NACAA Comments on FHWA’s Consideration of GHG Emissions Measure

August 11, 2016 – NACAA submitted comments to the Federal Highway Administration (FHWA) on a particular aspect of a Notice of Proposed Rulemaking (NPRM) to implement provisions of the 2012 surface transportation planning law, MAP-21 (Moving Ahead for Progress in the 21st Century), which requires transportation planners to consider and find ways to reduce transportation-related pollution, including through the use of performance-based measures.  According to FHWA, the rulemaking is intended to improve accountability, address the nation’s congestion problems and make available “valuable information about how transportation investments are performing and delivering reliable highway travel with minimal delays and less air pollution.”  Included in the NPRM is a request for comments on whether and how to establish a measure to track carbon emissions from transportation.  It is this component of the NPRM, called “Consideration of a Greenhouse Gas Emissions Measure,” on which NACAA focused its comments.  In particular, NACAA offered support for a GHG emissions measure and provided responses to a number of questions posed by FHWA related to designing such a measure, including, among others, whether the measure should address all onroad mobile sources or a particular vehicle type; include nonroad sources; be limited to tailpipe emissions or extend to emissions generated upstream in the lifecycle of vehicle operation; and estimate CO2 emissions performance based on gasoline and diesel fuel sales, vehicle miles traveled or other surrogates.