Joint Comments on Fuel Economy Standards and the Social Cost of Greenhouse Gases
Vehicle fuel economy standards set by the National Highway Traffic and Safety Administration (NHTSA) help reduce greenhouse gas emissions in the United States by making cars more fuel efficient. But despite the role these standards play in reducing emissions from the transportation sector, the carbon emissions of which are second only to electricity generation, NHTSA proposed leaving out of their Environmental Impact Statement a monetized value of the standard’s most important environmental effect.
Our comments on the reconsideration argue that NHTSA should value the social cost of those emissions as robustly as possible, as they have done in the past. We encourage NHTSA to consider the social cost of greenhouse gases in both the rule’s Environmental Impact Statement and Regulatory Impact Analysis, and that it should use estimates considering global damages of climate change using a three percent or lower discount rate.
These comments were jointly submitted with the Environmental Defense Fund, National Resource Defense Council, the Sierra Club, and the Union of Concerned Scientists.