Good Morning - My name is Stephen Mahan, and I represent Delphi Automotive Systems.
Delphi is the world’s largest supplier of automotive components and systems. Our customers
include many of the vehicle manufacturers represented here today. Delphi also supplies the
aftermarket service community with components, systems and information.

I have been involved in the development and application of subsystems and components used by
vehicle manufacturers to meet the OBD regulations. I have also trained members of the aftermarket 
service community in various aspects of OBD.

Thank you for the opportunity to speak this morning. I intend to be brief.

The specific area of concern to Delphi is in paragraph g.5 of the proposed rules, entitled
REQUIRED INFORMATION, under § i, where the regulations call for the posting of

" (i) manuals, including subsystem and component manuals, technical service bulletins, recall
service information, diagrams, charts, and training materials."

Delphi believes that this wording is overly broad in its scope and overly specific, and may
result in the dissemination of proprietary information. This is in direct conflict with the intent 
stated in the preamble. Please let me explain.

The Agency has recognized that many components and subsystems are supplied to the
vehicle manufacturers by Tier 1 suppliers such as Delphi. When a supplier sells a product to a
vehicle manufacturer, we don’t just provide parts that show up on the vehicle assembly line on the first 
day of production. Over the course of the vehicle development process, much information related to the 
design and manufacture of components is communicated to the vehicle manufacturer. This information is 
often proprietary. And it often comes in the form of a component manual. 

These manuals are created for the vehicle manufacturers’ engineering groups to assist in the application 
of our components to their vehicle platforms. This information is not disseminated to the service 
community or the OEM dealerships.

However, when product information is supplied to a vehicle manufacturer, the supplier loses
control of it. There is nothing to stop a manufacturer from posting this information on a service website 
in an attempt to meet their interpretation of the regulation.

It is Delphi’s opinion that the proposed wording in the regulations may lead to either willful
or inadvertent dissemination of a supplier’s proprietary information by a vehicle manufacturer.

Delphi supports the dissemination of appropriate service information. However, we believe that
paragraphs ¶2 and ¶5 of that section of the rules [§G.2.ii.E (Maintenance Instructions; Emissions control 
diagnostic service information; General Requirements; Definitions)] are sufficiently broad to encompass 
the pertinent component and subsystem information important for the diagnosis and repair of vehicles.

Therefore Delphi recommends that the EPA remove the words ‘including subsystem and
component manuals’ from the regulations. We recommend that the wording for each of these
paragraphs be revised as follows.

§g.2.ii.E.1 “Service manuals; technical service bulletins (TSBs); recall service information;
diagrams, charts and training materials. “

The EPA will still meet its legislative requirements with this change, without exposing the Tier
1 suppliers to the loss of proprietary information.

Thank you for the opportunity to present this information, and I will entertain any [further]
questions at this time.