In August, the National Highway Traffic Safety Administration (NHTSA) proposed to strengthen vehicle fuel-economy standards. Our comment letter suggested that NHTSA assess the benefits and costs of that regulation using draft climate-damage valuations and discount rates that were then in development within the federal government.
Since then, the Environmental Protection Agency has finalized its update to the social cost of greenhouse gases and the Office of Management and Budget has finalized its revisions to Circular A-4. In light of these updates, we submitted a supplemental comment letter reasserting our call for NHTSA to assess regulatory impacts using the best available economics.