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Sutton, Tia

From: Sutton, Tia

Sent: Thursday, June 11, 2015 4:48 PM

To: Whiteman, Chad

Cc: Hengst, Benjamin

Subject: Quick status update on HD GHG responses to 6/5 Interagency comments

Attachments: EPA and NHTSA Responses to Interagency Line Item Comments Received on Ju....docx

Hi Chad, 

Please see responses from the EPA team below on the edits where it was unclear whether or not they were accepted – 

the team has confirmed that these edits have in fact been made to the active master Preamble file. The EPA/NHTSA 

team is conferring on the comment/edit on p. 46 and will send us something on that as soon as possible, which we will 

forward on. 

Thanks, 

 Tia 

EPA responses in Red font: 

• 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. 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: 

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.] 

• 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 
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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.

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

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

To: Chad_S_Whiteman@omb.eop.gov; Hengst, Benjamin; Sutton, Tia; james.tamm@dot.gov 

Cc: 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) 

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