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Stakeholder Submissions for Medium- and Heavy-Duty Zero-Emission Vehicles: Action Plan Development Process

Comments submitted through the public input portal are posted below. Please note that all submissions are reviewed before posting. Therefore, there will be a delay between the time when comments are submitted and when comments are posted.


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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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