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Comments to EPA on New Clean Car Standards

We submitted comments on the Environmental Protection Agency’s (“EPA”) notice of proposed rulemaking, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. Our comment urged EPA to: select the regulatory alternative that will maximize net social welfare and promote distributional justice; rely on legislative and regulatory history to help justify its aproach to lead time; and improve its modeling to more fully capture benefits of stronger standards.

We also submitted joint comments with a coalition of other environmental groups on EPA's use of the social cost of carbon (SCC) in its proposed regulation, recommending that the agency expand its justification its discount rates and inclusion of global damages in the SCC, and affirm that the SCC is a lower bound of projected climate impacts.