ACPA and PCA Submit Comments on FHWA Rulemaking
FHWA published a notice of proposed rulemaking that would require state DOTs and planning organizations to establish declining CO2 targets and establish a method for measurement and reporting of greenhouse gas emissions. This rule would not mandate the level of targets, just ensure that emissions are declining over time. After releasing the proposed rulemaking, FHWA asked for public comments. ACPA and PCA submitted joint comments that argue that if FHWA requires measurement and goal setting around on-road emissions, it should also take a full life cycle approach, capturing the lower use of carbon in building materials. Additionally, the comments stressed the importance of a full life cycle approach including resilience, durability and carbonation.
ACPA and PCA comments on this issue can be read here. On a related note, there was significant discussion about the GHG Rulemaking at the Sustainable Pavements meeting this week. Several states and AASHTO expressed comments against the ruling. ACPA is proud to have worked with PCA to push the discussion into life cycle approach.