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Extending the ZEV Timeline in NY

Our Support for Sustainability Goals

At Burr Truck, we fully support New York’s ambitious sustainability goals. We are committed to reducing greenhouse gas emissions and transitioning to zero-emission vehicles (ZEVs) as part of our contribution to a cleaner, healthier environment. Our efforts align with the state’s Climate Leadership and Community Protection Act (CLCPA), aiming to achieve significant emissions reductions by 2050.



Challenges for Businesses

While we are dedicated to the transition to ZEVs, we face significant challenges and constraints. Supply chain issues limit the ability for manufacturers to meet ZEV production targets. The economic impact on truck dealers is substantial, with the cost of BEVs significantly higher than diesel trucks. Additionally, there is a critical lack of charging infrastructure, especially in rural and upstate areas, making the adoption of ZEVs more difficult.


Need for Realistic Timelines

We advocate for extending the 2025 ACT Rule to 2027 to allow for a more realistic timeline that aligns with OEM production capabilities and infrastructure development.


Rushing to meet the 2025 target could result in economic hardships for truck dealers and operators, potentially leading to job losses and business closures. A phased approach gives us the necessary time to build up the infrastructure and supply chain resilience needed for sustainable ZEV adoption.


ZEV Transition Solutions


We propose practical solutions to facilitate the transition to ZEVs:

  1. Implementing a phased approach to ZEV adoption allows gradual scaling.

  2. Increasing funding for infrastructure development, particularly in under-served areas, is crucial.

  3. Additionally, providing incentives for early adopters and streamlining the NYSERDA funding process can help offset the high costs associated with ZEVs.   

  4. By taking these steps, we can ensure a smoother transition that benefits both the environment and the economy.


Impact on Dealers


Financial Burdens

The high cost of ZEVs compared to diesel trucks poses a significant economic challenge. For example, a BEV can cost up to $480,000 compared to $150,000 for a diesel truck, which can strain the finances of fleet operators and truck dealers.


Application Process

The application process for funding can be lengthy and complex, which is a significant concern for businesses relying on these incentives to offset the higher costs of ZEVs.


Infrastructure Gaps

The lack of sufficient charging infrastructure, especially for medium-duty trucks and heavy-duty trucks, remains a critical barrier to widespread adoption. This is particularly pronounced in rural and Upstate areas of New York, compared to more urbanized regions like New York City.


Why Should We Consider Extending the 2025 ACT Rule Timeline to 2027?


Extending the timeline to 2027 is crucial for several reasons:

Supply Chain Constraints

Current global supply chain issues limit the production capacity of ZEVs. This makes meeting the 2025 targets unfeasible without causing significant market disruption. Once we are no longer under limited production constraints—everyone will benefit!


Economic Impact

The cost disparity between BEVs and traditional diesel trucks is substantial ($480,000 vs $150,000). This financial burden on truck dealers and fleet operators could lead to business closures and job losses. Extending the timeline allows for a more gradual economic transition.


Development

There is significant lack of charging infrastructure, particularly in rural and Upstate New York. More time is needed to build out and support widespread ZEV adoption effectively.



Man replaces electric battery charger for his BEV on dock
Battery electric charging stations are few and far between, particularly in rural areas of Upstate New York.


How Will Extending the Timeline Affect NY's Environmental Goals?


Extending the timeline will not hinder New York’s long-term environmental goals. Instead, it allows for a more sustainable and practical transition:


  1. Sustainable Growth: A phased approach ensures that ZEV adoption progresses steadily without causing economic disruption. This method supports long-term sustainability by fostering stable market conditions.

  2. Improved Infrastructure: Additional time will enable the development of necessary charging infrastructure, which is crucial for supporting ZEVs and ensuring their efficient operation.

  3. Balanced Transition: By allowing more time, we can ensure that both environmental benefits and economic stability are achieved, leading to a more successful and equitable transition to ZEVs.


What Specific Steps can be Taken to Support Truck Dealers and Fleet Operators During this Transition?


Several practical steps can be taken to support truck dealers and fleet operators:

  1. Phased Implementation: Gradually increase ZEV sales targets over time to allow businesses to adapt.

  2. Increased Funding: Provide additional funding for infrastructure development, particularly in underserved areas. This includes expanding programs like the New YorkTruck Voucher Incentive Program and the Electric Truck and Bus Challenge Prize competition.

  3. Incentives for Early Adopters: Offer financial incentives to early adopters of ZEVs to offset the higher initial costs. Streamlining the NYSERDA funding process can also make these incentives more accessible.

  4. Technical Assistance: Provide technical assistance and resources to help dealers and fleet operators transition to ZEVs. This includes training programs and support for maintaining and operating ZEVs.


It is possible! According to the National Renewable Energy Laboratory (NREL), the adoption of electric commercial vehicles is feasible but requires substantial infrastructure development and supply chain improvements. The Environmental Defense Fund (EDF) emphasizes the importance of a balanced approach that includes both aggressive targets and practical steps to achieve them. They support phased implementation as a way to meet environmental goals without causing undue harm to the economy. The International Council on Clean Transportation (ICCT) recommends financial incentives and infrastructure development as key components of a successful ZEV transition strategy.




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