Comments on Truck GHG Emissions
We recently submitted two sets of comments to the EPA and National Highway Traffic Safety Administration on their greenhouse gas standards for trucks. In joint comments with EDF, NRDC, and the Union of Concerned Scientists, we encouraged the use of the social cost of carbon and agreed with EPA’s most recent assessment that the Social Cost of Methane should be applied to value methane emissions. Additionally, we offered suggestions for further refinements to the both the Social Cost of Carbon as well as the Social Cost of Methane, noting that both numbers will evolve as new scientific research develops. In separate comments, we advocated for improved consumer labels, consideration of upstream emissions, modeling improvements, and a stringency that maximizes net benefits.