In September 2020, the Vermont General Assembly enacted the Global Warming Solutions Act and created a Climate Council charged with adopting an Initial Climate Action Plan. The Initial Climate Action Plan directed the Agency of Natural Resources (ANR) to adopt California’s Greenhouse Gas emission standards for trucks and trailers, arguing that these rules are critical to meet Vermont’s required reductions of greenhouse gas emissions from the transportation sector. ANR must adopt these regulatory amendments before the end of 2022 to meet the deadlines
If approved, the Vermont Low and Zero Emission Vehicle Regulation will require a rapid phase out of gasoline and diesel powered vehicles. If adopted, 35% of all new cars and light duty vehicles sold in Vermont will need to be electric by 2026. All new cars must have ‘zero emissions' by 2035. And 30% of all new trucks and buses sold in Vermont must have ‘zero emissions’ by the end of the decade
(ANR) draft rules would incorporate by reference California’s motor vehicle emission standard regulations and mandate. This proposal promises to restrict consumer choice, and essentially force the use of heavy-duty electric vehicles onto the commercial truck industry before the technology has proven to be available, effective, economically competitive, and practically appropriate.
Feed trucks serving Vermont’s dairy industry travel the length of the state and often reach west to New York, south into Massachusetts and Connecticut and east into New Hampshire and Maine. Vermont’s feed manufacturing industry is essential to feeding dairy cattle and other essential livestock throughout New England and New York. Currently it is not uncommon for a feed delivery vehicle to travel 300 miles or more per day to pick up and deliver feed to dairy farms. Rural roads with many challenging hills require substantial horsepower from over the road tractors to accomplish the job. Further, engine power is required at the delivery site to operate the truck’s unloading equipment.
State of the art heavy duty electric vehicle technology does not come close to performing the daily requirements of a feed truck, particularly in Vermont. Cold temperatures, hilly roads and onsite delivery demands will quickly reduce heavy duty truck performance to well below required performance rates. Further, recharging times, even if recharging infrastructure is available, would require hours per day to recharge in contrast to minutes per day for diesel refueling. Vehicle cost is another significant factor. Current heavy-duty EV over the road tractors are running around $400,000 each. A conventional diesel engine truck sells for about $180,000. One Vermont feed business estimated that they would have to significantly increase the size of their fleet to accommodate the lower daily mileage performance and extensive recharge times. Charging takes between 8-10 hours and charging stations require expensive 3-phase power sources that cost as much as $50,000. Further, even if it was possible for a fleet of heavy duty EVs to deliver feed commodities, the significant additional cost per vehicle cannot be absorbed by feed mills and dairy farms as farmers are price takers and cannot pass along additional expenses up the food chain.
The technology for large EV vehicles to replace diesel is still in the development stage, particularly regarding battery capacity. Currently, there are serious safety concerns relating to batteries in passenger cars. A large EV truck with tons of batteries poses a more serious threat that needs to be understood before mandating them onto the highway. EV passenger vehicles are not the same as large delivery trucks especially in the agricultural businesses.
Draft rules are out for public review and were reviewed last week by NEAFA members Kevin Kouri, Mike Thresher, Rick Zimmerman and John Mitchell. The conclusion is that they pose serious threat to the agribusiness community, particularly the feed industry, to undertake basic functions required to deliver feed to Vermont’s dairy farms. NEAFA will be signing on a letter from other stakeholders voicing our objections and implore the Vermont’s Agency of Natural Resources to consider the consequences to Vermont’s agriculture if these rules are adopted.