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Public Comments Submitted During the MHD ZEV Action Plan Development Process


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Attachment (if applicable)

Paul Allen

M.J. Bradley & Associates

Washington, DC

Medium- and Heavy-Duty ZEV Action Plan Utility Stakeholder Comments
Attachment: Utility Stakeholder Group Comment Letter Final 2021-8-31.pdf

Douglas Greenhaus


Tysons, VA

Please see attached comments from the American Truck Dealers Division of the National Automobile Dealers Association (ATD).
Attachment: Comments on NESCAUM ZEV Truck Action Plan (Final).pdf

Patricio Portillo

On behalf of the Moving Forward Network (MFN) Zero-Emission Truck (ZET) Working Group and Signatories

Coachella, CA

Attached are the MFN ZET Working Group's and signatories' comments on the NESCAUM draft Action Plan.
Attachment: NESCAUM Action Plan Comment Letter_FINAL.pdf

Thomas Regan Lefebvre

Center for Latino Progress Transport Hartford

Hartford, CT

Hello, please find attached comments
Attachment: CLP Commnents on NESCAUM MHD DRAFT PLAN.pdf

Dawn Fenton

Volvo Group North America

Washington, DC

See file.
Attachment: VGNA MOU Comments FINAL.pdf

Anastasia Gordon

WE ACT for Environmental Justice

New York City, NY

Comments attached.
Attachment: WE ACT Comments_MHD ZEV Action Plan.pdf

Gerard Coyle

Meridian Consulting Services

Media, PA

A battery electric truck can cost as much as $450,000. (versus $135,000 for a new diesel truck)
A fuel cell electric truck can cost as much as $600,000.
The raw materials for batteries are all sourced in foreign countries such as, Russia and China.
Currently, there is no real charging infrastructure.
The range for a diesel truck is 2,100 miles. The range for an electric truck is 300 miles, under ideal conditions.
The average weight of a diesel truck is 18,216 Lbs.
The average weight of an electric truck is 32,016 Lbs. (Batteries alone weigh 17,106 Lbs.)
This reduces the amount of cargo carried by 13,800 Lbs. A reduction of about 30% in capacity.
The amount of CO2 used to produce a diesel truck is 74,728 Lbs.
The amount of CO2 used to produce a diesel truck is 478,055 Lbs. (6.3 times higher than a diesel truck)
Sixty percent (60%) of electricity is produced by fossil fuels.
Electric truck will require a significant increase in the number of drivers needed.

Peter Olmsted

FreeWire Technologies

Oakland, CA

Please see attachment. Thank you.
Attachment: Multi-State MHD Action Plan - FreeWire Recommendations.pdf

Jay Smith

Charge Ahead Partnership

Alexandria, VA

Please find Charge Ahead Partnership's comments in the attached PDF.
Attachment: CAP NESCAUM Comments.pdf

Kevin George Miller


Campbell, CA

To Whom It May Concern: Please find attached comments by ChargePoint, which contains the complete submission.

Thank you.

Attachment: NESCAUM MHD ZEV Draft Action Plan - Comments by ChargePoint_Final.pdf

Richard VanOrnum

On Behalf of the Partners for a Zero Emission Vehicle Future (PZEVF)

Washington, DC

Hi there,

On behalf of the PZEVF coalition and its founding members, I'm glad to submit our comments to NESCAUM for consideration on the NESCAUM Multi-State MHD ZEV Action Plan. We appreciate your time and for extending the invitation to our coalition to submit commentary.

Many thanks!

Attachment: V.F - PZEVF NESCAUM Comment Submission 5-9-22.pdf

Steve Letendre

Nuvve Holding Corporation

San Diego, CA

Nuvve supports the overall draft Plan and was pleased to see V2G referenced in several locations. The Plan could be even stronger with more emphasis on the need for advanced planning and policy support for the development of a bi-directional infrastructure and V2G capable MHD EVs to take full advantage of the transformative opportunities that V2G creates as the electric and transportation industries become tightly coupled.
Attachment: NESCAUM_MHD ZEV Action Plan_Nuvve_Corp_May_9_2022.pdf

Suzanne Merkelson


Charlotte, NC

May 9, 2022

Northeast States for Coordinated Air Use Management
89 South Street, Suite 602
Boston, MA 02111

To Whom It May Concern,

I’m writing to convey Arrival’s support for the multi-state Medium- and Heavy-Duty (MHD) Zero Emission Vehicles Action Plan and make a recommendation to strengthen the effectiveness of the plan’s suggested actions and enable greater adoption of MHD zero emission vehicles in all signatory states.

Arrival is a producer of commercial electric vehicles (EVs), headquartered in London and Charlotte, NC. Arrival was founded in 2015 with a mission to make air clean by replacing all vehicles with affordable electric solutions, produced at local Microfactories, smaller production facilities sited closer to our customer base. Our first U.S. Microfactory is expected to start producing a delivery van by the end of this year, with deliveries expected to UPS, our largest customer to date. We will later be producing additional medium- and heavy-duty EVs, including a transit bus.

Arrival suggests you include in your Action Plan the impact of prohibitive franchise laws on the ability of EV-only manufacturers to sell their products in many of the signatory states. While this issue is well-known from the perspective of passenger EV manufacturers, franchise laws have negative consequences for both the sales and servicing of MHD EVs, many of which are operated by fleets. The patchwork of franchise laws across the states limits not only the sales of MHD EVs, but also obstructs vehicle financing processes, complicates how fleet managers may navigate cross-border taxes, registrations, and fees, and mars the ability for these vehicles to be serviced under warranty, ultimately causing a potential slowdown in fleet adoption.

Direct sales of EVs can coexist with the dealership model and in states such as Vermont, legislation has recently passed requiring manufacturers who pursue direct sales to not only not have a franchise in the state at the present moment, but also to have never had a franchise in the past. Most direct sales and service legislation in effect today requires provisions that the manufacturer only produce EVs. Additionally, data has proven that direct sales of EVs pose no threats to dealership jobs. A study from the Acadia Center found that in four northeastern states between 2009 and 2016, direct sales of EVs did not negatively impact employment levels at car dealerships.

Enabling direct sales for EV-only manufacturers will help increase EV model availability in the signatory states, without costing taxpayers or ratepayers. While no single policy is enough to support the full-scale transition to EVs, achieving the ambitious goals set out by the signatory states will be difficult if manufacturers are not able to sell EVs directly to their fleet and individual customers. There is no reason for states with strong commitments to electrifying their transportation systems to have restrictive franchise laws.

Please contact me if you have any questions. Thank you for your leadership on vital state actions to transition MHD vehicles to zero emissions.

Suzanne Merkelson
Director, U.S. State Policy & Government Affairs

Emily Green

Conservation Law Foundation

Portland, ME

Please find attached a Joint Comment Letter Regarding Draft Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan. Please direct any questions about this letter to Emily K. Green, Conservation Law Foundation,
Thank you for your consideration of these comments.

Attachment: Final NESCAUM MHD ZEV AP Comment Letter.pdf

Marisa Anderson

Ford Motor Company

Dearborn, MI


Benjamin Mandel


Pasadena, CA

CALSTART is pleased to offer its strong endorsement of the Multi-State Medium- and Heavy-Duty Zero-Emission Vehicles Draft Action Plan. The corresponding Memorandum of Understanding (MOU), now signed by 17 U.S. states, the District of Columbia, and the Province of Quebec, commits more than 35% of the U.S. truck market to rapidly decarbonize with 30% of truck sales to be zero-emission by 2030 and 100% of sales by 2050. The Action Plan provides participating jurisdictions with the policy building blocks and equity principles to put these aggressive targets within reach. Please find our comments attached.
Attachment: CALSTART_MHD ZEV Action Plan comments_May2022.pdf

Larissa Koehler

Environmental Defense Fund

Chicago, IL

Attachment containing comments attached.
Attachment: EDF NESCAUM Comments FINAL.pdf

Katrina McLaughlin

World Resources Institute

Washington, DC

Please see attached comments from World Resources Institute's Electric School Bus Initiative on the Medium- and Heavy-Duty Zero-Emission Vehicles Action Plan.
Attachment: WRI_NESCAUM Draft Action Plan Comments_ 5.9.22.pdf

Lisa Yakomin

Association of Bi-State Motor Carriers

Port Newark, NJ

Please see attached comments from the Association of Bi-State Motor Carriers, a non-profit 501c membership organization representing intermodal motor carriers at the Port of NY-NJ.
Attachment: COMMENTS-ZE Action Plan.docx.pdf

Margaret Boelter

Zeem Solutions

Inglewood, CA


Andreanne Brazeau


Montreal, QC

Hello! Please note that the David Suzuki Foundation and Equiterre are based in Quebec, Canada. I therefore picked the first state in the list: Alaska. Thanks for your understanding!
Attachment: NESCAUM_submission_DSF_Equiterre_EN.pdf

Dan Bogard

General Motors

Detroit, MI

Attachments contains the complete submission.
Attachment: 2022.05.09_GM-NESCAUM-MHD-ZEV-ActionPlan.pdf

Casey Cota

Cota & Cota

Bellows falls, VT

This plan is destructive to business and customer service and cost structure. These vehicles will not work to the level the current vehicles work. If these vehicles are so great how come Green Mt Power does have electric bucket trucks? Because they are unreliable and could potentially cost an employee their life.

Anne Blair

Electrification Coalition

Washington, DC

Electrification Coalition Public Comment on the Multi-State Medium-and Heavy-Duty Zero-Emission Vehicle Action Plan

Thank you for the opportunity to provide comments on the Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan (‘Action Plan’). The Electrification Coalition commends the work of NESCAUM and the MOU signatories for your leadership to expand of zero emissions vehicles in the U.S.
The Electrification Coalition is a non-profit, nonpartisan organization that is focused on accelerating transportation electrification through a combination of stakeholder engagement, technical support, direct implementation, and policy support to facilitate the deployment of electric vehicles (EVs) on a mass scale, to combat the national security, economic, and public health impacts associated with the nation’s dependence on oil. The EC has direct experience working at the local, state, and federal levels that includes providing technical and program support for cities, states and businesses.
Over the last two years, the EC has built and implemented an increasingly robust strategy to accelerate EV action in five priority states (Nevada, North Carolina, Virginia, Pennsylvania, and Michigan) while also increasing our reach and impact through a growing network of cities, states, and private sector partners. The EC is also working to increase our impact in our current states while expanding efforts into new states including Florida, Georgia, Illinois, and other parts of the Southeast and Midwest.

We are pleased to submit the attached recommendations to strengthen the impact and results of the MOU.

Thank you!

Anne Blair
Director of Policy

Attachment: Electrification_Coalition_NESCAUM_MHD_Action_Plan_Comments_2022_05_09.pdf

Brian Ross


New York City, NY

The attachment contains the complete submission.
Attachment: AMPLY Comments on NESCAUM MDHD ZEV Plan 2022.pdf

Teddy Coin

American Automotive Policy Council

Washington, DC

Comments are attached
Attachment: AAPC NESCAUM Comments.pdf

Victoria Paykar

Climate Solutions

Portland, OR

Attached PDF
Attachment: MHDZEVMOU_CommentLetter.pdf

Tom Van Heeke

Rivian Automotive, LLC

Plymouth, MI


Sherrie Merrow

Natural Gas Vehicles for America (NGVAmerica)

Washington, DC

RE: Multi-State Medium- and Heavy-Duty Zero Emission Vehicle Draft Action Plan

Dear NESCAUM, Governors and Mayor:

Natural Gas Vehicles for America (NGVAmerica) and its members commend the Multi-State Medium- and Heavy-Duty Zero Emission Vehicle Memorandum of Understanding (MOU) Signatory States and the District of Columbia for their leadership and coordinated action to reduce greenhouse gases, nitrogen oxides, particulate matter and other toxic air emissions.

Your leadership on this issue is important because climate change is cumulative. The longer we wait, the harder it gets to solve. And your MOU recognizes the need to immediately employ the use of commercially available low-NOx natural gas vehicles using renewable natural gas today to achieve their proven steep emissions reductions while additional advanced technologies are developed, tested, and finally commercialized.

Please see the attached comments that NGVAmerica has prepared on the Draft MOU Action Plan and let me know if I can provide additional information.


Sherrie Merrow
Director, State Government Affairs

Attachment: NGVAmerica Comments - RNG Imperative for the Multi-State MHD MOU Draft Action Plan - Apr 25 2022.pdf

David Schlosberg

TeraWatt Infrastructure

San Francisco, CA

TeraWatt Infrastructure's comments are attached.
Attachment: NESCAUM MHD ZEV Action Plan - TeraWatt Comments.pdf

Elizabeth Kieskowski

private citizen

Honolulu, HI

This is urgent: Please proceed with all haste to convert to zero-emission vehicles. We are at a precipice for climate change, and every action and every tool available must be utilized just as quickly as is possible. To delay is to endanger our citizens, our land and our nation.

Valerie Forget

The Lion Electric Co. USA Inc.

Sacramento, CA

The Lion Electric Co. USA Inc.(Lion) would like to thank the Northeast States for Coordinated Air Use Management (NESCAUM) for allowing stakeholders to submit their feedback on the draft of the Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan.

Please find attached Lion's comments on NESCAUM's Draft Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan.

Attachment: The Lion Electric Co. USA Inc. Comments on NESCAUM’s Draft Multi-State Medium- and Heavy-Duty Zero-Emission Vehicle Action Plan.pdf

William Smith

VT Truck & Bus Association

Northfield, VT

On behalf of the Vermont Truck and Bus Association I have been tasked with responding to the draft plan. While its aspirational goals are laudable, the practical effect of it will likely result in substantial dislocation of this industry.
My members have been looking at alternative fuel vehicles for some time. Unfortunately the cost of electric trucks is three times as much ($420,000 for a class 8 power unit), manufacturers are at least 20 months behind on delivery of electric heavy trucks, the real world range is 1/4 of diesel (120 miles in actual usage), and the infrastructure is both non-existent and problematic. To this last point, charging stations for a class 8 power unit would need to be at least 50Kw direct current. It is unlikely that the current power grid at truck stops, commercial customers, and trucking companies can handle such a power draw. Combined with this are issues of federally mandated driver hours of service which must be coordinated with fuel stops, and the long haul trucking industry is at a loss as to how to buy more expensive equipment, haul less distance per fueling, take more time to fuel, integrate hours of service mandates, and still meet the needs of consumers and businesses for on-time low cost deliveries.
I was concerned to hear that at least one participant wants to mandate Advanced Clean Fleet standards in our region. These have not even been addressed by C.A.R.B. at this point. This is type of unrealistic opinion which causes my industry to distrust this type of process. We understand the need to push the envelope but getting ahead of national standards will only harm our trucking companies.
If mandates fall on my members before there is a meaningful choice in the marketplace, many of them will have to go out of business or maintain an aging fleet of diesels. This would harm our customers and the end of delivery consumers who choose to purchase items that need to be trucked to and from Vermont.
This industry does see the benefits of non-diesel fueled trucks and buses in certain contexts. It makes sense to work on broadening those contexts. We remain interested in the progress toward non-diesel transport of goods, and thank you for allowing us to participate.

Shruti Vaidyanathan

American Council for an Energy-Efficient Economy (ACEEE)

Washington, DC

Attachment contains ACEEE's complete comment response.
Attachment: ACEEE NESCAUM Draft Action Plan Comments FINAL.pdf

Glenn Choe

Toyota Motor North America

Washington, DC


Toyota Motor North America would like to offer our comments related to NESCAUM's MD/HD ZEV Action Plan. Please review our comments and let us know if there are any questions. Thank you.

Glenn Choe
Toyota Motor North America

Attachment: 20220415 - toyota md-hd zev nescaum comments signed.pdf

Jack McNamara

XOS Trucks

Portland, OR

I am trying to learn more about incentives and rebates for Medium to Heavy "All Electric Trucks"
I am interested in any Forums that might help too

Scott Kidd

Private citizens of Hawaii

Honolulu, HI

Hawaii should be the leader in electrification of our vehicles especially heavy trucks and transportation vehicles. Reducing our dependency on fossil fuels which need to be shipped in and are subject to violate market swings, makes Hawaii more energy secure. Additionally operating costs go considerably down over the life of electric vehicles, increasing the lifespan of those vehicles and decreases cost of ownership over said lifespan. Reducing noise pollution is another considerable benefit from going electric. Removing the loud diesel engines and hydraulic systems in place of electric motors will help make our environment more pleasant to be in. Finally, air and water pollution will be dramatically decreased. Between tailpipe emissions being eliminated which will exponentially increase air quality, oil and fuel spills will be eliminated. The amount of oil that leaks from cars, spilled fuel or improperly disposed of fuels and oils will have a sharp and drastic increase in our soil and water quality. The cost of holding out going electric could never be higher and every day spent using fossil fuel driven vehicles is a day you steal from future generations.

Joseph LaSpina


Birmingham, AL

I am just a garbage truck sales person for 50 plus years now and not repersenting the views of any specific company. My thoughts are as follows.

Unless electric power is generated from a nuclear reactor,(and currently with a small number of natural gas), then the bulk of electricity is generated by burning coal, which is what we are trying to stop. Currently, natural gas appears to be our most effecient and abundent "clean fuel" source with only fuel transportation/distribution issues in many sections of the county, while electrical brownouts are being reported out west and the northeast. For this reason I believe we are already stressing the electrical grid in many areas of the country and it seems to me that completing a natural gas pipeline infrastructure would be a better short terms funding expendure. It is a significantly cleaner fuel than gas or diesel and I believe coal is not required in the mix.

To provide the electrical grid to support our nations cars and heavy duty trucks will be a massive expenditure , business disruption, and still the need to burn coal to supply electricity is more harmful the the resulting benifit from EV, unless we go Nuclear for the fuel source. How often can a 400kWt(6000 lbs) battery for a truck be recycled after its useful life and then what happens with it, even if it is solid state technology.Haz Waste? What does that 6000 pounds of battery do to the profit margin of the truck load. What does it do to the bridge laws and weight distributions that we have been living with since the interstate highway system was enacted. Talk about infrastructure issues.

Hydrogin may be a better solution than all of these in consideration. Until we know which is the best system, stick with good oil American oil and natural gas to fill the gap in development for an economically clean attainable fuel sourse.

Thank you for your time.

Charlene Burke

West Side Community Alliance

Jersey City, NJ

As a resident and community leader of a neighborhood surrounded by trucking and warehouse facilities and directly impacted by the exhaust of this traffic as it travels our local roads seeking relief from sitting in traffic - there has to be consideration above and beyond other communities for addressing air pollution exhaust that we cannot avoid. Jersey City is in Hudson County. The County has two tunnels that have direct access to New York City and the two or three lanes under the river are a severe reduction from the numerous feeder roadways that lead to them - causing tremendous traffic jams that move at a snails pace. Air quality everyday isn't the best here but on most days its awful.

Then on Jersey City's western edge is the Lincoln Highway bridge that supports Truck Route 1-9 over the Hackensack River. Since it is a commercially navigable river and the bridge is about 100 years old - all traffic stops, the bridge opens and the river traffic proceeds often during rush hours on the land. In 20 minutes the traffic can back up for miles and it sits still for a half an hour or more.

Given the density of our county and within the #1 major market area of the nation, there should be additional incentives to purchase, support, maintain and if need be replace these more costly HMDZ-EVs for the next 10 years. Many a fleet owner is leery given that there is a big discount for the initial investment but if they have to replace it - its all on their dime. Something they are reluctant to do at today's cost level. Assure them they can replace any damaged or destroyed vehicle over the 10 year period applying the same incentives and they may be more willing to transition to EVs.

Victoria Paykar

Climate Solutions

Portland, OR

Providing Comments to the draft multi-state MHD ZEV Action Plan.
Attachment: MHD ZEV Action Plans Comments.pdf


Moving Forward Network




Patricio Portillo

Coalition Sign-On Letter

Los Angeles, CA

The attached coalition sign-on letter urges states to adopt the Advanced Clean Trucks and Heavy-Duty Omnibus rules as soon as possible and responds to misleading arguments asking states to delay. The letter includes over 30 signatory organizations from across the country representing community and public health groups, environmental organizations, and industry representatives. Please don't hesitate to reach out if you have any questions or would like additional information.
Attachment: ACT-HDO_Response to Delay Requests_8-17-2021_v2.pdf

Arthur Hirsch

Climate Reality Project Boulder Chapter

Boulder, CO

The Action Plan is supposed to be developed the Task Force within 6 months of the MOU execution (February timeframe). This action has not happened. The Action Plan was supposed to address the following issues for DOT coordination and collaboration:
• Financial vehicle and infrastructure incentives;
• Non-financial vehicle and infrastructure incentives;
• Actions to encourage public transit and public fleet zero emission MHDV deployment;
• Effective infrastructure deployment strategies;
• Funding sources and innovative financing models to support incentives and other marketing programs;
• Leveraging environmental and air quality benefits associated with adoption of the
California Advanced Clean Trucks rule under Section 177 of the Clean Air Act;
• Coordinated outreach and education to public and private MHDV fleet managers;
• Utility actions to promote zero emission MHDVs, such as electric distribution system
planning, beneficial rate design and investment in “make-ready” charging infrastructure;
• Measures to foster electric truck use in densely populated areas;
• Addressing vehicle weight restrictions that are barriers to zero emission MHDV
• Uniform standards and data collection requirements; and
• Any other initiative the Task Force deems appropriate.

It is my understanding that NESCAUM is facilitating the development of this Action Plan and has not timeframe or deadline in which this plan will be developed which is disappointing.

NESCAUM needs to complete this Action Plan as soon as possible and act like we are in a climate change crisis….because we are in a crisis.

I recommend that you coordinate with the signatory DOTs and remind them that you need information on above mentioned Action issues and EJ (that apparently was slowing down the Action Plan development). As I mentioned some DOTs do not know what is the purpose of the MOU and not aware of an Action Plan.

The Action Plan is an important tool for all signatory DOTs toward making progress toward ZEV truck transportation. Action is needed to make sure this is not just a political items that get a quick press release and is forgotten.


Art Hirsch
Boulder Chapter Climate Reality Project

Patricio Portillo

Coalition Sign-On Letter

San Francisco, CA

Please find attached a coalition sign-on letter supporting states adopting the Advanced Clean Trucks and Heavy-Duty Omnibus rules as soon as possible. The letter includes 86 signatory organizations from across the country representing community and public health groups, environmental organizations, and industry representatives. If you have any questions, please don't hesitate to reach out.
Attachment: Coalition Sign-On Letter_ACT and HDO Rule Adoption_2-25-2021.pdf

John Perona

Metro Climate Action Team/ Oregon League of Conservation Voters

Portland, OR

The attached file contains all the comments.
Attachment: Comments to NESCAUM on MHDEV action plan.pdf

Sherrie Merrow


Washington, DC

MOU Governors and Mayor:

Natural Gas Vehicles for America (NGVAmerica) and its members commend the Multi-State Medium- and Heavy-Duty Zero Emission Vehicle Memorandum of Understanding (MOU) Signatory States and the District of Columbia for their leadership and coordinated action to reduce greenhouse gases, nitrogen oxides, particulate matter and other toxic air emissions.

Your leadership on this issue is important because climate change is cumulative. The longer we wait, the harder it gets to solve. And your MOU recognizes the need to immediately employ the use of commercially available low-NOx natural gas vehicles today to achieve their proven steep emissions reductions while additional advanced technologies are developed, tested, and finally commercialized.

Please see the attached letter from NGVAmerica and its members. We appreciate your consideration of our comments and please let me know if you have any questions.


Sherrie Merrow

Sherrie Merrow
Director, State Government Affairs

Attachment: NGVAmerica Member Letter to 15 States DC MOU Participants - Jan 7 2021.pdf

Chris Kroeker

NW Natural

Portland, OR

Medium and heavy duty vehicles lend themselves well towards using hydrogen as a fuel, due to weight, range, charging time, cold weather performance, and fueling infrastructure cost advantages over other ZEV technologies. We would suggest that hydrogen be a significant focus of the action plan development process.

Make-ready infrastructure will likely play a positive role in ZEV market development. Hydrogen sourced from renewable natural gas can be carbon negative and much lower cost than hydrogen sourced from other processes. Therefore, we would suggest that natural gas utilities and others in the hydrogen and RNG supply chains be included in the action plan development.

Timothy French

Truck and Engine Manufacturers Association

Chicago, IL

Attached please find the Truck and Engine Manufacturers Association's comments regarding Oregon DEQ’s Action Plan for Medium-Duty and Heavy-Duty ZEVs.
Attachment: EMA Comments on Oregon Action Plan for MD and HD ZEVs.pdf

Timothy French

Truck and Engine Manufacturers Association

Chicago, IL

Attached please find the Truck and Engine Manufacturers Association's comments regarding New Jersey DEP’s Action Plan for Medium-Duty and Heavy-Duty ZEVs
Attachment: EMA Comments on NJDEP's Action Plan for MD and HD ZEVs.pdf

Alan Bates

CityFleet Portland

Portland, OR

Transport Refrigeration Units (TRUs) are diesel engines that keep trailers cold. California, over time, is mandating plug-in hybrid versions of these units while at the loading docks to eliminate local emissions in and around warehouses. eTRUs are becoming more common and offer a way to reduce a large amount of carbon by simply plugging in. Can this mandate be compelled in all ZEV states?


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