April 10, 2025
On behalf of fifteen trade associations that represent Vermonters who buy, sell, and depend on medium and heavy-duty trucks, we respectfully request your support in delaying the implementation of the Vermont Advanced Clean Trucks (ACT) Regulation.Although we support the state’s efforts to reduce greenhouse gas emissions, the current regulatory timeline is premature due to significant limitations in zero-emission truck technology, insufficient infrastructure, and the high costs of these vehicles. Without corrective action, the regulation will restrict access to the vehicles that are essential for Vermont’s economy.
Medium and heavy-duty vehicles are indispensable to nearly every sector of Vermont’s economy and public services. These trucks are tools that deliver food, fuel, and essential goods, maintain public infrastructure, plow our roads, and support emergency services, local manufacturing, and tourism. They are vital to the success of our agricultural and forestry economies, as well as manufacturing, construction, and utility operations. There is no viable zero-emission substitute capable of meeting the performance and logistical demands placed on diesel-powered trucks—especially in Vermont’s rural and mountainous terrain. Even if electric trucks were affordable and available—which they are not—they remain the wrong tool for many applications in Vermont’s rural economy.
Vermont businesses that depend on medium- and heavy-duty vehicles are not ordering electric vehicles because they are incapable of replacing their diesel fleet. The consequences of enacting the regulations before the technology is available and affordable means diesel truck sales are now artificially contracting. The ACT rules have effectively limited manufacturers to a shrinking pool of diesel allocations. This impacts more than just local businesses. Towns need diesel trucks to maintain Vermont’s highways and plow our roads. The state of Massachusetts has recognized this by exempting “street sweepers and snow plow trucks” purchased by municipalities. Vermont has no such exemption. As discussed in testimony before the House Transportation Committee, Vermont businesses that require diesel powertrains can escape these restrictions by opening a satellite facility in a non-ACT state, such as New Hampshire, in order to purchase medium and heavy-duty trucks. This has troubling fiscal implications. In 2024 alone, medium and heavy-duty truck registrations generated an estimated $15.4 million in purchase-and-use tax revenue and associated fees for Vermont’s education and transportation funds. Losing these taxes and fees to New Hampshire would directly reduce funding for core state functions here in Vermont.
Early evidence from Massachusetts and New York—both of which implemented ACT a year earlier—shows that the regulation is contributing to a slowdown in truck sales. Vermont is now on the same path, risking both economic disruption and environmental backsliding. If newer, cleaner diesel trucks are unavailable, fleet owners are more likely to retain older, higher-emitting models longer. Diesel remains the industry standard because it uniquely combines high power density, energy efficiency, durability, long-range, heavy payload capacity, and reliable servicing networks. This is why 97% of Class 8 trucks in operation are powered by diesel engines.
New diesel vehicles are markedly cleaner than older models. Since 1988, emissions of nitrogen oxides (NOₓ) and particulate matter (PM) have fallen by 99% due to advances in ultra-low sulfur diesel (ULSD), diesel particulate filters (DPFs), and selective catalytic reduction (SCR) systems. Fuel efficiency improvements have also reduced CO₂ emissions by more than 40% since 2010. These technological gains have made today’s diesel trucks significantly cleaner, safer, and more efficient. They are also more affordable. A recent analysis by the California Air Resources Board (CARB) found that an electric Class 8 truck costs approximately $435,839—roughly $280,000 more than a comparable diesel model.
We respectfully urge the Legislature to include a provision in the FY2026 transportation budget (H.488) or the DMV Miscellaneous Bill (S.123) to delay the implementation of the Vermont Advanced Clean Trucks (ACT) Regulation.
Such a delay would allow for the expansion of charging infrastructure, maturation of zero-emission vehicle (ZEV) technology, and greater equity in vehicle access across all communities. This approach would support environmental progress while safeguarding the operational, economic, and logistical needs of Vermont’s businesses, municipalities, and essential services.
In the interest of providing certainty and predictability during these volatile times, we respectfully urge you to pause enforcement of the current mandates affecting businesses that are making substantial investments to deliver essential goods and services. We appreciate your attention to this urgent matter and stand ready to engage in continued dialogue on how Vermont’s climate goals can be effectively aligned with the operational realities of the transportation sector.
Sincerely,
Associated Builders and Contractors NH/VT
Associated General Contractors of Vermont
Associated Industries of Vermont
Heating and Cooling Contractors of Vermont
Lake Champlain Chamber
National Federation of Independent Business–Vermont
Vermont Chamber of Commerce
Vermont Dairy Producers Alliance
Vermont Farm Bureau
Vermont Forest Products Association
Vermont Fuel Dealers Association
Vermont Retail and Grocers Association
Vermont Retail Lumber Dealer Association
Vermont Truck and Bus Association
Vermont Vehicle and Automotive Distributors Association
CC:
Senator Phil Baruth, President Pro Tempore
Rep. Jill Krowinski, Speaker of the House
Senator Richard Westman, Chair of the Senate Transportation Committee
Rep. Matthew Walker, Chair of the House Transportation Committee
Rep. Kathleen James, Chair of the House Energy and Digital Infrastructure Committee
Senator Anne Watson, Chair of the Senate Natural Resources and Energy Committee
Rep. Lori Houghton, House Majority Leader
Rep. Patricia McCoy, House Minority Leader
Senator Kesha Ram Hinsdale, Senate Majority Leader
Senator Scott Beck, Senate Minority Leader