ZEVergreen State Dialogue Sessions

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Comment From: ZEEM Solutions (Margaret Boelter)

11/07/25 @ 4:04 PM

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Comment From: Jeffry Berner

11/06/25 @ 12:58 AM

There is a rural/urban divide which reflects a Republican/Democrat divide over EV adoption. Current incentives are tailored toward BEVs exclusively which do not meet needs of rural drivers who driver further distances, have less access to chargers, a...↓

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Comment From: Jeffry Berner

11/06/25 @ 12:53 AM

Incentives to-date have focused exclusively on subsidizing the initial purchase price of EV vehicles. For example, Washington state through 2025 had offered a sales tax break up to $15,000 on new EVs and up to $16,000 on used EVs. It is proposed that...↓

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Comment From: Jeffry Berner

11/06/25 @ 12:33 AM

Create an initiative for consumer product protection for EVs to address battery life and high maintenance cost perceptions to EV adoption, and to ensure that EVs have equal or better expected life to displace highest mileage ICE vehicles. See attache...↓

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Comment From: Electric Era (Isabella Craddock)

11/05/25 @ 9:41 PM

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Comment From: CALSTART (Darryl Little)

11/05/25 @ 7:31 PM

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Comment From: Ed Staub and Sons Petroleum (Jason Cole)

11/05/25 @ 7:01 PM

To Whom It May Concern,

I am writing to offer comments on the State's clean transportation policy initiatives. As a professional active in Washington's fuel and transportation sector, I strongly support policies that enable the state to reduce emiss...↓ions while ensuring the reliability, affordability, and economic vitality of our transportation networks.

While the adoption of new technologies merits thoughtful consideration, it is equally important not to overlook the ongoing advancements and significant benefits of proven energy sources such as cleaner-burning diesel and hydrogen fuels. These fuels provide real and measurable emission reductions while harnessing existing infrastructure, minimizing supply chain risks, and supporting family-wage jobs in Washington.

Diesel technology in particular has continued to evolve. Today's cleaner-burning diesel engines and renewable diesel fuels deliver meaningful emissions improvements compared to older fleets, while maintaining the performance and dependability industries rely on. Additionally, simply requiring diesel sold in the state to include a modest proportion of biodiesel or renewable diesel could greatly reduce particulate and greenhouse gas emissions from existing equipment without any disruption to operations or infrastructure.

Hydrogen-powered vehicles are likewise emerging as a practical low-carbon solution, particularly for heavier-duty applications where range, payload, and fueling speed are critical.

Conversely, a policy focus that over-prioritizes electric truck adoption risks straining electrical infrastructure, creating supply bottlenecks, and imposing costs on businesses and public agencies—especially in rural and underserved areas where electric charging options may be limited for years to come.

I urge the Department of Ecology to continue supporting the responsible use and development of cleaner-burning diesel and liquid hydrogen fuels alongside other alternatives. By keeping all practical options on the table, Washington can achieve its emissions goals without sacrificing transportation reliability, cost-effectiveness, or equity for industries and communities reliant on liquid fuel supply chains.

Thank you for considering these comments as you shape Washington's clean transport future.

Sincerely,

Jason Cole

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Comment From: Washington Oil Marketers Assoc... (Diana Carlen)

11/05/25 @ 6:47 PM

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Comment From: Washington Public Ports Associ... (Carly Michiels)

11/05/25 @ 6:26 PM

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Comment From: King County - Executive Climat... (Marissa Aho)

11/05/25 @ 5:42 PM

Thank you for this opportunity to comment. Please see attached letter from King County's Executive Climate Office

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Comment From: Washington Trucking Associatio... (Sheri Call)

11/05/25 @ 5:39 PM

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Comment From: Chris Bruno

11/05/25 @ 5:38 PM

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Comment From: City of Vancouver, WA (Stacey Dalgaard)

11/05/25 @ 5:05 PM

Please see attached comments regarding the transition to clean transportation from the City of Vancouver, Wash.

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Comment From: Washington Coalition (Linda Mitchell)

11/05/25 @ 5:02 PM

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Comment From: Clean & Prosperous (Michael Mann)

11/05/25 @ 4:36 PM

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Comment From: Sierra Club (Andrea Issod)

11/05/25 @ 4:02 PM

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Comment From: Earthjustice, Front and Center... (Jaimini Parekh)

11/05/25 @ 12:16 PM

Please see the attached PDF.

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Comment From: Electrification Coalition (Skye Golann)

11/05/25 @ 12:14 PM

Please see the Electrification Coalition's attached comments.

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Comment From: Alliance for Automotive Innova... (Brandon Houskeeper)

11/05/25 @ 8:39 AM

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Comment From: Coltura (Robert Sargent)

11/05/25 @ 7:58 AM

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Comment From: Natural Resources Defense Coun... (Kate White Tudor)

11/05/25 @ 1:00 AM

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Comment From: American Lung Association in W... (Carrie Nyssen)

11/04/25 @ 4:10 PM

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Comment From: Association of Washington Busi... (Ken Short)

11/04/25 @ 3:42 PM

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Comment From: Pacific Environment (Gabriella Alvira)

11/04/25 @ 3:06 PM

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Comment From: Rebekah Tuno

11/04/25 @ 2:45 PM

With the changes at the federal level, funding for transit agencies has dwindled for clean energy vehicles and infrastructure. While some WA State programs continue to fund this scope, funding is limited and continues to be reduced for transit that c...↓

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Comment From: Climate Solutions (Leah Missik)

11/04/25 @ 12:45 PM

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Comment From: City of Seattle, Office of Sus... (Christine Bunch)

11/04/25 @ 11:06 AM

Thank you for the opportunity to provide recommendations on advancing zero-emission vehicle adoption in Washington. Please find attached letter from the City of Seattle's Office of Sustainability and Environment that outlines our recommendations. Tha...↓

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Comment From: Scott Dubble

11/04/25 @ 10:31 AM

Increasing dedicated assigned level 2 charging stations in multi-family dwellings like apartments and condominiums (not first-come first-served). We live in the only apartments in downtown Olympia that will assign an EV charging station parking spot....↓

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Comment From: Orange EV (Jason Dake)

11/04/25 @ 10:16 AM

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Comment From: Brandon Bowersox-Johnson

11/03/25 @ 10:51 PM

Dear Ecology, thanks for working on this important issue. I want my son to grow up with clean air and water, so accelerating a transition to a clean transportation system is a critical piece of his future!

In response to questions #1-3, please co...↓

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Comment From: Mollie Grow

11/03/25 @ 9:24 PM

Number 1 action: provide incentives of all types for electric vehicles (purchasing (tax rebates), operating (HOV lanes and parking for EV), owning (vehicle tab renewals with discounts), charging (charge stations in rest stops along I-5)

Other action...↓

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Comment From: Washington State Auto Dealers ... (Vicki Fabre)

11/03/25 @ 5:59 PM

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Comment From: Sarah Mikkelborg

11/03/25 @ 5:37 PM

Dear Department of Ecology,

Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State as part of your ZEVergreen process. I appreciate your work to make sure that our state is a leader...↓

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Comment From: Dennis McLerran

11/03/25 @ 12:41 PM

The number one action Washington should take is to continue incentives for vehicle purchases and EV charging infrastructure under the WAZIP, Clean Fuel Standard and VW diesel settlement funding. Continued appropriations from the Climate Commitment Ac...↓t for incentive programs will provide the greatest potential for both greenhouse gas reductions and conventional air pollutant reductions, especially in disproportionately impacted communities. For medium and heavy-duty vehicles, because of the cost differential over diesel trucks and because of the up-front cost of megawatt level charging infrastructure, these incentive programs are crucial for meeting state transportation targets.
These programs should continue to contain plus-ups for drayage and secondary market purchases as the drayage sector is the hardest to reach due to the business models in place there and because of the needs of small businesses that are large participants in that sector. The Roadmap for Zero Emission Drayage developed under the sponsorship of the Northwest Seaport Alliance contains much more on how this sector can be successfully addressed.
Ecology should continue to work with key partners and stakeholders to identify both needs and opportunities for successful deployment of Zero Emission trucks and necessary supporting infrastructure and the ZEVergreen dialogue sessions are a good start on that. However, it needs to continue into the future. In addition, promising new business models like trucking as a service should have early access to funding programs as they are a promising opportunity for early adoption of ZEV technology. Grants and incentives should be developed to favor funding applications from projects that have the most potential air quality and climate change benefits to disproportionately impacted communities. Project evaluation criteria should include requirements that favor a focus on equity and community benefit as well as emissions reductions.
Given current regulatory uncertainty the state should attempt to backfill some of the prior light duty vehicle incentives that were available at the federal level. This could include on the hood incentives available at the time of purchase but perhaps at lower levels than past programs as cost differentials between light duty EVs and combustion alternatives are narrowing from manufacturers. Also, grant programs for charging infrastructure must address maintenance and uptime for publicly incentivized charging infrastructure as many sites currently are not well maintained. In addition, the high cost of publicly available fast charging at many sites exceeds the cost of current gasoline. While this may be difficult to structure, there should be consideration of cost caps on publicly incentivized charging infrastructure.
Coordination with utilities and the UTC to ensure that there are policies in place that allow more rapid deployment of infrastructure and cost recovery should be part of a successful program going forward. And, finally, access to charging for people that live in apartments needs to be better addressed, both in existing development and new construction. Building and construction codes as well as incentive programs should be developed that address this need. And, incentives for individuals to install charging infrastructure in homes should also be considered. Some manufacturers have developed their own incentive programs around this such as Ford, but the cost of home charging infrastructure can be a barrier to wider EV adoption.
In addition, a careful review of current legislative fees and incentives is merited. Licensing fee penalties for EVs are currently a disincentive for purchasers and a road use or mileage fee across all vehicle types could be more equitable and reduce EV disincentives.

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Comment From: Steven Buckminster

11/03/25 @ 8:03 AM

I feel that the Department of Ecology should focus less on EVs and more emphasis on Carbon Sequestion by improving wetlands and making more wetlands.

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Comment From: Ryan Crompton

11/02/25 @ 10:18 PM

First off thank you for seeking this input and for continuing to put a focus on finding ways for Washington to be a leader in reducing emissions that are harmful locally and globally.

For the next two to three years I think the state needs to help ...↓close the upfront cost gap for buyers who are buying cars with MSRPs under $50k. I would suggest that the state offer $3,500 point of purchase discount for all new EVs under $50,000, this is much easier than trying to do means testing but still keeps the discounts flowing to those who need it the most. This will keep demand higher and help to create a second use market while only requiring ~$50 million dollar allocation from the >$1 billion dollars that the Climate Commitment auctions brought in this year. Regardless of specifics I think it's critical to have enough funding that this doesn't run out within weeks but is instead available to buyers and dealers for much of the year.

One area that I think states have overlooked is the marketing and promotion aspect associated with the owner benefits of an EV. This is something that automakers have also done a poor job with here in the US. Ecology could help reach people via a PSA campaign on TV, radio, tiktok/facebook, etc describing how EVs don't require oil changes, have far less parts to break, are fun to drive, and that it is way cheaper to fill up with a charge than a tank of gas.

I think the state needs to continue to help make public chargers more available, reliable, and affordable. More 9+ KW Level 2 chargers are needed in densely populated areas (especially curbside charging like SCLs program) and apartment buildings need support in retrofitting level 2 chargers. Level 3 EV chargers not just available, (and very reliable+not in some back corner) but common place at desirable locations all all freeway routes. Once people are seeing chargers everywhere, and as the latest generation of EVs all have ranges of at least 300 miles, I think range anxiety will largely disappear. It feels like we are within just a few years of reaching this and private industry is already starting to take more of a leadership/investment role but they still need help. In order to help them fully own this it's critical that state and city regulation is supportive, that there is targeting of charging gaps/critical sites and permitting is expedited to just a few months.

Thank you for your work and please take fast, definitive action with whatever projects you decide to move forward with.

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Comment From: Devon Kellogg

11/02/25 @ 7:57 PM

I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being!

The state needs to make up for the federal government moving backwards on climate and clean transportation policy.

The state...↓

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Comment From: Richard Mordini

11/02/25 @ 7:56 AM

Encourage businesses to have their workers work from home.

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Comment From: Janet `Hada

11/01/25 @ 10:28 PM

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Comment From: Joanne Stellini

11/01/25 @ 4:27 PM

As the owner of a Chevy Bolt EV car for the last 5 years, I am responding primarily to your 3rd question.

Casual events to learn about EVs
To encourage, promote, and incentivize the purchase of more ZEVs, I think it is useful to support opportunitie...↓

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Comment From: Ken Zontek

11/01/25 @ 12:40 PM

I appreciate your efforts toward clean energy and transportation. Please intensify and sustain your efforts.

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Comment From: Janet Hamill

11/01/25 @ 9:13 AM

Dept of Ecology: We need to move forward with clean energy. Transpiration is our biggest polluter in WA State and it needs an imperative that we address it. Please hold to the previous limits and goals set, and move forward by working to achieve t...↓

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Comment From: Barb Bailey

11/01/25 @ 7:20 AM

Hello and thank you for this opportunity to comment.
1. Clean transportation/Zero emissions? As the state continues to grow, especially in certain regions (Seattle, Tacoma) exceeding their plans and abilities - sadly, I have nothing specific to offe...↓

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Comment From: Zoox, Inc. (Paul Escobar)

10/31/25 @ 2:46 PM

Please see attached comments submitted on behalf of Zoox, Inc.

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Comment From: Rivian Automotive, LLC (Tom Van Heeke)

10/31/25 @ 1:12 PM

Please see attached for Rivian's comments in response to the ZEVergreen Dialogue.

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Comment From: Sarah M

10/31/25 @ 11:56 AM

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Comment From: JENNIFER VINING

10/31/25 @ 11:26 AM

I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being!

Please keep up the momentum on bike lane and light rail expansion.

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Comment From: Renewable Hydrogen Alliance (R... (Rebecca Smith)

10/31/25 @ 11:16 AM

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Comment From: Scout Motors Inc.

10/31/25 @ 10:32 AM

Scout Motors Inc. ("Scout Motors") applauds the Department of Ecology for seeking input on actionable strategies for the 2026 legislative session to accelerate Washington's transition to electrified vehicles and achieve statewide emission goals. As d...↓

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Comment From: Public Citizen (Will Anderson)

10/31/25 @ 10:13 AM

October 31, 2025
Washington State Department of Ecology
300 Desmond Drive SE
Lacey, WA 98503

Dear Director Sixkiller and Members of the ZEVergreen Dialogue Team,

As a national consumer advocacy organization committed to advancing a zero-emission tr...↓

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Comment From: Steven Meyer

10/31/25 @ 9:02 AM

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Comment From: Shary B

10/30/25 @ 7:02 PM

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Comment From: WILLIAM CRIMBRING

10/30/25 @ 1:56 PM

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Comment From: Dave Porter

10/30/25 @ 12:15 PM

Dear Department of Ecology,

I appreciate the opportunity to submit comments on transportation electrification and clean energy. Please ensure our state is a leader in building a clean transportation future that reduces harmful pollution and works f...↓

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Comment From: Dennis McLerran

10/30/25 @ 9:50 AM

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Comment From: Angel Menchaca

10/30/25 @ 9:35 AM

1. Washington's number one action should be to accelerate the statewide transition to zero‑emission transportation by rapidly expanding charging and fueling infrastructure that is accessible to every community. By investing in this backbone and lever...↓

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Comment From: Margo Rolf

10/30/25 @ 8:27 AM

It is vital to change Washington school buses from combustion to electric now. Electric creates no fumes as they pickup, carry and drop off our children. The fumes created by diesel and other carbon fuels literally are deadly fumes. No one should bre...↓

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Comment From: Dana Hendricks

10/30/25 @ 8:05 AM

Dear Department of Ecology,
Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State as part of your ZEVergreen process. I appreciate your work to make sure that our state is a leader i...↓

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Comment From: Jason Hartman

10/30/25 @ 7:04 AM

Dear Department of Ecology,
Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State as part of your ZEVergreen process. I appreciate your work to make sure that our state is a leader i...↓

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Comment From: Virgene Link-New

10/29/25 @ 10:39 PM

Dear Department of Ecology:

As you develop clean transportation strategies, I encourage state leaders to prioritize the following:

Accelerate the transition to zero-emission trucks by adopting policies that reduce transportation pollution around ...↓

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Comment From: Tiffani Manteuffel-Ross

10/29/25 @ 10:05 PM

Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State. I appreciate your work to make sure that our state is a leader in building a clean transportation future. As you develop clean ...↓

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Comment From: Linda Ellsworth

10/29/25 @ 9:12 PM

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Comment From: Christine Perry

10/29/25 @ 8:58 PM

Legislators incorporate clean/green energy grids, nuclear energy, electric vehicles and increase recycling programs and products.

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Comment From: Don Steinke

10/29/25 @ 8:08 PM

We need to reduce emissions as much as possible within the next 5-10 years. Do not consider any combustion fuels unless unless the carbon intensity is guaranteed to be almost zero, now, not in 30 years.
When all emissions are accounted for, biomass,...↓

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Comment From: Tom Hall

10/29/25 @ 7:18 PM

Dear Department of Ecology,
Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State as part of your ZEVergreen process. I appreciate your work to make sure that our state is a leader i...↓

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Comment From: Helen Rector

10/29/25 @ 4:49 PM

It is difficult to get between counties without changing buses. Make bus services to ferries and seatac easier to arrange. This saves individually driven cars and parking. Similarly remove restrictions on boat shuttles. For instance, there is no publ...↓

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Comment From: Michael Siptroth

10/29/25 @ 4:02 PM

More money for rural transport, incl Sundays. Now people can get to our area to recreate, but w/o Sunday service, they can't get back, which means more people drive. Locals, incl seniors like me can't get around by public transport when no Sun servic...↓

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Comment From: Evey Winther

10/29/25 @ 3:31 PM

What is the number one action Washington should take to promote clean transportation and/or reduce transportation emissions?
Invest in electric vehicle charging infrastructure.

What types of programs would you like to see Washington State assess an...↓

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Comment From: Denise Farrer

10/29/25 @ 2:48 PM

I support ZEVergreen. Washington State action on clean transportation is important to me and my community, family, health, well-being!

The state should help people access electric vehicles, especially people living on lower incomes who will especial...↓

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Comment From: Alice Nicholson

10/29/25 @ 2:46 PM

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Comment From: Donald Padelford

10/29/25 @ 2:16 PM

We should have quick chargers (NACS) at all state rest stops.

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Comment From: Patricia PERRON

10/29/25 @ 1:55 PM

** Accelerate the transition to zero-emission trucks by adopting policies that reduce transportation pollution around ports and warehouses and offering rebates that incentivize zero-emission trucks. Communities near freight hubs have been burdened b...↓

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Comment From: Jeffry Steele

10/29/25 @ 1:31 PM

Dear Department of Ecology,

As you develop clean transportation strategies, I encourage state leaders to prioritize the following:

Accelerate the transition to zero-emission trucks by adopting policies that reduce transportation pollution around ...↓

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Comment From: Rachel Serkownek

10/29/25 @ 1:19 PM

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Comment From: Jimmie Farmer

10/29/25 @ 1:14 PM

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Comment From: Shaun Hubbard

10/29/25 @ 1:08 PM

Thank you for the opportunity to comment on how to Make Washington Green(er). What actions to take to promote clean transportation in Washington State? Accelerate the transition to zero-emission trucks at freight hubs, electrify school bus fleets, el...↓

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Comment From: Ramona Hicks

10/29/25 @ 1:06 PM

Dear Department of Ecology,
Thank you for the opportunity to submit comments on transportation electrification and clean vehicles in Washington State as part of your ZEVergreen process. I appreciate your work to make sure that our state is a leader i...↓

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Comment From: Sue Comis

10/29/25 @ 12:38 PM

The number one action Washington should take is to promote public transportation.
I would like to see Washington promote public transportation in rural areas as well as cities. There are many good ways to promote public transportation, but the main ...↓

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Comment From: Anonymous Anonymous

10/29/25 @ 12:29 PM

As a lifelong Washingtonian, I urge you to act decisively to protect our clean vehicle progress. The
Trump Administration's rollbacks are harmful to our health, economy, and environment. The
Evergreen State must respond with strong state-level incent...↓

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Comment From: Kimberly Higgins

10/29/25 @ 12:25 PM

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Comment From: WA PUD Association (Travis Nelson)

10/29/25 @ 12:23 PM

The storm that hit the Pacific Northwest this past weekend (October 25-26, 2025), resulted in over 200,000 customers losing power in the area and caused localized urban flooding in several communities from storm debris blocking drainage systems.

Res...↓toration of these systems was critical to citizens in our region for safety and restoration of basic services. These restoration efforts were made possible through the hard work of our dedicated public servants who are the "First Responders" when the storms take out power and block our drainage systems. Like our Police and Fire services, the electricity and stormwater professionals rely on vehicles that can withstand the elements and time duration required to restore services and safety without the additional constraints from equipment failure. As such, just as the law provides exemptions from Electric Vehicle requirements for police, fire, and military vehicles, it is appropriate that the utility industry be afforded the same exemption for the response vehicles they rely on to protect and serve the public through restoration of electricity and stormwater services.

The maintenance and restoration of these systems requires the use of specialized Utility Service Vehicles (USV). Oftentimes, these vehicles are called upon during times of emergency, natural disasters, and extreme weather events. The distance crews are commonly required to travel to restore or stabilize services can be more than 100 miles in extreme temperatures.

Once the crews arrive at an area that requires repairs or restoration, the USV may remain on sight for many hours or even days while operating auxiliary hydraulic functions, such as a digger derrick (auger), hydrovac (water-vacuum), and personnel lift (bucket) operations.

In addition to these mechanical functions, consistent with state law, these vehicles serve as shelters from the elements. This use requires extended periods of time when engine idling is required to provide heating and cooling for crews. Presently, electrified USVs cannot adequately perform these functions or meet the basic needs of utility workers as they service and repair utility infrastructure.

On a regular basis utility providers share equipment resources through Mutual Aid and Assistance to neighboring communities in Washington and other states across the country experiencing service outages due to natural disasters and extreme weather events that interrupt utility services. The current ZEV capabilities are not adequate to support these operations that often require hundreds of miles of travel to reach neighboring communities in need of regional assistance outside the local area in need.

Please exempt Utility Service Vehicles from the zero emission vehicle requirements.

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Comment From: Susan Morales

10/29/25 @ 12:12 PM

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Comment From: McKenna Princing

10/29/25 @ 11:53 AM

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Comment From: Amanda Grindle

10/29/25 @ 11:50 AM

I'd love to see more Sounder trains available on the weekends. Currently they only run on the weekends when there is a game.

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Comment From: Tony Carbo

10/29/25 @ 11:23 AM

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Comment From: Valarie St Marie

10/29/25 @ 11:12 AM

In the coming months, we'll continue to push for good ideas and bold ideas to reduce transportation pollution. So, you'll be hearing from us! Thanks so much for your support.

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Comment From: Michael Lutomski

10/29/25 @ 11:11 AM

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Comment From: David Camp

10/29/25 @ 11:07 AM

Speaking as an older Eastern Washington resident of limited means, I hope you'll help make electric vehicles more affordable. With the Federal government revoking its EV incentives, it's time for the state to step in, helping those of us concerned ab...↓

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Comment From: David Turnoy

10/29/25 @ 11:01 AM

I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being! The state needs to make up for the federal government moving backwards on climate and clean transportation policy.

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Comment From: James Cronin

10/29/25 @ 10:03 AM

I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being!"

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Comment From: Climate Action of Southwest Wa... (Don Steinke)

10/28/25 @ 8:05 PM

1. Keep this in mind. Semi-trucks don't need to be long haul. They're usually short haul such as from a Safeway warehouse to Safeway stores within 50 miles, or such as Frito Lay plans to have in Vancouver WA. They make the chips in Vancouver and ...↓

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Comment From: Leslie Schneider

10/28/25 @ 1:36 PM

I support ZEVergreen. State action on clean transportation is important to me for our community's well-being.

With federal subsidies now gone, the state should "surgically" help subsidize electric vehicles, especially to replace low fuel efficiency ...↓

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Comment From: NW Alliance for Clean Transpor... (Alex Schlay)

10/27/25 @ 3:54 PM

To whom it may concern,

The NW Alliance for Clean Transportation supports an all-of-the-above approach to fleet decarbonization. This “all-of-the-above” approach must be governed, first and foremost, by duty cycle, i.e.: Can the vehicle do the work? ...↓

In general, we take this opportunity to point out that there are many functions and truck types that cannot accommodate Battery Electric Vehicle (BEV) technology. For example, snowplows cannot accommodate BEV technology. Because in many municipalities refuse trucks double as snowplows, refuse trucks also do not lend themselves to use of BEV technology. Other truck types / duty cycles that do not recommend themselves to use of BEV technology include concrete mixers, trucks that pump out sewer mains, as well as any truck with a Gross Vehicle Weight Rating (GVWR) that is greater than 82,000 lbs. In Washington, most Class 8, over-the-road trucks operate at a GVWR of 105,500 pounds, and there is no Zero Emission Vehicle (ZEV) engine technology that may operate at a GVWR of more than 82,000 pounds.

Given the high cost of ZEVs, ZEVs’ weight & range limitations, as well as limited ($100 million) grant dollars available through the Washington State Department of Ecology to support deployment of ZEVs, we recommend focusing ZEV-deployment efforts on Class 4 – 6 trucks vs. Class 7 & 8 trucks.

I also take this opportunity to note that Compressed Natural Gas (CNG) engine technology is proven, is clean, is inexpensive, can do the work, and can go the distance. Additionally, CNG engine technology does not require incentives to make financial sense. Finally, when trucks and buses are fueled with Renewable Natural Gas (RNG), meaningful reductions in GHG emissions are achieved. I attach a recently-published article that describes the benefits of natural gas trucking.

During recent conversations with fleets that are considering use of CNG engine technology, I get push-back that is related to concerns about fleets’ future ability to use CNG engine technology, e.g.: In 10 years. Given regulatory uncertainty, fleets are unwilling to invest in CNG vehicles and infrastructure. With this backdrop in mind, we encourage regulators to offer assurances that fleets may continue to use CNG engine technology in future when available ZEV technology cannot meet duty cycle requirements.

Thanks in advance for taking our comments onboard, and please do not hesitate to reach out with questions or concerns. We will welcome your call or e-mail, any time.

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Comment From: Nick Maxwell

10/27/25 @ 3:17 PM

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Comment From: David Nightingale

10/27/25 @ 10:18 AM

A strategy to streamline installation of more chargers may be to develop a WA utility standard installation configuration for level 2 and possibly DC fast chargers. If a standard EV charger standard was agreed to by most WA utilities, it could provi...↓

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Comment From: Climate Action of Southwest Wa... (Don Steinke)

10/25/25 @ 7:00 PM

1. I really like the idea of feebates.

Feebates are a policy where fees are charged on inefficient vehicles, and rebates are given to buyers of efficient vehicles, with the fees used to pay for the rebates.
This system creates a financial incenti...↓

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Comment From: Barbara Anderson

10/25/25 @ 4:06 PM

"I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being!"

Transportation is our state's largest source of climate pollution; to meet our climate targets, we need to invest in helpin...↓

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Comment From: Brie Gyncild

10/24/25 @ 12:04 PM

I support ZEVergreen. Especially now that we can't count on the federal government to keep us safe, state action to promote clean transportation is imperative.

We need to do everything we can to reduce the use of fossil fuels in our transportation...↓

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Comment From: Anne Miller

10/23/25 @ 11:59 AM

I support ZEVergreen. We need action on clean transportation. Preserving our environment is crucial to me and my community, family, health, well-being!

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Comment From: Gretchen Garth

10/23/25 @ 11:39 AM

I support ZEVergreen. State action on clean transportation is important to me and my community, family, health, well-being!

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