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

To: William Charmley/AA/USEPA/US@EPA, Robin Moran/AA/USEPA/US@EPA, 

<rebecca.yoon@dot.gov>, <james.tamm@dot.gov> 

Date: 03/30/2010 08:04 PM 

Subjec

t: 

Summary of interagency working comments on draft rule under EO 12866 

Please find attached a summary of interagency working comments received under draft joint

rule under EO 12866 review. They are for your consideration and subject to further policy

review.

  

Thanks. [attachment "Summary of Interagency Working Comments on draft rule under EO

12866.pdf" deleted by Tad Wysor/AA/USEPA/US]  
Summary of Interagency Working Comments on Draft rule under EO 12866 review. Subject to further

policy review.

1

Below is a summary of interagency comments received during EO 12866 review of the draft rule “Joint

Rulemaking to Establish Light‐Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average

Fuel Economy Standards”. They are for your consideration and subject to further policy review.  

 In Table 8-13 in the RIA, and Tables III.A.3-3 and III.H.10-3 in the Preamble we 

recommend the agencies eliminate the row called “quantified annual costs” and replace 

with two separate rows labeled “vehicle costs” and “fuel savings,” respectively. Table 7 

in the RIA ES already does this. These three other tables need to be changed so that they 

are consistent. 

 Please revise the following section from the response to comment document on SCC: 

“Finally, it is useful to recognize the somewhat limited role that the monetary value 

placed on the SCC plays in the determination of what emissions standards should be 

adopted. As noted above, the value of the SCC is not relevant to whether EPA has the 

authority or the obligation to adopt emissions standards, as that stems from the 

endangerment and contribution findings. In addition, the levels of the standards adopted 

by EPA have been determined based on the effectiveness of the technology that will be 

available, their cost, and the appropriate leadtime for incorporation of that technology in 

the light-duty vehicle fleet. See the detailed explanation in section III.F for further 

discussion of this. The cost-benefits analysis is used to help evaluate the overall 

reasonableness of the emissions standards chosen by EPA. In this case, the benefits of 

the standards are significantly greater than the costs, and this would be the case whether 

EPA considered the domestic value for the SCC, the global value for the SCC, or a range 

of values including higher SCC values. The specific range or values used in this analysis 

are therefore not outcome determinative as far as deciding what emissions standards to 

adopt, as the standards adopted by EPA would still be reasonable from a net benefits 

perspective under a wide range of SCC.” 

Might be better, simpler, less redundant, and less potentially confusing as: 

“Finally, it is useful to recognize the somewhat limited role that the monetary value 

placed on the SCC plays in the determination of what emissions standards should be 

adopted. As noted above, the value of the SCC is not relevant to whether EPA has the 

authority or the obligation to adopt emissions standards, as that stems from the 

endangerment and contribution findings. The cost-benefit analysis is used to help 

evaluate the overall reasonableness of the emissions standards chosen by EPA and to 

promote transparency. In this case, the benefits of the standards are significantly greater 
Summary of Interagency Working Comments on Draft rule under EO 12866 review. Subject to further

policy review.

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than the costs, and this would be the case whether EPA considered the domestic value for 

the SCC, the global value for the SCC, or a range of values including higher SCC 

values.”