                                       
                                       
MemoTo:	Docket EPA-HQ-OAR-2021-0208
From:	Todd Sherwood, U.S. EPA-OTAQ-ASD
Date:	August 25, 2021
Re:	e-mail Exchange with Neelesh Nerurkar

On August 25, 2021, I responded to two e-mail inquiries from Neelesh Nerurkar. The e-mail threads are included in this memorandum.

Message Thread 1

Todd,

Many thanks for this and the fuel demand guidance (you were correct about my error). Greatly appreciated!

I hope the hearing is going well and good luck as you work towards a final rule. 

Best wishes,
Neelesh
202-330-1360




On Aug 25, 2021, at 12:14 PM, Sherwood, Todd <sherwood.todd@epa.gov> wrote:
﻿ 
Neelesh,
 
The best place to look may well be RIA section 4.2 "Estimates of Fuel Economy Impacts" which shows standards and ratings (achieved) levels. The tables presented are in MPG-space but the footnotes show how they were calculated so can easily be converted back to CO2/CO2e (whichever you want) and may be easier to compare to NHTSA MPG tables in their documents.
 
Best regards,
Todd Sherwood
 
 
From: Moran, Robin <moran.robin@epa.gov> 
Sent: Wednesday, August 25, 2021 12:11 PM
To: Sherwood, Todd <sherwood.todd@epa.gov>
Cc: Olechiw, Michael <olechiw.michael@epa.gov>
Subject: RE: [EXT] RE: Question on tailpipe standards
 
Todd, can you reply directly back to Neelesh?
 
From: Sherwood, Todd <sherwood.todd@epa.gov> 
Sent: Wednesday, August 25, 2021 10:04 AM
To: Moran, Robin <moran.robin@epa.gov>
Cc: Olechiw, Michael <olechiw.michael@epa.gov>
Subject: RE: [EXT] RE: Question on tailpipe standards
 
The best place to look may well be RIA section 4.2 "Estimates of Fuel Economy Impacts" which shows standards and ratings (achieved) levels. The tables presented are in MPG-space but the footnotes show how they were calculated so can easily be converted back to CO2/CO2e and may be easier to compare to NHTSA MPG tables in their documents.
 
From: Moran, Robin <moran.robin@epa.gov> 
Sent: Tuesday, August 24, 2021 7:46 AM
To: Sherwood, Todd <sherwood.todd@epa.gov>
Cc: Olechiw, Michael <olechiw.michael@epa.gov>
Subject: FW: [EXT] RE: Question on tailpipe standards
 
Hi Todd, another public (consultant?) inquiry  -  any ideas on this Q?
 
From: Neelesh Nerurkar <Neelesh@CVEnergy.com> 
Sent: Monday, August 23, 2021 11:47 PM
To: Moran, Robin <moran.robin@epa.gov>; Olechiw, Michael <olechiw.michael@epa.gov>
Cc: Hengst, Benjamin <Hengst.Benjamin@epa.gov>
Subject: RE: [EXT] RE: Question on tailpipe standards
 
Ben  -  thank you. 
 
Mike and Robin  -  Congratulations on getting the proposal out and thanks for your help; I know you must be busy. 
 
Background/road rules: I write analytic notes on energy/climate policy that we send to clients and also share with some press. I do intend to use this information for a note Tuesday afternoon, but it is for my context. I only cite publicly available information and I will never quote you. 
 
I figured out where I misread the fuel use information in the CCEMS files, but did have a second question where I would appreciate any thoughts you can share: Is there someplace where data on EPA's and NHTSA's achieved annual fleet average emissions stringency is on a comparable basis? I had thought it might be Table 36 in EPA's NPRM and Table II-5 in NHTSA's NPRM, but the former is in gCO2e/mile and the latter is in gCO2/mile. I do not know if the difference is covered gases or different levels of stringency. 
 
Understood if this is complicated. Also, please let know if it is more convenient to chat by phone. 
 
Many thanks,
Neelesh 
202-330-1360
 
 
 

Message Thread 2


Neelesh  -  I thought I was sending this directly to you.

From: Sherwood, Todd 
Sent: Wednesday, August 25, 2021 9:15 AM
To: Moran, Robin <moran.robin@epa.gov>; Klump, Jennifer <Klump.Jennifer.L@epa.gov>; Olechiw, Michael <olechiw.michael@epa.gov>
Cc: Ronquillo, Rafi <Ronquillo.Rafi@epa.gov>; Wysor, Tad <wysor.tad@epa.gov>
Subject: RE: OTAQ inquiry FW: Question on Gasoline use Table 46 in LDV GHG NPRM

You might be filtering the data on "TOTAL" while we filtered on "Gasoline" (just a guess since by doing that I got ~8 million barrels in 2023). The "TOTAL" value would include electricity consumption as a gasoline equivalent, which works for NHTSA in CAFE-space, but not for EPA in GHG-space.

If you have downloaded the PostProcessingTool then you have all of the excel files that show exactly how we calculated things. In "annual_societal_effects_summary_report_NPRM_Primary.xlsx" there is a worksheet called "fuel" that shows the values presented in our preamble and RIA tables.

Lastly, in the PDF documentation for the tool (usepa-ccems-postprocessingtool-release0.3.1.pdf), in section 3.2, Table 1, you will find a complete run down of the scenarios, their names, what they represent, etc.

I hope that helps.

From: Moran, Robin <moran.robin@epa.gov> 
Sent: Monday, August 23, 2021 3:31 PM
To: Klump, Jennifer <Klump.Jennifer.L@epa.gov>; Olechiw, Michael <olechiw.michael@epa.gov>; Sherwood, Todd <sherwood.todd@epa.gov>
Cc: Ronquillo, Rafi <Ronquillo.Rafi@epa.gov>; Wysor, Tad <wysor.tad@epa.gov>
Subject: RE: OTAQ inquiry FW: Question on Gasoline use Table 46 in LDV GHG NPRM

Todd, since this incoming Q is on the model, can you respond directly to the requester?  Just cc Jennifer so she knows its been responded to.

Thanks
Robin

From: Klump, Jennifer <Klump.Jennifer.L@epa.gov> 
Sent: Thursday, August 19, 2021 11:18 AM
To: Moran, Robin <moran.robin@epa.gov>; Olechiw, Michael <olechiw.michael@epa.gov>
Cc: Ronquillo, Rafi <Ronquillo.Rafi@epa.gov>
Subject: OTAQ inquiry FW: Question on Gasoline use Table 46 in LDV GHG NPRM

Hello again Robin and Michael,

Here is another request we received regarding the LDV GHG NPRM. Let me know if I should direct this inquiry to someone else or if you can respond.

Thanks very much.


Jennifer Klump (she/her/hers)
Public Inquiries Librarian, ASRC Federal (ASMS) Contractor
Klump.Jennifer.L@epa.gov | 734-214-4097
11:00am  -  3:00pm, (Mon.-Fri., excluding federal holidays)
US EPA NVFEL 
asrcfederal.com | Purpose Driven. Enduring Commitment




From: Neelesh Nerurkar <Neelesh@CVEnergy.com> 
Sent: Monday, August 16, 2021 5:30 AM
To: EPA Office of Transportation & Air Quality <OTAQ@epa.gov>
Subject: Question on Gasoline use Table 46 in LDV GHG NPRM

Thanks for your help. I'm trying to find the data behind NPRM Table 46 or DRIA Table 5-7 (same data) in the output files in the "CCEM PostProcessingToolProject" zip folder. 

I think I should be able to calculate the NPRM/DRIA gasoline use figures from column J of tab "annual_societal_effects_summary" in the excel file labeled "annual_societal_effects_summary_report_NPRM_Primary" using the following two scenarios:
 "Framework_Safe"
 "Fw-to-Proposal_Safe-to-Proposal"

For other data points, these two scenarios seem to correspond to what the NPRM refers to as "no-action" and "proposal" scenarios. However, the numbers do not come out to quite the same for gasoline use. For instance, I get -8 million barrels in 2023 and  -256 million barrels in 2050. The NPRM has -9 million and -291 million for those values, respectively. 

Am I using the wrong file, the wrong scenarios, or is EPA adjusting by more than just 42 gallons to the barrel? 

Separately, is there text describing the different scenarios/runs somewhere?

Thanks,
Neelesh Nerurkar
202-330-1360


