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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 Inte ragency comments Attachments: EPA and NHTSA Responses to Interagency Line Item Co mments 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 wer e accepted – the team has confirmed that these edits have in fac t been made to the active master Preamble file. Th e 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 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 relati ve risks and benefits.

• 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: 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 cost effectiveness metric that treats fuel saving s as 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.]

• 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 the2

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.

From: Timothy.Mullins@dot.gov [mailto:Timothy.Mullins@do t.gov] Sent: Wednesday, June 10, 2015 11:57 AM
To: Chad_S_Whiteman@omb.eop.gov; Hengst, Benjamin; Sut ton, Tia; james.tamm@dot.gov Cc: Chandana_L._Achanta@omb.eop.gov Subject: RE: EO 12866 Interagency Comments on HD Phase II N OPR

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.eop.gov ] Sent: Friday, June 05, 2015 5:57 PM To: 'Hengst, Benjamin'; 'Sutton, Tia'; Mullins, Timoth y (OST); Tamm, James (NHTSA) Cc: Achanta, Chandana L. Subject: RE: EO 12866 Interagency Comments on HD Phase II N OPR

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