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For engine braking it doesn't matter if you are above the torque curve. Just select a low enough gear to achieve DFCO. Means you have to use it a lot later in the slow down cycle, but that doesn't mean you have to lose the benefit entirely.
I had an incident today, when I changed into 3rd at 50 mph, to slow for traffic building up ahead. Recorded about 4,000 rpm.
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