From: William Charmley/AA/USEPA/US 

To: Dominic_J._Mancini@omb.eop.gov, Chandana_L._Achanta@omb.eop.gov 

Cc: Robin Moran/AA/USEPA/US@EPA, rebecca.yoon@dot.gov, james.tamm@dot.gov, 

steve.wood@dot.gov, Maureen Delaney/DC/USEPA/US@EPA, John 

Hannon/DC/USEPA/US@EPA, Steven Silverman/DC/USEPA/US@EPA 

Date: 03/30/2010 10:07 PM 

Subject

: 

Interagency comments from this evening 

Dom and Chandana, 

Thank you for the call earlier this evening regarding the interagency comments 

with respect to several of the EPA tables in the EPA RIA and the joint preamble 

regarding the presentation of costs and benefits. We understand the interagency request, 

as discussed during our call and in the attachment to the recent email from Chandana 

(copy attached), is for EPA to replace the program cost values, which in those tables are 

shown as a negative value, with separate line items for the vehicle technology costs and 

the fuel savings. 

Per Dom’s request, I have discussed this issue with my Division Director, Chet 

France, and we do not agree with the requested change. 

This past Friday, based on our discussion with OMB, we informed our senior 

management that on behalf of the interagency review, OMB requested that a single table 

in the Executive Summary of the EPA RIA be modified, and no other changes to the 

preamble or RIA were necessary (see attached email). We took this request very 

seriously and discussed the request with our senior leadership, and we decided that EPA 

could make the narrow requested change to the rulemaking package. Since that time 

OMB has requested several additional changes above and beyond the request from 

Friday. We do not believe additional changes to the rulemaking package regarding the 

presentation of the costs and benefits are necessary. These tables present costs in a 

manner which is consistent with EPA’s presentation in the NPRM. 

If OMB believes this change is necessary in order for this rulemaking to be 

cleared from review, Chet and I recommend that OMB discuss this issue with our 

Assistant Administrator for the EPA Air Office on Wednesday morning. 

With respect to the interagency requested change in EPA's response to comment 

on SCC, we have discussed this request with the EPA legal counsel and we believe the 

changes are not needed and that the requested edits would weaken the strength of the 

EPA response to the comment, thus we do not plan on making these requested changes. 

Thanks 

Bill Charmley 
[attachment "Summary of Interagency Working Comments on draft rule under 

EO 12866.pdf" deleted by Tad Wysor/AA/USEPA/US] 

----- Forwarded by William Charmley/AA/USEPA/US on 03/30/2010 09:48 PM ----- 

From: William Charmley/AA/USEPA/US 

To: "Achanta, Chandana L." <Chandana_L._Achanta@omb.eop.gov> 

Cc: Robin Moran/AA/USEPA/US@EPA, Maureen Delaney/DC/USEPA/US@EPA, Kathryn Sargeant/AA/USEPA/US@

Date: 03/26/2010 01:21 PM 

Subject: OMB request on preamble and RIA table formats and word changes regarding fuel savings 

Chandana - 

I just want to clarify our phone discussion. 

Regarding the reformatting of tables with respect to the programs costs and benefits, OMB is 

requesting that only one table in the entire EPA package be altered - Table 7 of the Executive 

Summary of the RIA. No changes in the preamble and no changes in the rest of the RIA need to 

be made. 

For Table 7 - which I show below, you would like the two rows I highlighted in red to be moved to 

be directly beneath the row labled "Fuel Savingss" 

With respect to word edits, for both the EPA sections of the preamble and in the EPA RIA, OMB 

would like EPA not to refer to fuel savings as a "negative cost", but simply as a "fuel savings". 

For example, in the following sentences from the RIA, OMB's request could be met by deleting 

the middle sentence: 

"Note that the quantified annual costs shown in Table 1 are negative because fuel savings 

are included. Fuel savings are considered as negative costs (i.e., positive benefits) of the 

vehicle program. The fuel savings outweigh the costs associated with the addition of new 

technology and, therefore, the vehicle program costs are negative." 

Can you please respond to this email ASAP and let me know if I have captured the request 

correctly. 

Thanks 

Bill 

[table deleted]