Comments on U.S. Environmental Protection Agency Proposed Rule, "Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards," RIN 2060-AQ86

Primary Questions for Discussion:

   1. For the estimates on the bottom of page 8-4 that decrease the benefits by 12-16% by removing California from the baseline, how is this estimate consistent with the benefits maps that were shown during the briefing in which the majority of the benefits appeared to be in California? 
   2. Please reconcile the estimates of population and counties estimated to be in nonattainment with the PM and ozone NAAQS on pages 11, 29, 33, and 36 of the preamble.  Some of these estimates appear to be based on the RIA modeling for this rule, some appear to be related to nonattainment designations.  Please help us reconcile how both sets of estimates reconcile with the number of counties estimated to be in nonattainment at these dates when the NAAQS were designated. 
   3. The introductory portion of Chapter 8 of the RIA mistakenly refers to the ACS based estimate for PM/premature morality benefits as "most conservative." ["most conservative" appears at least 3 times in pages 8-4 and 8-5.]  Rather, the ACS and 6-Cities based estimates represent EPA's preferred estimates.  As indicated in the rest of the chapter, there are estimates that are both higher and lower than these preferred estimates.  If this verbiage appears in the preamble, it should be fixed there as well.
   4. We will send an edit to page 8-10 of the RIA, to clarify the role/purpose of the expert elicitation.
   5. What is the purpose of Table 8-13 of the RIA (how it is it used?).
   6. The text in chapter 6 of the RIA appears almost identical to that on pages 30-60 of the preamble.  For brevity, consider deleting chapter 6.  If keeping both, please fix this issue in both places:  Page 48 of preamble and page 6-10 of RIA  -  suggest deleting 2[nd] and 3[rd] paragraphs of ethanol entry.

