legislation testimony

TAM Letter – Our concerns regarding aggressive ACT mandates

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The following letter was sent to Massachusetts Governor Maura Healy. Our letter details TAM member concerns about the aggressive mandates under the Advanced Clean Truck (ACT) rule that will be implemented on Jan. 1, 2025.

The letter to the governor is available as a PDF download.

Dear Governor Healey:

On behalf of the Massachusetts trucking industry, which employs slightly over 128,000 residents across more than 33,000 businesses, delivers 93 percent of all goods transported in the state and serves as the backbone of the state’s economy, and the Massachusetts State Automobile Dealers Association (MSADA) which represents approximately 20 percent of Massachusetts’s retail economy and employs over 25,000 individuals, we are writing to express our concerns regarding the aggressive mandates set to be implemented as of January 1, 2025, under the Advanced Clean Truck (ACT) rule.

In accordance with Mass. Gen. Laws Chapter 111, §142K, Massachusetts adopted the emissions standards established by the California Air Resources Board (CARB). Specifically, CARB approved the ACT rule in June 2020, which Massachusetts adopted in 2021. The ACT rule requires that manufacturers sell an increasing number of zero-emission medium- and heavy-duty vehicles (MHDs), greater than 8,500 pounds GVWR, from 2024 to 2035. In addition to adopting the ACT rule, Massachusetts has also adopted the heavy-duty omnibus rule (HDO), which aims to substantially reduce toxic air pollutants from heavyduty vehicles. Massachusetts is only one of three states implementing both the ACT and HDO at the same time effective January 1, 2025.

The Trucking Association of Massachusetts (TAM) and MSADA support the implementation of technology and practices that will reduce and, eventually, eliminate emissions from the transportation sector. Unfortunately, technology and infrastructure improvements have not kept pace with the ACT/HDO rules. This means that unless we delay implementation of the ACT/HDO rules, the shared goal of significantly reducing emissions by our industries, government, and advocates will fail – largely due to major logistical and technological roadblocks outside of our control. In addition, based on the unfolding California experience, small business dealerships for medium- and heavy-duty trucks will be significantly harmed by the rule as they will be unable to comply with the required sales mandate – again, due to issues beyond their control. This will have a ripple effect on state and local government, private industries of all kinds, and, most importantly, residents of the Commonwealth.

To this end, please consider the following:

  • Lack of Charging Infrastructure: The lack of available charging infrastructure for electric vehicles is well known for passenger vehicles, as are concerns about long-distance battery viability. For trucks, these concerns are even more pronounced, as the vehicles are heavier and travel longer distances much more frequently. Moreover, truck drivers are federally mandated to take rest breaks, meaning charging infrastructure must be convenient, reliable, and accessible for all. Regrettably, Massachusetts, as well as other states, has not made enough progress on building out a network of public or private charging stations for commercial vehicles. The lack of infrastructure means that it can take up to ten hours to charge a long-haul electric truck versus fifteen minutes to fuel a comparable diesel truck. This is a primary disincentive for trucking companies that may otherwise be interested in purchasing electric vehicles, thus creating a near impossibility for dealers to comply with the sales requirements of the ACT. No one will purchase a medium- or heavy-duty truck if they cannot reliably charge the same.
  • Cost and Lack of Equipment Availability: Today, the average cost of a new, clean-diesel commercial truck is between $180,000 and $200,000. Compare that to the cost of a batteryelectric truck, which is nearly $500,000. In addition to the significant differential in cost, it currently takes an average of eighteen months from the time an electric truck is ordered to the time it can be delivered to the customer. The purchase of these vehicles is more in line with a long-term project rather than a vehicle transaction. Unfortunately for our dealers, the lack of available ACT/HDO compliant engines, combined with a lack of charging infrastructure, provides another significant disincentive for fleets to purchase battery-electric trucks at this time. Simply put, many entities, if they can afford to purchase a compliant vehicle, cannot purchase a truck that is not available for purchase. Please note that this does not just affect private fleets; state agencies, like the Massachusetts Department of Transportation (MassDOT), and municipalities face the same impediment to buying these needed mediumand heavy-duty trucks.
  • Loss of Sales Tax Revenue: As the deadline for complying with the ACT / HDO rules approaches, the sales of new trucks will subsequently decline, and Massachusetts will see a substantial drop in sales tax collections from the sale of new trucks. Given Massachusetts’ current tax revenue fluctuations, this is not a desirable outcome. For example, many new dump trucks sell from $275,000 to $300,000. If a private fleet owner can even find a truck to purchase, the aforementioned purchase creates approximately $17,000-$19,000 in sales tax on one new truck depending on where that truck gets registered. This does not include related registration fees if the truck is registered in the Commonwealth. However, given the lack of compliant medium- and heavy-duty vehicles and a lack of infrastructure to support the same, fleet owners will simply hold onto their older, dirtier trucks for longer, meaning the Commonwealth will forego new sales tax revenue.

Again, TAM and MSADA support the reduction in emissions from the transportation sector. The need to move the upcoming deadline for ACT/HDO rules in Massachusetts is simply a situation where technology and infrastructure have not advanced as fast as everyone expected when these rules were originally adopted. A delay is not a retreat from attaining a zero emissions solution; it reflects reality. No responsible fleet manager – public or private – will buy an electric medium- or heavy-duty truck when there is no infrastructure to support the same, not enough personnel to fix the technology laden motor vehicle, or the cost is significantly more than a diesel-powered truck, even with incentives. As the Commonwealth continues to move forward to implement the standards required under ACT and HDO, a series of actions need to advance as well.

If we do not take a coordinated approach – or if zero-emission mandates are pushed too aggressively, too soon, on a poorly thought-out plan – there will be significant implications to our supply chain which will lead to increased costs and higher inflation. Further, unless dealers can meet the zeroemission sales mandate, they are limited in the ability to sell new clean diesel-powered vehicles due to the manufacturers’ zero emissions targets established under the ACT. Finally, given the potential for a loss of jobs and state revenue as in-state dealers look at their out-of-state options as has occurred in California, the Commonwealth’s adherence to this too soon deadline will probably have a more deleterious impact than ever intended. In fact, California, which began implementing these same rules earlier this year, has seen a significant reduction in new Class 8 vehicle registrations for every type of vehicle – electric or otherwise – at a rate that far exceeds the already declining national average. Without options for purchasing, supporting, or maintaining electric and other compliant medium- and heavy-duty trucks, Massachusetts’ upcoming deadline will have the same, counter intuitive impact of keeping older, dirtier diesel vehicles on the road.

Accordingly, we respectfully request that there be a delay in enforcement of the ACT/HDO rules in Massachusetts until 2027, when the CARB emissions standards align with those established by the United State Environmental Protection Agency. Until such time as the vehicle technology and the infrastructure to support these two rules are available, we risk harming multiple industries throughout the Commonwealth while stagnating forward progress on further reducing emissions from medium- and heavy-duty trucks. We would welcome the opportunity to discuss these issues with you and your staff at your convenience so that we can help Massachusetts become as green as possible now and in the long term.

Sincerely,

Robert F. O’Koniewski, Esq.
Executive Vice President and General Counsel
Massachusetts State Automobile Dealers Association, Inc.

Kevin Weeks
Executive Director
Trucking Association of Massachusetts

truck driver conversation

ACT/HDO deadline will adversely impact government, business and residents

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The Trucking Association of Massachusetts has created a detailed fact sheet concerning legislation that will implemented in January 2025.

Massachusetts adopted the emissions standards the California Air Resources Board (CARB) established. Specifically, CARB approved the Advanced Clean Truck (ACT) rule in June 2020, and Massachusetts adopted it in 2021.

The ACT requires manufacturers to sell an increasing number of zero-emission medium and heavy-duty vehicles with a GVWR greater than 8,500 pounds from 2024 to 2035. The sales target varies according to the size of the vehicle, requiring 40 to 75% of trucks sold to be electric vehicles by 2035.

This critical fact sheet provides an overview, the vehicle classifications that will be affected, percentage sales requirements over time, states that will implement the California-inspired rules and other reference informaton.

TAM ADVANCED CLEAN TRUCK FACT SHEET
Massachusetts state house dome

Legislators urge governor to delay ACT implementation

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More than 35 Massachusetts state legislators request that the implementation of the Commonwealth’s adoption of the Advanced Clean Truck and Heavy Duty Omnibus rules be delayed until January 2027.

Read the letter sent to Governor Maura Healy and Rebecca Tepper, Secretary of the Executive Office of Energy and Environmental Affairs.

Read Letter

 

truck driver appreciation logo

National Truck Driver Appreciation Week – Sept. 15-21

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National Truck Driver Appreciation Week

As we approach National Truck Driver Appreciation Week (September 15-21), 28Freight and The Trucking Association of Massachusetts, would like to take a moment to express our deepest gratitude to the backbone of our industry: the dedicated drivers who keep our country moving.

This week provides an opportunity for us all to reflect on the indispensable role truck drivers play in our economy and daily lives. From delivering essential goods and medical supplies to ensuring that businesses operate smoothly, truck drivers are vital to the success of every community across America.

We know that without the unwavering dedication of our drivers, we wouldn’t be able to deliver the top-tier service our customers and partners rely on. Their resilience, commitment, and professionalism are what make our industry not only thrive but evolve.

National Truck Driver Appreciation Week is more than a celebration—it’s a recognition of their hard work, sacrifices, and the essential services they provide. We invite all our partners, customers, and stakeholders to join us in showing our appreciation during this important week.

In honor of this special occasion, we’ll be sharing stories, engaging in driver-centric activities, and offering resources to further support all drivers. We encourage you to participate and show your gratitude by spreading the word, joining the conversation, and supporting those who spend countless hours on the road for the benefit of us all.

Thank you for your continued support of 28Freight and The Trucking Association of Massachusetts. Together, we can ensure that their contributions are recognized not just this week, but every day.

MassDOT holding EV infrastructure deployment plan open houses

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The Massachusetts Department of Transportation (MassDOT) will host a series of Open Houses across the Commonwealth to provide an update on its Electric Vehicle (EV) Infrastructure Deployment Plan, as required by the Bipartisan Infrastructure Law’s National Electric Vehicle Infrastructure (NEVI) Formula Program.

MassDOT will provide information on the program’s status, electric vehicle charging station site selection, future construction operations, and next steps at each event.

Additional details on the events are as follows:

MassDOT is constructing electric vehicle charging stations and establishing an interconnected network to facilitate reliability across Massachusetts as required by the Bipartisan Infrastructure Law’s NEVI Formula Program. Public involvement throughout the duration of the Plan’s implementation is essential for understanding community interests, needs, and sentiments.
All interested stakeholders are encouraged to attend these events to learn more about the Deployment Plan and provide feedback.

Registration for these events is not required. All locations are ADA-compliant.

Translation services will be available in Spanish and by request. For accommodation or language assistance, please contact MassDOT’s Chief Diversity and Civil Rights Officer by phone (857-368-8580), TTD/TTY at (857) 266-0603, fax (857) 368-0602 or by email at [email protected] Requests should be made as soon as possible prior to the meeting, and for more difficult to arrange services including sign-language, CART, or language translation or interpretation, requests should be made at least ten business days prior to the respective meeting.

To sign up to receive NEVI Plan updates please visit this link.

For more information on the Plan please visit the program website: https://www.mass.gov/massdot-nevi-plan

Please feel free to extend this invitation to others who may have an interest in attending. In the interim, please use the Program’s comment form for any questions or concerns.

matt allen show wpro

Kevin Weeks on the Matt Allen Show

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Kevin Weeks, executive director of the Trucking Association of Massachusetts, appears on The Matt Allen Show on WPRO to discuss the Advanced Clean Truck regulations.

5g graphic

TAM joins organizations regarding NextNav FCC petition

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More than 70 organizations, including the Trucking Association of Massachusetts, responded to the Federal Communications Commission’s Public Notice regarding NextNav’s petition for rulemaking to reorganize the 902-928 MHz band (“Lower 900 MHz Band or Band”) and establish a 5G terrestrial-based Positioning, Navigation, and Timing (“PNT”) network (“NextNav Petition”).

The signers oppose the NextNav Petition because it is likely to cause significant and adverse disruption to the hundreds of millions of Part 15 devices currently using the band.

Read the full letter sent to the Secretary of the FCC on Sept. 5.

ATRI launches 2024 Top Industry Issues survey

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Andrew Boyle, co-president at Boyle Transportation and American Trucking Associations chairman of the board, emailed members to request they complete the American Transportation Research Institute’s annual top industry issues survey.

We encourage everyone to take this step to ensure you are heard. The survey will remain open through Sept. 27. The results will be released on Oct. 12 at the American Trucking Associations Management Conference & Exhibition in Nashville.

From Andrew Boyle, Aug. 26.

This year has been marked by challenges for our industry. Costs have continued to climb, while freight demand has yet to return to profitable levels. Meanwhile, perpetual political dysfunction in Washington further complicates the ability to advance our policy agenda.

Despite these challenges, our industry has kept delivering for America, and ATA remains seated at the table with the key decision-makers in Washington. Our influence – both economically and politically – is derived from the undeniable fact that our country cannot function, let alone thrive, without a strong trucking industry.

In challenging environments like this one, it is ever more important to understand the issues facing fleets and our workforce so that ATA and its Federation partners can identify and press for solutions. The American Transportation Research Institute’s annual top industry issues survey has long been crucial to that effort, providing the opportunity for thousands of trucking industry professionals – from drivers to executives – to weigh in on the most important topics affecting the industry.

Completing this survey only takes a few minutes, but its impact is far-reaching. The data ATRI derives from this survey will chart the course for ATA and the industry at large as America prepares to elect new political leadership. Join me in completing the survey here to ensure your voice is heard, and please encourage your employees and colleagues to do the same.

Your input is critical, so thank you for your contributions.

Andrew Boyle, Co-President
Boyle Transportation
ATA Chairman of the Board

legislation testimony

TAM Testimony – In Support, EVICC and Infrastructure Requirements

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The following testimony was sent to the Massachusetts Joint Committee on Telecommunications, Utilities and Energy chairs. Our testimony supports Section 118 of Senate Bill 2829, Relative to the EVICC and Medium- and Heavy-Duty Infrastructure.

With the still-emerging state of technology surrounding alternative-powered trucking and the lack of suitable infrastructure, we must address both sides of this issue comprehensively.

The testimony supporting Section 118 of Senate Bill 2829 is available as a PDF download.

Dear Chair Barrett, Chair Roy and Members of the Conference Committee:

On behalf of the Trucking Association of Massachusetts (TAM), I am writing in strong support of Section 118 of Senate Bill 2829, relative to the Electric Vehicle Infrastructure Coordinating Council and the consideration of medium- and heavy-duty trucking needs. With the still emerging state of technology surrounding alternative-powered trucking and the lack of suitable infrastructure, it is imperative we begin to fully address both sides of this issue. Section 118 of SB2829 begins to bring our infrastructure needs into clearer focus, but with particular attention to a segment of the transportation industry that is often overlooked.

As you know, the Electric Vehicle Infrastructure Coordinating Council (EVICC) was established pursuant to Section 81 of Chapter 179 of the Acts of 2022 to develop strategies resulting in an equitable, interconnected, accessible and reliable electric vehicle (EV) charging network in Massachusetts. EVICC is required to report on these strategies to the legislature through a formal assessment submitted every two years, starting in August 2023. Each assessment must contain but is not limited to the review of the present condition of, and future needs for, road and highway electrification; the estimates of the number and type of electric vehicle charging stations in public and private locations; among the variety of considerations relative to electric vehicle charging. The next assessment is due in August 2025.

As trucking in Massachusetts deliver 93% of all goods in the Commonwealth, a greater focus is needed on the coordination of meeting the often-shifting standards being put on the industry with respect to medium and heavy-duty trucking. As currently configured, the EVICC is largely focused on the electrification of the automobile market. While there is passing reference to medium- and heavy-duty (MHD) trucks, medium and heavy-duty trucking is not even a specifically identified focus nor its users identified as a stakeholder for outreach and input in its enabling act. Section 118 of SB2829 begins to remedy this lack of attention – which is essential if the Commonwealth wants to make reasonable progress on this matter.

To that end, under Section 118 of Senate Bill 2829, the EVICC would be specifically required to consider the realities associated with the implementation of policies necessary to bring zero emissions, MHD trucks to the Commonwealth. Specifically, the EVICC would be required to provide estimates of the number of zero-emission MHD truck charging stations required to meet the commonwealth’s emissions limits and sublimits pursuant to said chapter 21N and provide a discussion of costs, permitting processes and estimated timelines for installing charging stations for medium- and heavy-duty vehicles.

Why is this language important? National Grid in its report, “The Road to Transportation Decarbonization: Understanding Grid Impacts of Electric Fleets”, notes “[f]leet operators may also use larger electric vehicle supply equipment (EVSE) than in public, work, or residential charging applications. This means that, even if overall charging times were shorter, the amount of electricity demand at any given point in time could be higher. These individual fleet sites could quickly become megawatt-scale loads. MHDVs (medium & heavy-duty vehicles) will also likely require more energy (kWh) per charging session, due to larger battery sizes and greater VMT. The scale of MHDV charging needs means that MHDVs will represent a significant portion of the overall electricity demand from electric vehicles … the scale and scope of full fleet electrification pose new challenges for utilities and system operators.” (See: Page 6, emphasis added).

Accordingly, the language of Section 118 of Senate Bill 2829 will simply increase the amount of attention needed to ensure we have properly identified the increased needs for electric infrastructure that the trucking industry will require to convert its fleet to electric vehicles. Given the competing yet related concerns between vehicle technology and infrastructure, this language simply ensures that the EVCC specifically works to ensure the transition for MHD truck users is both realistic and attainable. In short, Section 118 of Senate Bill 2829 focuses attention on a problem that exists today and, if not recognized specifically, could set back emission reduction efforts in the future.

I appreciate your consideration of this important matter and respectfully request that you include Section 118 of Senate Bill 2829 in the final conference committee report. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director
Trucking Association of Massachusetts

legislation testimony

TAM Testimony – In Support, Training Tomorrow’s Trucking Workforce

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The following testimony was sent to the Massachusetts House Committee on Ways and Means and Joint Committee on Economic Development and Emerging Technologies chairs. Our testimony supports Amendment 41, Relative to Training Tomorrow’s Trucking Workforce.

The Commonwealth must strengthen its pipeline to develop a new workforce for the trucking industry. TAM supports Massachusetts Amendment 41, Relative to Training Tomorrow’s Trucking Workforce.

The testimony supporting Amendment 41 is provided below but is also available as a PDF download.

Dear Chair Michlewitz and Chair Parisella:

On behalf of the Trucking Association of Massachusetts (TAM), I am writing in strong support for adopting Amendment #41, Relative to Training Tomorrow’s Trucking Workforce, to House Bill 4789, the House economic development legislation. With the trucking industry experiencing one of its greatest workforce challenges in recent years, it is essential that the Commonwealth strengthen its pipeline for developing a new workforce for this vital industry.

Complementary to the House economic development bill’s strong focus on workforce, Amendment #41 seeks to bring a new generation of qualified workers into the trucking profession by directing the Massachusetts Board of Higher Education to create a grant program, subject to appropriation, that would support training and education programs that address the workforce shortages in the commercial trucking industry. The applicable areas of the trucking workforce targeted would include truck drivers, mechanics, technicians, and ancillary support personnel. The grant program would be used to train students, create new jobs, retrain and upgrade existing jobs, and retrain existing workers to implement new technologies and to help meet the workforce needs of the trucking industry within the Commonwealth.

Amendment #41 is an important initiative for growing the trucking industry in Massachusetts. The creation of this program will allow for the training of students and transitioning career professionals — creating new jobs while improving the retainage and upgrading of existing jobs to help meet the growing workforce needs of the trucking industry. As reported by the American Trucking Associations (ATA), “there is no single cause of the driver shortage, but some of the primary factors include: high average age of current drivers, which leads to a high number of retirements; women making up only 7% of all drivers, well below their representation in the total workforce; the pandemic caused some drivers to leave the industry, [and] truck driver training schools trained far fewer drivers than normal in 2020. At current trends, the shortage could surpass 160,000 in 2030. This forecast is based on driver demographic trends, including gender and age, as well as expected freight growth. )See the report from the American Trucking Associations, Truck Driver Shortage Analysis Update 2021.)

Truck drivers and other trucking personnel play a crucial role in the current economy. 93% of all goods transported into and within the Commonwealth have been on a truck. Every item on the shelves of Massachusetts retailers are filled with products transported by the trucking industry. With interest in the profession dwindling, there is a clear need to encourage this career path. The revitalization of the profession is important for more than just the trucking companies, but the Commonwealth as a whole. This initiative will create a mechanism for a wide variety of organizations and employers to train and hire trucking professionals to fill the Commonwealth’s workforce shortage.

I appreciate your consideration of this important matter and respectfully request that you adopt Amendment #41 as part of House Bill 4789. If you have any questions or concerns, please do not hesitate to let me know.

Sincerely,

Kevin Weeks
Executive Director
Trucking Association of Massachusetts