Summary
Vermont’s geography and climate make reliable energy and transportation a necessity, not a luxury. Policies that raise costs without providing affordable, practical alternatives risk doing more harm than good. They deepen inequity and erode public trust in the climate transition. The Climate Council should avoid punitive measures that target existing fuel users and instead prioritize workforce training and infrastructure investments that deliver long-term, affordable, and sustainable benefits. These are the foundations of a resilient economy and an effective energy transition.
While the Plan’s emphasis on workforce development and technical training is essential, many of its other priorities would impose significant and regressive costs on Vermonters. Programs like the Clean Heat Standard and Cap-and-Invest are presented as climate solutions, but in practice, they function as energy taxes—raising the cost of essential fuels such as propane, kerosene, heating oil, diesel, and gasoline. These cost increases fall hardest on rural and working-class households that lack affordable or viable alternatives.
The Plan’s simultaneous push to electrify both the heating and transportation sectors compounds these challenges. Many homes and businesses simply do not have the electrical infrastructure needed to support heat pumps or EV chargers. One in four Vermont homes was built before 1940, and many still rely on knob-and-tube wiring, which is unsafe for modern electric loads. Replacing this wiring typically costs between $13,000 and $15,000 per home. Even newer homes with underpowered electrical service often require $2,000 or more in panel upgrades before any electrification can occur.
EV Issues
These infrastructure, workforce, and cost challenges are substantial. But even more concerning is the disconnect between the Climate Council’s policy mandates and the choices Vermonters are making. The most popular car in Vermont is not a car, but a truck or SUV. It most likely runs on gas and isn’t new. According to the Vermont Vehicle Index, 63% of vehicle purchases in 2024 were used, and 97% of all registered vehicles still rely on internal combustion engines. Despite steady growth in new electric vehicle sales—8% BEVs and 4% PHEVs in 2024—the hurdles to greater EV adoption aren’t just the upfront cost of a new car. One of Vermont’s top EV dealers, Mark Alderman of Alderman Chevrolet in Rutland, describes how the lack of in-home Level 2 charging is the most significant barrier. He noted that customers who purchase EVs without home charging often become “anti-EV evangelists” after poor experiences. We are now seeing, for the first time, a decline in consumer interest in electric vehicles. Only 22% of Vermonters in the VEC service territory report they are likely to purchase an EV, down from 34% two years ago.
Thermal Barriers
The Climate Action Plan lacks meaningful input from the Vermonters who sell, install, and service electric heat pumps. This is apparent by the Plan’s repetition of the word “switch.” The Plan refers to air-source heat pumps as a “switching” technology, implying a full transition away from fossil fuels. But that’s not what is actually happening in Vermont. While heat pumps can reduce emissions when powered by clean electricity, their performance diminishes in cold weather. As outdoor temperatures fall, heat pump efficiency drops and electricity demand rises sharply. Field data cited during the Public Utility Commission’s deliberations of the Clean Heat Standard shows that most homeowners stop using their heat pumps when the temperature dips below 30°F, precisely when reliable heat is most needed. On average, these systems provide heat for less than half the winter season. Heat pump installers— particularly those who also sell heating fuels— see this firsthand, and the data backs them up. In most existing homes, electric heat pumps function as supplemental systems during the coldest months, not full replacements.
The Vermont Department of Public Service is currently studying how heat pump adoption affects heating fuel use. So far, the answer is: not much. Despite the installation of more than 60,000 cold-climate heat pumps over the past decade, heating fuel sales—adjusted for weather—have remained largely unchanged, according to the Vermont Heat Index, which tracks heating fuel sales. In fact, propane sales continue to rise annually, despite the robust adoption of electric heat pumps.
The Plan has chosen a “climate solution” for the thermal sector that is not delivering the results as advertised. Multiple field studies confirm this pattern: heat pumps are delivering only 20 to 40 percent of their expected heating capacity. This underutilization raises critical questions about the cost-effectiveness of current incentive programs, particularly if they are used primarily for summer cooling. To meet Vermont’s greenhouse gas reduction mandates, climate policy must reflect how technologies are actually used, not how they perform in ideal lab conditions. A successful thermal strategy must be technology-neutral, based on real-world performance, and aligned with the realities of Vermont’s cold, rural environment. Heat pumps have a role to play—but not at the expense of reliability, affordability, or environmental integrity.
Net Zero Means Zero Growth
Vermont’s Climate Action Plan pursues an emissions reduction strategy that conflicts with the state’s broader public policy goals. The Stockholm Environment Institute based its “Pathways” recommendation to the Climate Council on an assumption of zero population growth. The Climate Council accepted this framework, even though stagnant population growth is widely acknowledged as a threat to Vermont’s health, safety, and economic security. In reality, Vermont must grow its population by approximately 155,000 people by 2035—about 12,900 new residents per year—to meet workforce and economic demands.
Supporting this growth will require tens of thousands of new homes, far beyond Vermont’s current rate of housing production. This growth is especially critical to attract and retain essential workers, such as the electricians needed to install heat pumps, EV chargers, and upgraded service panels that the Climate Action Plan demands. Population growth is also essential for revitalizing Vermont’s rural downtowns, many of which lie in river corridors that are adapting to climate change.
While such growth is vital to ensuring affordability, economic vitality, and preserving Vermont’s rural character, more people—along with the homes, vehicles, and infrastructure they require—will inevitably increase greenhouse gas emissions. This makes achieving the mandates of the Global Warming Solutions Act even more difficult.
The Voices in the Field
The perspectives of heating equipment installers and vehicle sellers—along with their firsthand knowledge of Vermont consumers—were not reflected in the development of the 2025 Climate Action Plan. These voices will be crucial if we are to have constructive dialogue about meeting our energy and climate ambitions in the future. Instead, the Plan supports mandates that benefit those who have the economic means to purchase an EV or own new homes that are EV-ready. The Plan supports complex credit trading programs favored by large energy conglomerates but opposed by the small family-owned businesses that provide most of the energy, equipment, and vehicles in rural Vermont.
Let’s Be Real
While we all have a role to play in reducing greenhouse gas emissions, we must be honest about the limits of Vermont’s impact on global climate trends. The idea that any of the policies suggested in the Climate Action Plan will meaningfully change the frequency of flooding or the depth of winter snowpack is not grounded in science. Our climate policies must serve not only the environment, but the people who live in it. No plan will succeed if it leaves rural and working-class Vermonters behind.
Rather than allow a 2020 law to dictate our energy, economic, and climate policies, the Climate Council should recommend that the Legislature remove the GHG mandates and pursue a more realistic, affordable, and environmentally sustainable path forward.
Thank you for the opportunity to serve on the Vermont Climate Council.
Sincerely,
Matt Cota