From: "Achanta, Chandana L." <Ch andana_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 cal led “quantified annual costs” and replace

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

in the RIA ES already does this. These three ot her 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 somewh at limited role that the monetary value

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

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

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

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

by EPA have been determined based on the e ffectiveness of the t echnology that will be

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

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

discussion of this. The cost-benefits analys is 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 th e costs, and this would be the case whether

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

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

are therefore not outcome determinative as fa r as deciding what em issions 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 somewh at limited role that the monetary value

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

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

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

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

evaluate the overall reasonabl eness of the emissions sta ndards chosen by EPA and to

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

policy review.

2 

### than the costs, and this would be the case wh ether EPA considered the domestic value for

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

values.”