1

Sutton, Tia

From: Sutton, Tia

Sent: Thursday, June 11, 2015 7:10 PM

To: Timothy.Mullins@dot.gov; Chad_S_Whiteman@omb.eop.gov; Chandana_L.

_Achanta@omb.eop.gov

Cc: james.tamm@dot.gov; Hengst, Benjamin; Spears, Matthew; Moulis, Charles

Subject: RE: Questions from OMB on 6/10 passback - UPDATE

Hi everyone, 

Sorry for the additional email, but I had a page numbering issue and missed one of the Interagency comments from the 

6/5 file. I was able to get into the active Master Preamble file and have confirmed that this Interagency comment was in 

fact accepted. Please see highlighted text below for the update. 

Tim- if you wouldn’t mind, could you copy this new text into the Word doc that you sent at 6:01pm and resend to Chad 

& Chandana? 

Thanks, 

 Tia 

• p. 46, “EO12866: This section discusses alternative 3. Suggest removing the reference to alternative 4 as it is 

discussed in other parts of the document.”: 

 EPA has reached out to NHTSA to discuss this item further today. The teams will follow up on this 

item ASAP, once the agencies have had an opportunity to confer. 

• p. 48, “EO12866: Suggest adding “and we are seeking comment on the relative risks and benefits of this 

approach”: 

 NOW READS: 

As discussed throughout this document, the agencies believe Alternative 4 has potential to be the 

maximum feasible alternative, however, based on the evidence currently before us, the agencies have 

outstanding questions regarding relative risks and benefits of that option in the timeframe envisioned. 

We are seeking comment on these relative risks and benefits. 

• p. 218, “EO12866: On page 75, EPA/NHTSA walk through three alternative ways of calculating cost 

effectiveness expressed as cost/ton of CO2 equivalent. One of the alterntiaves makes the estimate without 

acounting for the fuel savings and another alternative does. Suggest adding a footnote taken from the

language on page 75: If accounting for the fuel savings in the cost effectiveness estimate to offset the 

technology costs, net costs per ton of GHG emissions reduced would be negative under the proposed 

standards.”: 

 NOW READS: 

The agencies also regard these reductions as cost-effective, even without considering payback period. 

The agencies estimate the cost per metric ton of CO2eq reduction without considering fuel savings to be

$20 in 2030, and we estimate the cost per gallon of avoided fuel consumption to be about $0.25 per 

gallon, which compares favorably with the levels of cost effectiveness the agencies found to be 

reasonable for light duty trucks. [FN: If using a cost effectiveness metric that treats fuel savings as a 

negative cost, net costs per ton of GHG emissions reduced or per gallon of avoided fuel consumption 

would be negative under the proposed standards.] 
2

• p. 219, “EO12866: But agencies should also note that there would be a greater overall net benefit with

alternative 4. Suggest adding a sentence at the end of this paragraph that states that alternative 4 would 

provide earlier GHG reductions.”: 

 NOW READS: 

Alternative 3 is generally designed to achieve the levels of fuel consumption and GHG reduction that 

Alternative 4 would achieve, but with several years of additional lead-time – i.e., the Alternative 3 

standards would end up in the same place as the Alternative 4 standards, but several years later, 

meaning that manufacturers could, in theory, apply new technology at a more gradual pace and with 

greater flexibility. However, Alternative 4 would provide earlier GHG benefits compared to Alternative 

3. {The added sentence suggested by Interagency reviewers is the underlined sentence.}

• p. 848, “EO12866: This regulation deals with one of the forms that falls within the scope of the electronic filing 

requirments set forth in E.O. 103659 (Feb. 19, 2014), and importers already are required to store the 

accompanying records. The commenter recommends modification of the regulation to reflect the mandated

transition to electronic submission, which must occur no later than December 31, 2016.”: 

 REG TEXT NOW READS: 

(d) Complete the appropriate EPA declaration form before importing any engines or equipment. These 

forms may be submitted and stored electronically and are available on the Internet at 

http://www.epa.gov/OTAQ/imports/ or by phone at 734-214-4100. Importers must keep the forms 

these records for five years and make them available promptly upon request.

-----Original Message----- 

From: Timothy.Mullins@dot.gov [mailto:Timothy.Mullins@dot.gov] 

Sent: Thursday, June 11, 2015 6:01 PM 

To: Chad_S_Whiteman@omb.eop.gov; Chandana_L._Achanta@omb.eop.gov 

Cc: james.tamm@dot.gov; Sutton, Tia; Hengst, Benjamin; Spears, Matthew 

Subject: Fw: Questions from OMB on 6/10 passback 

Attached please find our updated response, per your earlier conversation with EPA. 

Thanks 

Tim 

From: Timothy.Mullins@dot.gov<mailto:Timothy.Mullins@dot.gov> [mailto:Timothy.Mullins@dot.gov] 

Sent: Wednesday, June 10, 2015 11:57 AM 

To: Chad_S_Whiteman@omb.eop.gov<mailto:Chad_S_Whiteman@omb.eop.gov>; Hengst, Benjamin; Sutton, Tia; 

james.tamm@dot.gov<mailto:james.tamm@dot.gov> 

Cc: Chandana_L._Achanta@omb.eop.gov<mailto:Chandana_L._Achanta@omb.eop.gov> 

Subject: RE: EO 12866 Interagency Comments on HD Phase II NOPR 

Chad and Chandana, 

We have accepted and incorporated these specific interagency recommended edits, except as noted and explained in 

the attached file. 

Thanks, 

Tim 

From: Whiteman, Chad [mailto:Chad_S_Whiteman@omb.eop.gov] 

Sent: Friday, June 05, 2015 5:57 PM 

To: 'Hengst, Benjamin'; 'Sutton, Tia'; Mullins, Timothy (OST); Tamm, James (NHTSA) 
3

Cc: Achanta, Chandana L. 

Subject: RE: EO 12866 Interagency Comments on HD Phase II NOPR 

All, Few responses to the redline passback from 5_29. Please let me know if you would like to discuss. Thanks, Chad