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### Sutton, Tia

From: Sutton, Tia
Sent: Thursday, June 11, 2015 7:10 PM
To: Timothy.Mullins@dot.gov; Chad_S_Whiteman@omb.eop.go v; Chandana_L. _Achanta@omb.eop.gov
Cc: james.tamm@dot.gov; Hengst, Benjamin; Spears, Matth ew; Moulis, Charles Subject: RE: Questions from OMB on 6/10 passback - UPDATE

Hi everyone, Sorry for the additional email, but I had a page nu mbering issue and missed one of the Interagency com ments from the 6/5 file. I was able to get into the active Master P reamble file and have confirmed that this Interagen cy comment was in fact accepted. Please see highlighted text below f or the update.

Tim - if you wouldn’t mind, could you copy this new tex t into the Word doc that you sent at 6:01pm and res end 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 opportunit y to confer.

• p. 48, “EO12866: Suggest adding “and we are seekin g comment on the relative risks and benefits of thi s 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 throug h three alternative ways of calculating cost effectiveness expressed as cost/ton of CO2 equivale nt. One of the alterntiaves makes the estimate wit hout acounting for the fuel savings and another alternat ive does. Suggest adding a footnote taken from the language on page 75: If accounting for the fuel sav ings in the cost effectiveness estimate to offset t he technology costs, net costs per ton of GHG emission s reduced would be negative under the proposed
standards. ”:  NOW READS: The agencies also regard these reductions as cost-e ffective, even without considering payback period. The agencies estimate the cost per metric ton of CO 2 eq 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 c ost effectiveness metric that treats fuel savings a s a negative cost, net costs per ton of GHG emissions r educed or per gallon of avoided fuel consumption would be negative under the proposed standards.]2

• p. 219, “EO12866: But agencies should also note tha t there would be a greater overall net benefit with alternative 4. Suggest adding a sentence at the en d 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 Alt ernative 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 Alternativ e 3. { The added sentence suggested by Interagency reviewe rs 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 mod ification of the regulation to reflect the mandated transition to electronic submission, which must occ ur no later than December 31, 2016.”:  REG TEXT NOW READS: (d) Complete the appropriate EPA declaration form b efore importing any engines or equipment. These forms may be submitted and stored electronically an d 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 availabl e promptly upon request.

-----Original Message----- From: Timothy.Mullins@dot.gov [mailto:Timothy.Mulli ns@dot.gov] Sent: Thursday, June 11, 2015 6:01 PM To: Chad_S_Whiteman@omb.eop.gov; Chandana_L._Achant a@omb.eop.gov Cc: james.tamm@dot.gov; Sutton, Tia; Hengst, Benjam in; 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.Mullin s@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_White man@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 Ph ase II NOPR

Chad and Chandana, We have accepted and incorporated these specific in teragency recommended edits, except as noted and ex plained in
the attached file. Thanks,
Tim

From: Whiteman, Chad [mailto:Chad_S_Whiteman@omb.eo p.gov] Sent: Friday, June 05, 2015 5:57 PM To: 'Hengst, Benjamin'; 'Sutton, Tia'; Mullins, Tim othy (OST); Tamm, James (NHTSA)3 Cc: Achanta, Chandana L. Subject: RE: EO 12866 Interagency Comments on HD Ph ase II NOPR

All, Few responses to the redline passback from 5_ 29. Please let me know if you would like to discus s. Thanks, Chad