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NDC Gap Analysis

CATF finds strong EPA standards are needed to achieve U.S. climate goals

April 20, 2023

A new report from Clean Air Task Force (CATF) finds that without swift action by the Biden administration to reduce greenhouse gas emissions, the U.S. risks falling short of its Nationally Determined Contribution (NDC) under the Paris Agreement – Iaying out a suite of actions the administration can take to get on track, including through regulatory authority under the Clean Air Act and existing authority to prioritize carbon sequestration and mitigation from agriculture and forestry investments. CATF’s analysis builds on the Princeton University REPEAT Project’s recently released analysis of the economy-wide greenhouse gas benefits of current law (including the Inflation Reduction Act). CATF based its analysis on the REPEAT Project’s “middle” Inflation Reduction Act scenario, using the same RIO-Pathways model and assumptions as the REPEAT Project as run by Evolved Energy Research to consider the greenhouse gas impacts from ambitious promulgation of power, vehicle, industrial, and oil and gas methane Clean Air Act Rules.  

“Under current policies and regulations, the U.S. is on track to fall 810 million tonnes of CO2 short of its NDC,” says Stacey Davis, Climate, Technology, and Innovation Policy Director at CATF. “The Inflation Reduction Act and Infrastructure Investment and Jobs Act are estimated to provide significant emissions reductions, but alone they are not enough. Our new analysis finds this ‘gap’ can be virtually closed with strong rules to reduce CO2 emissions from the power, industry, and transportation sectors, along with strong rules to reduce methane from oil and gas operations – all actions that are well within the administration’s authority and required by the Clean Air Act.” 

“The U.S. has set ambitious climate goals and has made laudable strides toward achieving them through historic climate action over the last few years. But unless the Biden Administration takes swift action on a suite of strong greenhouse gas regulations, the U.S. risks falling short of its NDC,” says Conrad Schneider, Senior Director, U.S. at CATF. “Failure to meet our NDC target is not just consequential for climate, the economy, and public health. The U.S. must demonstrate its leadership and commitment to decarbonization so other countries will follow suit. By putting in place strong pollution standards, including through section 111 of the Clean Air Act, the U.S. can reach its climate goals while advancing domestic energy security, improving air quality, driving economic competitiveness, and positioning the U.S. as a global climate leader. We urge the Biden administration to issue stringent Clean Air Act regulations on power plants, vehicles, industrial operations, and gas production and to use its existing authority to ensure agriculture and forestry spending prioritizes climate impacts without delay.” 

Through a combination of tax credits, grants, loans, pollution fees, and more, the Inflation Reduction Act is estimated to reduce greenhouse gas emissions by roughly 0.5 to 0.8 billion tonnes of CO2, according to the Princeton University REPEAT Project. This leaves an estimated 810 million tonnes of CO2 that must be reduced to meet the NDC.  

Here is what the Biden administration can do to close the gap:  

  • Propose and finalize strong standards under section 111(b) and 111(d) of the Clean Air Act, which would result in a reduction of an estimated 764 million tonnes: 
    • Strong power sector standards for new natural gas-fired power plants and existing coal-and natural-gas fired power plants 
    • Strong greenhouse gas emissions performance standards for new and existing sources from large industrial sectors 
  • Strengthen and finalize strong standards under relevant Clean Air Act authorities: 
    • Strong performance standards to regulate methane emissions from upstream oil and gas operations for new and existing sources 
    • Strong rules aimed at further reducing emissions from vehicles, including fuel efficiency standards for internal combustion engine vehicles and emission rate standards consistent with California zero-emission vehicle (ZEV) standards for light-duty, medium-duty, and heavy-duty vehicles  
  • Prioritize carbon sequestration and mitigation in agriculture and forestry investments by the U.S. Department of Agriculture, where there is more than ample mitigation opportunity to reduce the 46 million tonnes of CO2 emissions needed to close the gap by 2030  

Find the full report, “Closing the Gap: Delivering on the U.S Nationally Determined Contribution” here.  

Press Contact

Samantha Sadowski, Communications Manager, U.S.,, +1 202-440-1717

About Clean Air Task Force 

Clean Air Task Force (CATF) is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalyzing the rapid development and deployment of low-carbon energy and other climate-protecting technologies. With 25 years of internationally recognized expertise on climate policy and a fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group with the bold ideas needed to address climate change. CATF has offices in Boston, Washington D.C., and Brussels, with staff working virtually around the world. Visit and follow @cleanaircatf.

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