Document 10w6GEVJDmYq72ozQV3q8bQmo

NVMA supports "an exemption process for essential uses without substi tutes". EPA should propose exemption procedure. Exemptions for aftermarket required. HVMA requests that EPA allow at least two full years between promulgation and the effective date of any regulatory action. Individual member companies will provide additional comments on this matter of timing. Truck and Equipment Manufacturers Wagner Phase-down proposed in Option 3 10 year period represents too great a highway safety risk. Brake strip friction material must be exempted from Option 3, and 5 year options 1 and 2. Recommend EPA establish mechanism for exemption procedure. Request (1) an exemption on drum brake strip lining, and (2) extension of 5-year ban option for disc brake pads used on older vehicles. . Navistar 3-1/2 to 4 years lead time to develop and incorporate new material into any product. One-year not enough lead time for brake linings.. Exemption required for replacement parts. Navistar supports Alternative 1 (5 years) if certain modifications are made: Year Percent ~T ~30 7 24 8 18 9 12 10 6 11 0 121