From: <james.tamm@dot.gov>

To: <Chandana_L._Achanta@omb.eop.gov>

Cc: William Charmley/AA/USEPA/US@EPA, Ed Nam/AA/USEPA/US@EPA, Robin Moran/AA/USEPA/US@EPA, <rebecca.yoon@dot.gov>

Date: 09/29/2010 04:03 PM

Subject: Re: Summary of interagency working comments received on draft Notice and Technical Assessment under EO 12866 review

Chandana,

Attached are EPA and NHTSA responses to interagency text edit recommendations.

Jim 

From: Achanta, Chandana L. [mailto:Chandana_L._Achanta@omb.eop.gov] 

Sent: Tuesday, September 28, 2010 5:56 PM

To: Charmley.William@epamail.epa.gov; Eisner, Neil (OST); Yoon, Rebecca (NHTSA); Tamm, James 

(NHTSA); Wood, Steve (NHTSA); Petrie, Joanne (OST); Delaney.Maureen@epamail.epa.gov; 

Moran.Robin@epamail.epa.gov

Subject: Summary of interagency working comments received on draft Notice and Technical Assessment 

under EO 12866 review

Please find attached additional interagency working comments we received under EO 12866 

review of the draft notice and technical assessment. 

They are for your consideration and subject to further policy review.
EPA & NHTSA Document - Draft – Do Not Cite or Quote

DRAFT

Responses to interagency comments from 28 Sept 2010 on NHTSA/EPA,

Mark-ups of the NOI

Page 5 edits: The agencies will make this change

Page 6 edits: The agencies will not make this change, as the edited part of the sentence discuss “global 

challenges”, plus later in the same sentence we already discuss “that will spur economic growth ... “

Page 7 edits: The agencies will make the requested insert, but without the word “social” in front of 

“benefits” or “costs”.

Page 8 edits: The agencies will make this change

Page 9 edits: The agencies will make this change

Page 10 edits: The agencies will make these changes, except for the insert regarding “cannot be 

foreseen in advance and .” This sentence is a summary of what the auto firms told NHTSA/CARB/EPA 

this past summer, and this is not what they said.

Page 11 edits: The agencies will make the requested changes, though we have worded the suggested 

insert differently, as shown here;

“Although the assessment of new technologies up to 15 years in the future is has uncertainties, 

the agencies and CARB have determined that there are a wide range of technologies capable of 

achieving significant reductions in CO2 emissions and significant improvements in fuel economy 

and available at reasonable costs in the 2017 to 2025 MY timeframe.”

Page 12 edits: The agencies will make the requested edits. Regarding the suggestion “shouldn’t we 

have a brief summary of that assessment here” – there is no need, as we point the reader to the actual 

section, which comes 1 paragraph later.

Page 15 edits: the first suggested edit (“technology is difficult to predict in advance”) makes no sense in 

the context of the sentence it has been inserted into. Regarding comment A1, the agencies have added 

the following footnote 

“ See section II.B.1 for more information on attribute based curves.”
EPA & NHTSA Document - Draft – Do Not Cite or Quote

Page 16 edits: The agencies will not make the requested change at the top of the page, as the sentence 

already has two qualifiers (“initial” and “approximate”). The agencies will make the suggested insert at 

the bottom of page 16.

Page 17 edits: Regarding comment A2 and the 2020 estimates, the agencies have added the following 

footnote to this section of the NOI

“In Chapter 6 of the TAR, the agencies also present results for MY 2020 for Pathways A, B, and C.”

Regarding comment A3, the agencies have added an addition note to Table 3

“We note that the total lifetime benefits of the program over MYs 2017-2025 will be significantly greater 

than those of MY 2025 alone.”

Page 18 edits: Regarding comment A4, the footnote added in response to the comments on page 15 

address this comment. Regarding comment A5, we have added the following footnote to the 

highlighted sentence:

“All other things being equal, limiting credit transfers between passenger cars and light trucks 

within a firm, and limiting credit trading among manufacturers, are two factors that would likely 

lead to higher cost estimates.”

Page 20 edits: The agencies will make this change

Page 22 edits: The suggested edit at the top of page 20 (“and if appropriate expanded”) is not needed, 

as the sentence already says the agencies will consider “whether and how” the existing flexibilities 

might be included for 2017+

Regarding comment A6, we will replace the existing sentence with the following revised 

sentence.

“Under the statute, for all dual fueled vehicles such as FFVs, the maximum credit that a 

manufacturer can apply to CAFE compliance will be limited to 0.6 mpg in 2017, 0.4 mpg in 2018, 

0.2 mpg in 2019, and zero in MY 2020 or after. Dual fueled electric vehicles, such as PHEVs, are 

not subject to this limitation.”