November 14, 2006

Mr. Daniel C. Smith, Associate Administrator
National Highway Traffic Safety Administration (NSA-01)
Room 5321, Mail Code NVS-010
400 7th Street, SW., Washington, DC 20590

Re: DEFECT INFORMATION REPORT

Dear Mr. Smith,

Pursuant to Part 573 of Title 49 of the Code of Federal Regulations, Volvo Cars of North America, LLC (Volvo) submits the following information concerning a safety recall program that it is initiating for a concern believed by the National Highway Traffic Safety Administration (NHTSA) as being safety related. Volvo does not share this belief, for the reasons set forth below, but has decided to proceed in this manner.

1. Vehicle Manufacturer
Volvo Car Corporation
Gothenburg, Sweden

Designated Agent
Volvo Cars of North America
Rockleigh, New Jersey 07647

2.Identification of Vehicles involved.

The vehicles involved in this recall are the specific Volvo models as identified below:
MY1999 to MY2001 Volvo models (not including the Volvo S40 and V40 models)
MY2002 Volvo S60 and V70 with naturally aspirated engines
MY2002 Volvo C70
The remedy for this is a software upgrade which was already introduced by Volvo on March 16, 2006. As of today more than 161,202 Volvo vehicles as specified above have already been provided this software upgrade. Vehicles that already have the upgraded software are not included in this recall action.
Starting with MY2002 a new electronic throttle module was introduced into the Volvo vehicle models specified above. Vehicles with this new electronic throttle module are not included in this action.
The approximate number of the involved vehicles are as follows:
The recalled model population is taken from the total population of vehicles as described above.

3.Number of Vehicles Potentially Affected.
The number of vehicles potentially affected by this recall in the U.S. is approximately 170,099.

4.Estimated percentage of Vehicles with the Defect.
Unknown.

5.Description of the Defect.

In certain of the involved vehicles, a combination of throttle positioning sensor irregularities, a dirty throttle housing, and/or inefficient software calibration may cause a warning lamp to light and the subsequent onset of limp home modes. This resulted in a high number of these vehicles going into limp home mode without need. For the many reasons discussed during the course of the NHTSA Engineering Analysis related to this subject, Volvo does not believe that the condition that was the subject of that investigation presents an unreasonable risk to safety. Nonetheless, to avoid a protracted discussion with the agency, Volvo has decided to take this action.
The corrective action is to have the current software upgrade installed onto the involved vehicles.
All vehicles as specified in #2 above will be recalled and remedied.

6.Chronology of Events.
November 9, 2006 Volvo Decision
November 14, 2006Notification to NHTSA

7.Program for Remedy of Defect.
All involved vehicles that have not yet had the software download solution will be subject to the recall. Vehicle owners will receive a letter via first class mail. The letter will request that the owner of the vehicle take the vehicle to a Volvo retailer for remedy.

A schedule for notification to the dealers/retailers and customers will be provided to NHTSA at a future date. We are striving to implement this action as soon as possible.

8.Copies of Notices, Bulletins, etc.
Formal retailer notices, bulletins and other communications have not been completed. Copies of all such information will be forwarded to NHTSA as soon as they are available.

Owners that have paid to have an affected vehicle remedied prior to the recall will be reimbursed with proper documentation.

9.Proposed Owner Notification Letter.
A draft copy of Volvo's Owner notification letter will be submitted to NHTSA for approval no fewer than five (5) Federal Government Business Days before Volvo intends to begin mailing it to owners.

10.The Manufacturer's Campaign Number.
Volvo has assigned Volvo Campaign Number R155 to this Safety Recall Campaign.

If you have any questions regarding this report please contact: Diana Lidgett (201) 768-7300 X7249 phone, (201) 784-4989 fax, dlidgett@volvocars.com or myself.

Sincerely yours,

VOLVO CARS OF NORTH AMERICA, INC.
Customer Service

William Shapiro, P.E.
Manager, Regulatory and Product Compliance