GENERAL MOTORS LLC 

Global Vehicle Safety 

June 28, 2018	 VIA EMAIL 

Stephen Hench 

Trial Attorney, Litigation & Enforcement 

National Highway Traffic Safety Administration USG 4760 1200 New Jersey Ave, SE, Room W41-227 

Washington, DC 20590 NHTSA-2015-0055

Re:	 General Motors LLC’s Amended Request to Modify Certain Sufficient Supply and 

Launch Deadlines under Paragraph 39 of the Third Amendment to the Coordinated 

Remedy Order (the “Extension Request”) 

Dear Stephen: 

On August 25, 2017, GM requested, pursuant to paragraph 39 of the Third Amendment to 

the Coordinated Remedy Order (the “ACRO”), that NHTSA modify the Sufficient Supply and 

Launch Deadlines for the GMT900 vehicles covered by GM’s Inconsequentiality Petitions (the 

“GMT900 Vehicles”). Since that filing, GM and ZF (formerly TRW), GM’s replacement inflator 

supplier, have made substantial progress preparing to conduct a remedy campaign, if necessary, 

on the GMT900 Vehicles and in assembling a substantial bank of PPI3 guanadine nitrate 

replacement inflators—progress detailed in the October 16, 2017, January 2, 2018, and March 28, 

2018 Sufficient Supply and Remedy Launch Certification Reports (the “Supply Reports”) that 

GM submitted to the Agency. 

Drawing on repair-rate data from other GM recalls, including recalls of Takata airbag 

inflators, GM recently conducted an in-depth analysis of its readiness to launch a recall campaign 

on the GMT900 Vehicles. Based on this analysis, GM hereby amends its August 2017 Extension 

Request to account for the following facts and developments: 

1. Priority Group Six GMT900 Vehicles 

As of June 21, 2018, GM had approximately 486,000 replacement inflators in its 

warehouse in Pontiac, Michigan. Totaling approximately 2.5 million GMT900 Vehicles, Priority 

Group Six is the largest of the priority groups covered by GM’s petitions; the other three priority 

groups together total only 1.6 million vehicles. Even with a substantially larger bank of 

replacement parts, GM’s analysis indicates that launching all 2.5 million vehicles in Priority Group 

Six simultaneously could rapidly deplete GM’s bank, stress GM’s dealer network, and delay the 

launch of subsequent priority groups. 

2. GM’s January 2018 Third Inconsequentiality Petition 

GM’s original August 2017 Extension Request included GMT900 Vehicles in Priority 

Groups Six, Seven, and Eight, then the only GMT900 Vehicles covered by one of GM’s Petitions. 

In January 2018, GM filed its Third Inconsequentiality Petition, which covered Priority Group 

Nine vehicles. Under the ACRO, these vehicles would have been scheduled to launch on June 30, 

2018. 

1
 
3.	 Unforeseen ZF Supply Delays 

Under its contracts with GM, ZF committed to supply GM with replacement inflators in 

the following volumes: (i) 900,000 in 2018; (ii) 1,095,000 in 2019; and (iii) 1,525,000 in 2020. 

Citing supply constraints, ZF has been unable, thus far, to supply GM with replacement inflators 

at the contracted rate of 900,000 parts-per-year that GM paid for under its capacity reservation and 

supply agreements with ZF. Over the last few months, ZF has not met GM’s supply releases and 

informed GM that it was unable to supply more than approximately 50,000 replacement inflators 

per month. 

GM is actively working with ZF to increase this production rate. On June 20, 2018, at 

GM’s insistence, ZF committed to increase production of replacement inflators, but not to the 

extent required to supply GM with the promised 900,000 replacement inflators in 2018. Moreover, 

ZF has indicated to GM that it will backload 2019 replacement inflator shipments to the end of 

2019, further disrupting GM’s near-term capacity to build a bank of replacement parts and 

replenish that bank if a launch occurs. Although ZF’s unexpected production shortfalls have 

delayed GM’s progress in assembling its bank of replacement inflators, GM has still amassed a 

bank of approximately 486,000 replacement inflators as of June 21, 2018, and expects to have 

900,000 by the end of 2018. 

4.	 GM’s Amended Request For Relief 

To facilitate an orderly launch and avoid part shortfalls, GM’s revised launch schedule, 

attached as Exhibit B,

1

 divides the 2.5 million GMT900 Vehicles in Priority Group 6 into three 

tranches: (i) Tranche A, containing 2007-2008 Zone A vehicles; (ii) Tranche B, containing 2009­

2011 Zone A vehicles; and (iii) Tranche C, containing 2007-2008 Zone B vehicles. Because 

GM’s three Petitions remain pending, GM’s proposed launch dates are calculated from the 

effective date of a final order denying the Petitions (a “Final Order”). 

After the Final Order, GM’s proposed launch schedule provides for a 120-day ramp-up 

period, which will allow GM to: 

•	 notify the approximately 1 million owners of GMT900 Vehicles in Priority Group 

Six Tranche A (owner notification for each subsequent launch will commence at 

the start of its corresponding launch date); 

•	 secure sufficient hazardous material transportation and logistics support to 

transport large volumes of replacement inflators from GM’s central warehouse in 

Pontiac, Michigan to GM dealers nationwide; and 

1

 GM’s revised launch schedule is based on GM’s current replacement inflator bank and ZF’s most recent 

representations regarding its capacity commitment to supply GM with replacement inflators. The launch schedule is 

subject to change as GM continues to build its bank of replacement inflators and work with ZF on increasing its 

production rate. 

2
 
Brief; which collectively de1nonstrate that: 

• 	 GM and ZF have been working_ diligently and with urgency to prepare to replace 

the inflators in the GMT900 Vehicles, if ultimately required. Originally delayed 

by unanticipated engineering challenges, GM and ZF have built nearly half-amil!ion replace1nent inflators for use as a potential remedy cpmponent. Throughout 

this process, GM has kept NHTSA apprised of its progress through the Supply 

Reports. 

• 	 Granting GM's request will not adversely impact consu1ners. The facts and 

evidence that GM has supplied in its Petitions, August 2017 Supplemental Brief, 

and in regular updates establishes that the inflators in the GMT900 Vehicles are not 

at risk ofrupture. 

• 	 Modifying the launch dates for the GMT900 Vehicles in the manner requested will 

preserve the ACRO's orderly launch phasing, prevent unanticipated parts 

shortages, and permit the further prioritization of limited production and supply 

resources to other inflators in these priority groups that, to date, have not been as 

rigorously tested and analyzed for risk of ruptW'e as the inflators in the GMT900 

Vehicles. See ACRO ~~ 33-34. 

Please contact 1ne if you have any questions. Nothing in this request is intended to 

supersede or prejudice any of the positions taken, arguments made, or evidence presented in the 

ad1ninistrative record ofthe pending Petitions. 

Sincerely, 

?lbr-~~ 

Maryann L. Combs 

Vice President, Global Vehicle Safety 

General Motors LLC 

3 

EXHIBIT A
 
UNITED STATES DEPARTMENT OF TRANSPORTATION
 

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
 

In re: 

Docket No. NHTSA-2015-0055 

Coordinated Remedy Program Proceeding 

DECLARATION OF MARYANN COMBS IN SUPPORT OF GENERAL MOTORS
 

LLC’S AMENDED REQUEST TO MODIFY CERTAIN SUFFICIENT SUPPLY AND
 

REMEDY LAUNCH DEADLINES UNDER PARAGRAPH 39 OF THE THIRD
 

AMENDMENT TO THE COORDINATED REMEDY ORDER
 

Maryann Combs, pursuant to 28 U.S.C. § 1746, hereby declares as follows: 

1. I am the Vice President of Global Vehicle Safety for General Motors LLC (“GM”), 

and I am authorized to submit this Declaration on GM’s behalf. 

2. I submit this Declaration under paragraph 39 of the Third Amendment to the 

Coordinated Remedy Order in the above-captioned proceeding and in support of GM’s Amended 

Request to Modify Certain Sufficient Supply and Launch Deadlines under Paragraph 39 of the 

Third Amendment to the Coordinated Remedy Order (the “Request”). 

3. GM will promptly supplement the Request if GM becomes aware of any 

information that contradicts the statements in the Request, and will continue to keep NHTSA 

informed on the status of its efforts to produce replacement inflators for the GMT900 Vehicles. 

4. The contents of the Request are complete and accurate to the best of my knowledge, 

information, and belief. 
~a<~ 

Maryann L. Combs 

Vice President, Global Vehicle Safety 

General _Motors LLC 
EXHIBIT B
 
EXHIBIT B 

Summary of Requested Relief 

Current ACRO Requested ACRO Zone NHTSA No. MY Models Priority Group Launch Deadline Launch Deadline 

Zone A 16V381 2007-2008 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Suburban, Tahoe, 

GMC: Sierra 1500, Yukon, Yukon XL 

6 (Tranche A) 9/30/2017 120 days after 

Final Order 

Zone A 16V381 2009-2011 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe, 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

6 (Tranche B) 9/30/2017 9 months after 

PG6 Tranche A* 

Zone B 16V383 2007-2008 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Suburban, Tahoe 

GMC: Sierra 1500, Yukon, Yukon XL 

6 (Tranche C) 9/30/2017 9 months after 

PG6 Tranche B* 

Zone A 17V010 2012 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

7 12/31/2017 90 days after PG6 

Tranche C* 

Zone B 17V019 2009 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

8 3/31/2018 90 days after 

PG7* 

Zone C 17V021 2007-2008 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Suburban, Tahoe 

GMC: Sierra 1500, Yukon, Yukon XL 

8 3/31/2018 90 days after 

PG7* 

Zone A 18V027 2013 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

9 6/30/2018 90 days after 

PG8* 

Zone B 18V028 2010 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

9 6/30/2018 90 days after 

PG8* 

Zone C 18V029 2009 

Cadillac: Escalade, Escalade ESV, 

Escalade EXT 

Chevrolet: Avalanche, Silverado 1500, 

Silverado 2500/3500, Suburban, Tahoe 

GMC: Sierra 1500, Sierra 2500/3500, 

Yukon, Yukon XL 

9 6/30/2018 90 days after 

PG8* 

*Based on most recent ZF representations regarding its 

capacity commitment to supply GM with replacement 

inflators