Defend Clean Trucks Coalition Memo to NJ Legislature
Memorandum
TO: New Jersey State Legislature
FROM: Defend Clean Trucks Coalition
DATE: March 31, 2025
SUBJECT: Preserving Advanced Clean Trucks (ACT) and Protecting State Authority
Summary: The Advanced Clean Trucks (ACT) policy, which prepares our state for the gradual transition to zero-emission medium- and heavy-duty (MHD) vehicles, is essential to advancing our climate goals and improving air quality. Diesel MHD vehicles contribute a disproportionate amount of New Jersey’s greenhouse gas emissions and air toxics, which exacerbate public health and safety harms. New Jersey’s ACT policy and state authority are under attack as part of a national coordinated disinformation campaign. We implore legislators to preserve the ACT policy as scheduled, resist efforts to diminish state authority and protect New Jersey residents from harmful diesel pollution. We have provided additional information in an attached fact sheet.
The Advanced Clean Trucks (ACT) policy is one of New Jersey’s strongest tools for achieving the state’s clean air and climate goals while simultaneously realizing billions of dollars in economic, environmental, and public health benefits. The ACT standard will accelerate the medium- and heavy-duty (MHD) zero-emission vehicle (ZEV) market by setting requirements for manufacturers to sell an increasing percentage of clean vehicles gradually over time. Preserving New Jersey’s ACT policy implementation as scheduled also demonstrates our state’s commitment to protect 60+ year-old state authority under the federal Clean Air Act to regulate mobile source emissions, which is under severe threat. We cannot afford to stand idly by while the federal government prepares to scrap minimal baseline protections against carcinogenic diesel exhaust.
At 38%, the transportation sector is the state’s largest source of greenhouse gas (GHG) emissions. While the MHD sector makes up about 4% of the state’s on-road vehicles, it is responsible for a quarter of the greenhouse gas emissions from transportation. The diesel pollution emitted from these vehicles has been proven to worsen asthma, lung disease, and cancer, leading to premature deaths that are avoidable. People of color and low-income communities experience disproportionately high exposure to this pollution based on their proximity to warehouses, ports, and transportation hubs. New Jersey is the country’s most highway-dense state and second-worst state for cancer risk from diesel soot. One in three New Jerseyans currently reside within a half-mile of a mega-warehouse. These public health impacts in the state have resulted in more than 330 premature deaths, 19,900 lost days of work, and approximately $3.75 billion annually in health damages. Even a two-year delay of the ACT policy in New Jersey until model year 2027 would cause up to 24 premature deaths linked to air pollution and up to $372.9 million in public health damages.
Despite the importance of the ACT, engine manufacturers across New Jersey and the country have used a coordinated disinformation strategy to sabotage the transition to cleaner vehicles. Manufacturers are falsely claiming that the policy requires truck dealers to buy ZEV trucks before they can purchase diesel trucks in an attempt to stoke anger among dealers and turn them against the policy. Manufacturers’ practice of imposing their own ZEV sales ratios is worsened still by their shady pricing strategies. A recent CARB assessment found that manufacturers are selling ZEV trucks in North America at significantly higher prices than in Europe (despite falling battery costs in both markets), suggesting that they may be colluding to artificially inflate vehicle prices across the country. Since manufacturers cannot directly lobby against ACT under the terms of a legal agreement they signed with regulators in 2023 (the Clean Truck Partnership), they are now deliberately creating a false shortage and crisis to manipulate dealers and fleet operators to do their bidding. The supplemental fact sheet attached will dispel the common myths argued by engine manufacturers, revealing their weaponization of dealers and fleet operators and demonstrating the policy’s feasibility.
Still, New Jersey continues to push forth in climate leadership with ongoing and emerging efforts to provide incentives for the purchase of clean electric trucks and the installation of charging infrastructure. In his Budget Address on February 25th, Governor Murphy highlighted the $135 million investment in February alone that would make it easier for businesses and local governments to expand their electric vehicle fleets. The funding the Governor referenced stems from more than $100 million from the NJEDA, with $75 million for electric truck vouchers from $15,000 for delivery vans (Class 2b) to up to $175,000 for semi-trucks (Class 8). This is in addition to $25 million in low-interest loans to small and medium businesses adopting clean trucks and $35 million in grants from NJDEP for local governments that are electrifying their fleets. The move will also help create good-paying job opportunities for New Jerseyans. The NJ Board of Public Utilities also continues to move forward with charging infrastructure utility filings to support MHD ZEVs. In fact, three state utilities just submitted filings for the MHD charging infrastructure program by the February 27 deadline.
We implore you to reject S3817, A4967, and any further attempts to delay and undermine the ACT policy. The coordinated attack on the ACT policy is a direct attack on state authority.
Contrary to manufacturers’ claim that the ACT timeline is infeasible, NJDEP data demonstrates that New Jersey has already nearly met our 2025 requirements under the ACT program with more than 5,400 electric trucks on the road and more than 500 private truck depot chargers for medium- and heavy-duty vehicles funded by NJDEP. Even before the end of 2024, NJDEP and NJEDA funding provided incentives for more than 150 semi-electric trucks (Class 7-8) that were delivered or will be delivered in 2025, with slightly over 100 trucks needed this year.
If New Jerseyans give in to industry and Big Oil’s tactics and preemptively strike down this critical regulation just as four other states proceed as planned with implementation this year, we will signal to the Trump Administration that our state is prepared to relinquish its authority under the Clean Air Act to ever again regulate pollution from mobile sources. New Jersey must stand strong amidst the Trump Administration’s attempts and threats to roll back life- and cost-saving policies and revoke state waivers. New Jerseyans can resist these efforts to curtail our state’s rights by simply staying the course on the ACT policy.
Respectfully,
Winn Khuong
Executive Director
Action Together New Jersey
Jennifer S. Higgins
President
AFT New Jersey
John Reichman
Environmental Chair
BlueWaveNJ
George Koutsouradis
Sales Manager
Bryan Electric Inc.
Susan Dorwad
Principal
Carbon Manager LLC
Tolani Taylor
Zero Emissions & Warehouse Organizer
Clean Water Action
Anita Edward
Administrative Assistant
Clinicians For Climate Action NJ
Kelli Koontz-Wilson
Coalition Coordinator
Coalition for Healthy Ports
Casandia Bellevue
Senior Associate Attorney
Community Partnerships Program, Earthjustice
Sally Malanga
CEO
Ecco Bella
Kristine Waldren
VP Corporate Affairs
ECOS
Doug O’Malley
Director
Environment New Jersey
Justin Balik
VP, States
Evergreen Action
Adam Gordon
Executive Director
Fair Share Housing Center
Ben Haygood
Director of Policy
Isles, Inc.
Drew Tompkins
Director
Jersey Renews
Garrett O’Connor
Director of Worker Organizing and Policy
Make the Road NJ
Richard Smith
President
NAACP New Jersey State Conference
Guillermo Ortiz
Senior Clean Vehicles Advocate
Natural Resources Defense Council
Maura Collinsgru
Director of Policy & Advocacy
New Jersey Citizen Action
Alison Mitchell
Executive Director
New Jersey Conservation Foundation
Melissa Miles
Executive Director
New Jersey Environmental Justice Alliance
Zeke Weston
Policy Coordinator
New Jersey Future
Ed Potosnak
Executive Director
New Jersey League of Conservation Voters
Nicole Rodriguez
President
New Jersey Policy Perspective
Marcus Sibley
Chair
New Jersey Progressive Equitable Energy Coalition (NJPEEC)
Judith Schmidt
CEO
New Jersey State Nurses Association
Richard Lawton
Executive Director
New Jersey Sustainable Business Council
Doug O’Malley
Senior Advisor
NJ Public Interest Research Group
Anjuli Ramos-Busot
Director
NJ Sierra Club
Deb Coyle
Executive Director
NJ Work Environment Council
Antoinette Miles
Executive Director
NJ Working Families Party
Racquel Romans-Henry
Director of Policy
Salvation and Social Justice
Cynthia Korman
Owner
Strategic System Solutions
Jaqi Cohen
Director of Climate and Equity Policy
Tri-State Transportation Campaign
Athena Motavvef
Senior Washington Representative
Union of Concerned Scientists
Elowyn Corby
Mid-Atlantic Regional Director
Vote Solar Action Fund
Rachel Dawn Davis
Public Policy & Justice Organizer
Waterspirit
Diana Mejia
General Coordinator
Wind of the Spirit, Immigrant Resource Center
Gail Friedberg
CEO
Zago Manufacturing Company, Inc.