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Received Date: May 19 2011, at 12:00 AM Eastern Daylight Time

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2011-05-19 Joint Comment (received after comment close date May 18, 2011) stating that that modeling approaches make sense for low volume and custom products and can reduce testing costs for manufacturers; and that some of these issues are quite complicated and DOE’s expeditious start should help avoid any further delay in the compliance date for rules that allow for workable AEDMs.

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