lincoln Zephyr/MKZ PAB (A) December 31, 2017 

6 2010 Lincoln MKX PAB (A) January 31, 2018 

6 2007-2008 Lincoln MKX PAB (Non-A) February 28, 2018 N

6 2010-2011 Lincoln Zephyr/MKZ PAB (A) January 31, 2018 N

6 2006-2008 Lincoln Zephyr/MKZ PAB (Non-A) February 28, 2018 

6 2012 Lincoln Zephyr/MKZ PAB (A) February 28, 2018 N

8 2009 Lincoln MKX PAB (B) May 31, 2018 

8 2007-2008 Lincoln MKX PAB (C) June 30, 2018 N

8 2009 Lincoln Zephyr/MKZ PAB (B) May 31, 2018 

8 2006-2008 Lincoln Zephyr/MKZ PAB (C) April 30, 2018 

(1) These dates include some additional contingency timing to account for minor unforeseen c

will continue to work to launch final remedy parts as quickly as possible.