Joint SC-GHG Comments on NHTSA 2023 Fuel-Economy Rule

In November 2022, EPA released a draft update to the social cost of greenhouse gases that faithfully implements the roadmap laid out in 2017 by the National Academies of Sciences and applies recent advances in the science and economics on the costs of climate change (Draft SC-GHG Update).10 These updated valuations more robustly capture the incremental benefits of reducing greenhouse gas emissions. [...] In that case, the court held that NHTSA must monetize climate impacts as part of any cost-benefit analysis of proposed fuel-economy standards under EPCA.23 In its ruling, the court listed several estimates of the global social cost of greenhouse gases as values that the agency could have applied.24 By implication, the court indicated that NHTSA should consider the global externalities of greenhous. [...] 4 policy and requires of all agencies that “to the fullest extent possible[,] the policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this chapter,”25 including the need to “recognize the worldwide and long- range character of environmental problems” and to “lend appropriate support” to help “maximize intern. [...] with a view to minimizing adverse effects on the economy, on public health and on the quality of the environment, of projects or measures undertaken by them to mitigate or adapt to climate change.”30 The unmistakable implication of the Convention is that parties, including the United States, must account for global economic, public health, and environmental effects in their impact assessments. [...] Court for the Northern District of California struck down as arbitrary and capricious the Bureau of Land Management’s (BLM) rescission of the Waste Prevention Rule in part because the agency had abandoned the Working Group’s peer-reviewed, global estimates of the social cost of greenhouse gases in favor of flawed estimates that looked narrowly at effects within the U.