## Summary	of	Interagency	Working	Comments	on	Draft	Language	under

E

. O .	13563	and 12866	Interagency	Review.		Subject	to	Further	Policy	Review.

**Comments on U.S. Environmental Protection Agency Proposed Rule,**  **“ Control of Air Pollution f** **rom Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards** **, ”**  **RIN 2060**  **- AQ86**  As EPA granted the waiver for California’s program in December 2012, the costs and benefits for that program should be included in the baseline of the R IA analysis for Tier 3. C alifornia’s a ir pollutant st andards have long been different than o ther parts of the country so it makes both analytic a nd policy sense to consider the incremental impacts, costs and benefits of the rule with and without the California program. It is requested that EPA breakdown and present these incremental impacts for the scenari os laid out in the matrix below. A clarifying question would be whether the seven other states that adopted California’s standard would also be included in the baseline for Tier 3

. Presumably they should be included in the baseline if they adopted Cal ifornia’s program ; however, w ould the seven other states be preempted by the federal program if Tier 3 goes into effect? Fuel Sulfur Only Fuel Sulfur and Vehicle Controls Tier 3 (not counting CA) A B Tier 3 (entire country) C D
A
– Thi s breakout will incorporate the impacts of the California program in the Tier 3 baseline so it separates the costs and benefits of the California program from the Tier 3 program

. The costs and ben efits of the Tier 3 program will be estimated for all states outside of California and just for the fuel sulfur portion of Tier 3 , not the vehicle controls portion of Tier 3.
B

- This breakout will incorporate the impacts of the California program in the Tier 3 baseline s o it separates the costs and benefits of the California program from the Tier 3 program

. The costs and benefits of the Tier 3 program will be estimated for all states outside of California cover ing both the fuel sulfur and vehicle controls portions of Tie r 3. C
– This breakout will incorporate the impacts of the California program in the Tier 3 cost and benefit analysis, although would only apply to the fuel sulfur portion of Tier 3 and not the vehicle co ntrols portion of the program.
D

- This breako ut will incorporate the impacts of the California program in the Tier 3 cost and benefit analysis and is what the agency has provide to date. **EPA Response** The Tier 3 proposal does not include California’s Low Emission Vehicle III (LEV III) program in the baseline because the Tier 3 proposal’s analysis was initiated and completed well before EPA granted the waiver for the California LEV III program in December 2012. However, for the final rule’s analysis we will include LEV III in the baseline for Cali fornia and the other states that have adopted it.

## Summary	of	Interagency	Working	Comments	on	Draft	Language	under

E

. O .	13563	and 12866	Interagency	Review.		Subject	to	Further	Policy	Review.

**EPA Response (continued)**  With respect to the requested matrix, it is not possible to break out benefits in this manner. The Tier 3 program is a joint vehicle and fuel program that is designed to maxim ize environmental benefits. Our analysis modeled the air quality impacts of this total program; the health effects and monetized benefits are estimated from this air quality modeling of the total program. As a result, it is not possible to identify the ai r quality impacts, health effects, or benefits of a fuel sulfur program that would be independent of a vehicle program. Similarly, as the air quality modeling accounts for cross

- state transport of pollution, it is not possible from the proposal’s analysis to separate the impacts of Tier 3 in California from the total program benefits. As mentioned above, we will be conducting new air quality modeling for the final rule that will not include emission reductions from Tier 3 vehicles and fuels in California.