Document 4abxVvzZ4XMmoK3LKK9NjNw5j

Unrealistic lead times. Alternatives 1 or 2 would be more equitable. Exempt spare parts for earlier models. Toyota Opposed to applying rule for replacement parts to earlier models. Against proposed phase-down over 10 years. Prefer staged ban. Friction products--5 year lead time Gaskets--10 year lead time Insulators--5 year lead time National Automobile Dealers Association EPA should consider a simple, streamlined model-year-based ban on new vehicle parts. Avoid regulating replacement parts. EPA should consider Ban beginning in a given model year for new vehicles No regulation of replacement parts EPA and manufacturer should determine year(s) of ban on different products. American Motors Corporation Recommends More realistic timetable develop guidelines for exemption EPA should ban asbestos use in specific products, such as disc brakes, rather than a product category, such as friction material. Develop guidelines for exemptions. Lead time needs can only be adequately addressed under a product-specific regulation. This is major reason AMC opposes the phase-down scheme proposed by EPA. Motor Vehicles Manufacturers Association Schedule for implementation must be contingent upon the availability of suitable substitute materials so that safety and braking performance are not compromised. Lead times proposed are unrealistic. MVMA supports "an exemption process for essential uses without substitutes". 120