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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.


Date       Name
City, State
Attachment (if applicable)
2021.01.15John 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
2021.01.13Sherrie 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
2021.01.04Chris 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.
2020.12.29Timothy 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
2020.12.29Timothy 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
2020.12.15Alan 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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