From: Sargeant, Kathryn To: "Whiteman, Chad" Cc: Stewart, Lori ; Charmley, William ; Ghanta, Venu ; Machiele, Paul ; Olechiw, Michael ; Wysor, Tad ; Yanca, Catherine ; Davidson, Ken ; Moran, Robin ; Zawacki, Margaret ; Helfand, Gloria ; hannon, john ; Kataoka, Mark ; Okoye, Winifred ; Nam, Ed ; Beardsley, Megan ; Brunner, Christine Subject: Part 2 of EPA Response to 2/13 Interagency Comments on Tier 3 Date: Thursday, February 28, 2013 11:23:36 AM Attachments: EPA response part 2 to EO_12866_Tier 3_Summary Comments_2_13_2013.docx EPA Response to EO_12866_ Tier 3_Summary Comments_2_13_2013.docx EO_12866_ Tier 3_Summary Comments_2_13_2013.docx



### Chad, in response to our phone conversation on February 25, attached please find our further response to the comments from February 13 (specifically related to analysis of proposed Tier 3 fuel sulfur standards in isolation of the proposed Tier 3 vehicle standards).

_____________________________________________ From: Sargeant, Kathryn Sent: Friday, February 15, 2013 4:48 PM To: Whiteman, Chad Cc: Stewart, Lori; Charmley, William; Ghanta, Venu; Machiele, Paul; Olechiw, Michael; Wysor, Tad; Yanca, Catherine; Davidson, Ken; Moran, Robin; Zawacki, Margaret; Helfand, Gloria; hannon, john; Kataoka, Mark; Okoye, Winifred; Nam, Ed; Beardsley, Megan; Brunner, Christine Subject: EPA Response to 2/13 Interagency Comments on Tier 3 Chad, I'm attaching EPA's response to your written comments from Feb. 13. Hope you have a good long weekend.

From: "Whiteman, Chad" <Chad_S_Whiteman@omb.eop.gov>

To: Kathryn Sargeant/AA/USEPA/US@EPA

Cc: Lori Stewart/DC/USEPA/US@EPA

Date: 02/13/2013 05:55 PM
Subject: RE: Follow-up to Feb. 11 Tier 3 call 

### Kathryn,

Thank you for the follow-up to our conversation on Monday. I’ve attached a follow-up request. Please let me know if you have any questions. Thanks,
ChadFrom: Sargeant.Kathryn@epamail.epa.gov [ mailto:Sargeant.Kathryn@epamail.epa.gov ]
Sent: Wednesday, February 13, 2013 2:57 PM

To: Whiteman, Chad

Cc: Yanca.Catherine@epamail.epa.gov; Brunner.Christine@epamail.epa.gov; Nam.Ed@epamail.epa.gov; hannon.john@epamail.epa.gov; Davidson.Ken@epamail.epa.gov; Stewart.Lori@epamail.epa.gov; Beardsley.Megan@epamail.epa.gov; Olechiw.Michael@epamail.epa.gov; Machiele.Paul@epamail.epa.gov; Moran.Robin@epamail.epa.gov; Wysor.Tad@epamail.epa.gov; Ghanta.Venu@epamail.epa.gov; Charmley.William@epamail.epa.gov; Zawacki.Margaret@epamail.epa.gov; Helfand.Gloria@epamail.epa.gov; Wyborny.Lester@epamail.epa.gov Subject: Follow-up to Feb. 11 Tier 3 call

In response to a question during the Feb. 11 call, I wanted to follow up with the following information: Of the 35 small refineries, 5 of them are projected to require the installation of a grassroots FCC posttreater to comply with Tier 3, which is the same proportion as we project are required for the larger refineries. Those that are small, however, would be provided with a 3-year delay in their compliance deadline. I also understand that you passed along some additional questions, which we answer below:
1) Do the Tier 3 benefits include California's LEV III program?

A. Yes. EPA granted the waiver for California's program in December 2012, and the Tier 3 analysis was initiated and completed before that time.
2) Are the benefits of PM versus NOx reductions broken out in the rule?

A: The PM, NOx, and other emission reductions are presented in preamble section III.B (see pp. 64-66). The photochemical air quality modeling conducted for the NPRM estimates the total changes in ambient PM , ozone and air toxics that result from changes in their emission precursors (and directly emitted PM). We are not able to present air quality impacts and related health impacts separately for these precursors. We model the entire program's impacts simultaneously to accurately characterize the total air quality impact of the proposal. We do have health-related benefits broken out by ambient PM versus ambient ozone in preamble section VIII (p. 359 - 367) 3) What emission reductions are achievable from the existing fleet with the Tier 3 gasoline sulfur requirements?

A: See preamble section III.B (pp. 64-68). Tables III-2 through III-7 present the emissions reductions that result from the pre-Tier 3 fleet due to the sulfur standard.