EPA Response to OMB EO12866 Interagency Review Comments on E012866AircraftEmissions2060A070NPRMrule20110120
                                March 25, 2011
                  Redline/Strikeout on or beginning on Page #
                               Section Reference
                                    Comment
                                      74
III.B.2.a.
The annual report on exempt spare engines goes to EPA only. Same revision for new exemptions on p. 90
                                      76
III.B.2.b.
No new tracking system is contemplated for exempted spare engines.
                                      80
III.B.2.b.ii.
Rationale for why EPA is different from ETM guidance relative to 75 per type certificate holder versus 75 per type certificate, respectively, and how the EPA position was developed. 
                                      91
III.B.2.b.iii.
Exemption requests go only to FAA and FAA will share with EPA.
                                      98
III.B.2.c.
Voluntary emission offsets is solely an EPA program.
                                      101
III.C.
Describes derivative engines using ICAO and FAA terminology.
                                      102
III.C.
EPA rationale for codifying the ETM guidance language on derivative engine emission decision criteria, and that FAA has flexibility to adjust the criteria based on good engineering judgment. 
                                      106
III.D.
The annual production report goes to EPA only.  Footnotes expand on this and also describe why FAA is encumbered from providing much of the information to EPA.
                                      131
IV.C.
Revised table to improve description of Armed Services aircraft 
                                      135
V.
Explains why no economic analysis prepared and adds there is some limited benefit to manufacturers to codify emission ICAO standards. Similar discussion added to IX.A. 
                                      137
V.
Makes production report burden and cost estimate more overt. Similar addition to IX.A.
                                      151
IX.E.
Revised E.O. 13132 content

