November 19, 2024

Dear Senate President Scutari
and Assembly Speaker Coughlin:

We are writing to urge the Legislature to pass S3817 (Diegnan) and A4967 (Calabrese), which delays New Jersey’s participation in California’s electric truck regulation (ACT) until at least July 1, 2027. The ACT regulation takes effect in New Jersey on January 1, 2025.

The ACT regulation requires a certain ratio of EV trucks to be sold relative to regular diesel trucks, before additional diesel trucks can be sold. While the point of compliance is upon truck manufacturers, they are enforcing it against truck dealers. As of fall 2024 New Jersey truck dealers report that they are not able to satisfy customer requests for new heavy-duty diesel trucks since they haven’t sold the requisite number of heavy-duty EV trucks. They haven’t sold enough heavy-duty EV trucks for one reason, no one wants to buy them in proportion to how many the manufacturers are requiring to be sold. Among the reasons:

• EV heavy-duty trucks are three times more expensive than regular heavy-duty trucks.
• Heavy-duty trucks cannot exceed 80,000 GVWR lbs. Heavy-duty EV trucks are 8,000 lbs. heavier, so for every ten existing heavy-duty trucks, EV heavy duty trucks will necessitate an eleventh.
• More trucks require more CDL drivers at a time when industry is having difficulty filling positions.
• Passenger cars charge in kilowatt hours, heavy duty trucks charge in megawatt hours. This order of magnitude requires more infrastructure, not only for the bank of heavy-duty EV truck chargers but possibly utility upgrades like a new or expanded substation. The US Department of Energy estimates a utility substation upgrade can cost up to $5 million and a new substation can cost up to $35 million.
• In the past four months the Murphy Administration announced federal funding for two heavy duty vehicle charging projects: $100 million for the charging of 130 NJ Transit buses in the Meadowlands and NJ’s participation in a $250 million multi-state grant for public heavy-duty EV charging on the I-95 corridor, of which NJ’s share is $84 million. Both projects will be finished in 2029.
• For multi-state truck fleets adoption of ACT may result in them re-domiciling in a state that has not adopted the regulation. For many, they already have physical locations in other states. This means the annual registration of approximately $1,500 per truck will go to another state. And those new diesel trucks will drive the same routes, serve the same customers, and park in the same New Jersey locations as they do today.

Please understand we are not opposed to EV heavy-duty trucks and some companies are beginning to use them in select applications. But as a state we are simply not ready for the requirements that ACT imposes, nor the costs that will be borne by all consumers.

Sincerely, 

Affordable Energy for NJ
Associated Builders and Contractors – NJ
Beer Wholesalers Association of NJ
Bus Association of NJ
Chamber of Commerce Southern NJ
Chemistry Council of NJ
Commerce and Industry Association of NJ
Engineers Labor-Employer Cooperative 825
Fuel Merchants Association of NJ
Garden State Seafood Association
International Union of Operating Engineers Local 825
Mid-Atlantic Hearth Patio & Barbecue Association
National Federation of Independent Business – NJ
National Waste and Recycling Association
NAIOP-NJ
NJ Air Conditioning Contractors Association
NJ Apartment Association
NJ Asphalt Pavement Association
NJ Association of Counties
NJ Building Material Dealers Association
NJ Business and Industry Association
NJ Chamber of Commerce
NJ Coalition of Automotive Retailers
NJ Construction Materials Association
NJ Farm Bureau
NJ Food Council
NJ Motor Truck Association
NJ Propane Gas Association
NJ Retail Merchants Association
NJ Warehouse and Movers Association
Shipping Association of New York and New Jersey
Truck Renting and Leasing Association
Utility and Transportation Contractors Association of NJ 

cc:  NJ Legislature

The Challenge of Mandating Electric Trucks

The Advanced Clean Transportation (ACT) mandate aims to accelerate truck electrification, but implementation challenges and costs are immense. Electric trucks are three times more costly than diesel alternatives, hold less freight due to battery weight, and rely on an incomplete charging infrastructure. Complying with these requirements will place a significant financial burden on New Jersey, costs that would ultimately be passed on to consumers.