On-road gasoline and diesel emissions have decreased steadily and will continue to decrease with the influx of vehicles meeting federal Corporate Average Fuel Economy (CAFE) standards and increased demand for EVs. Emissions from heavy-duty diesel vehicles have remained consistent since 2006 but the U.S. Environmental Protection Agency’s (EPA) more stringent heavy-duty engine and vehicle GHG standards will be fully implemented by model year 2027.
To achieve deeper reductions from the transportation sector, it will be necessary to transition much of the light-duty fleet to ZEVs by 2031 and increase the use of other modes of transportation, including public transportation and micro-mobility options. New charging infrastructure will need to be developed and installed in conjunction with the retrofitting of existing gas stations to support charging stations. Public transportation and mobility alternatives must be enhanced, with an emphasis on promoting sustainable growth and other transit and mobility-oriented development.
Zero-Emission Vehicle Infrastructure Plan
(current)
To accomplish Maryland’s goal for rapid growth in the number of ZEVs on Maryland’s roads, building out a robust ZEV infrastructure network is critical. As such, the Maryland Department of Transportation’s (MDOT’s) National Electric Vehicle Infrastructure (NEVI) Plan, which was developed in partnership with MEA, serves as the foundational first step for this strategic network buildout. MDOT submitted the Maryland State Plan for NEVI Formula Funding Deployment to the Federal Highway Administration (FHWA) in 2022, and the 2023 Update of the ‘NEVI Plan’ in August 2023. The 2023 Plan Update, approved by FHWA in September 2023, describes Maryland’s activities that support the successful deployment of charging infrastructure.
The NEVI Plan details the strategy for awarding $63M of NEVI funds to build out and certify Maryland’s 23 EV Alternative Fuel Corridors (AFCs). This ensures that there will be reliable EV infrastructure accessible to the traveling public, with a minimum of two stations per AFC capable of charging four EVs simultaneously and located no more than 50 miles apart. MDOT anticipates the addition of 40-48 charging sites along Maryland AFCs to achieve corridor build-out and certification by FHWA. The NEVI Plan is updated annually. In its 2024 update of the NEVI Plan, MDOT will address potential applications of NEVI funding to support MHDV/Trucking infrastructure and investments in community charging to increase equitable charging access across diverse locations in the state. Throughout this deployment, MDOT will prioritize disadvantaged and rural communities, support workforce development, and collaborate closely with public and private stakeholders. The remaining NEVI funds will then be invested in community charging to increase equitable charging access across diverse locations in the state.
Advanced Clean Cars II
(current)
Governor Moore took swift action in the first few months of his Administration to adopt regulations that require car manufacturers to offer more zero-emission cars to consumers in Maryland. This policy alone may do more than any other to reduce GHG emissions in Maryland.
Vehicles sold in the United States must be certified under one of two certification programs: the federal program administered by EPA or the California program. Section 177 of the Clean Air Act Amendments of 1990 provides states with the ability to adopt the California program instead of the federal program as long as the adopted state program is identical to the California program and the state allows two model years lead time from adoption to implementation.
The Maryland Clean Cars Act of 2007 required MDE to adopt regulations implementing the California Advanced Clean Cars I (ACC I) program in Maryland. Maryland’s implementing regulations adopted, through incorporation by reference, the applicable California regulations. The ACC I program is a dynamic, changing program in which many of the relevant California regulations are continuously updated to stay current with vehicular technology advancement and environmental science. To retain California’s standards, Maryland must remain consistent with their regulations, hence when California updates its regulations, Maryland must reflect these changes by amending our regulations. The ACC I program included requirements for vehicles through model year 2025.
The Advanced Clean Cars II (ACC II) program requires that by 2035 all new passenger cars, trucks, and SUVs sold will be ZEVs. The ACC II program takes the state’s already growing ZEV market and robust motor vehicle emission control rules and augments them to meet more aggressive tailpipe emissions standards and ramp up to 100% ZEV. The ACC II program adopts new requirements for model year 2026 and later vehicles. Maryland’s implementation of the ACC II program will begin with the 2027 model year.
The ACC II program will result in significant additional emission reductions in Maryland as compared to the program currently in effect. Between 2027 and 2040, the updated program will deliver additional vehicular reductions of 5,978 tons of nitrogen oxides (NOx) and 585 tons of fine particulate matter 2.5 micrometers in diameter and smaller (PM2.5), as well as additional vehicular and power plant CO2 emission reductions of 76.7 million metric tons. By 2040, these reductions provide net health benefits equal to about $604 million annually due to decreases in respiratory and cardiovascular illness and associated lost work days.
The ACC II program applies to automobile manufacturers that produce new motor vehicles for sale in Maryland. All vehicle types that have a gross vehicle weight rating of less than 14,000 pounds are affected.
Although there are a substantial number of conforming revisions, the major revisions associated with the ACC II program consist of a requirement that vehicle manufacturers continue to offer more ZEVs for sale, culminating in a 100% sales requirement by model year 2035, and a requirement that internal combustion engine vehicles meet increasingly stringent pollutant standards during the period in which they continue to be sold.
ZEVs consist of all-electric EVs with a minimum range of 150 miles and plug-in hybrid electric vehicles (PHEVs) with a minimum all-electric range of 50 miles. PHEVs are allowed to satisfy 20% of overall ZEV sales requirements. Additional flexibility options are available in model years 2027 through 2030. Vehicle manufacturers are also allowed to carry forward and use compliance credits generated before model year 2027. To ensure that vehicles sold under the program are reliable and perform as well or better than their internal combustion engine counterparts, stringent requirements related to vehicle (and battery) durability, vehicle charging capability, on-board diagnostics, warranty, and reporting are established to ensure that ZEVs perform as designed throughout their full useful life.
Advanced Clean Trucks
(current)
The Clean Air Act established the framework for controlling harmful emissions from mobile sources. At the time, California had already established its own emission standards for mobile sources, and so was granted the sole authority to continue adopting vehicle emission standards, so long as they were at least as protective as the standards set by EPA.
The harmful emissions from medium- and heavy-duty trucks pose a serious threat to both public health and climate change. Recognizing this, California has adopted the Advanced Clean Trucks (ACT) regulation that aims to reduce on-road emissions from the medium- and heavy-duty truck sector to a greater extent than the current EPA standards.
Section 177 of the Clean Air Act allows other states to adopt the California standards if they are identical. Maryland’s Clean Trucks Act of 2023 requires MDE to exercise this authority and adopt regulations implementing the California ACT program in Maryland. MDE adopted regulations in 2023 through incorporation by reference of the applicable California regulations.
The Clean Trucks Act of 2023 reinforces the state’s ongoing commitment to reducing climate pollutants to reach the nation-leading goal of achieving a 60% reduction in GHG emissions by 2031. Medium- and heavy-duty trucks account for about a third of Maryland’s transportation emissions. On-road diesel trucks are the largest contributor to NOx emissions in Maryland.
Adopting ACT in Maryland will result in a significant reduction of harmful emissions associated with medium- and heavy-duty trucks and help Maryland attain its air quality goals. The ACT program will reduce NOx, PM2.5, and GHG emissions from the mobile source sector as cleaner, zero-emission trucks replace older internal combustion vehicles.
Zero-Emission Transit Buses
(current)
Maryland is investing in transitioning its public transit bus fleet to ZEVs. The first seven electric buses were delivered to the Maryland Transit Administration (MTA) in the Fall of 2023, and MTA is contracting for up to 350 more over the next five years. In addition, MTA is working closely with its electric utility provider, electric charging and power distribution suppliers, transit labor unions, and employees to ensure a seamless transition to zero emissions that maintains reliable bus service. Technology advances that increase the range of electric transit buses and increase hydrogen fuel availability will be important components to successful transit fleet conversions in Maryland.
Zero-Emission School Buses
(current)
Transportation contributes more GHG emissions than any other sector, and the nation’s 480,000 school buses make up its single largest public transportation fleet — a fleet that millions of children rely on to get to school safely (and far more efficiently than if every student were to drive on their own). Approximately 90% of buses run on diesel fuel.
Switching over to electric fleets has become a goal for many cities and school districts. As of June 2023, there were 2,277 electric buses either on the streets or on order for school districts in the U.S., according to the World Resources Institute. More than double that number are committed, meaning that school districts plan to continue electrifying their fleets.
Federal funding from the 2021 Bipartisan Infrastructure Law has been crucial to this trend, largely because one of the biggest barriers to electrifying school bus fleets is the price tag. The cost of an electric bus can be about three times the cost of a diesel bus.
Montgomery County has the largest electric school bus project in the country, and it offers a different model for the switch to electric buses. Rather than purchase its own buses, the county partnered with a private contractor, which works with municipal partners to help manage the process of adopting this new technology. This contractor works with Montgomery County to secure funding — by applying to EPA grants, for instance — and then buys the buses from EV manufacturers. The company essentially provides electrification as a service, from the hardware of the buses themselves to the software that optimizes charging schedules. It is also responsible for all repairs and maintenance, although the company offers training so that cities can keep their existing staff and contracts. Montgomery County has set its sights on a fully electric fleet within 10 years. For its initial pilot, the county has committed to swapping 326 of its buses to electric by 2025, and 86 are already running.
Last fall, Baltimore City received $9.4 million from EPA’s Clean School Bus Program. It was one of nearly 400 school districts from across the country selected to receive funding for new buses, with a focus on underserved areas and those overburdened by pollution, in keeping with President Biden’s Justice40 goals. For Baltimore, going electric wouldn’t have been possible without the help of the EPA grant.
The CSNA includes school bus electrification as a goal for the state. Under the CSNA, beginning in fiscal year 2025, a county board of education may not enter into a new contract for the purchase or use of any school bus that is not a zero-emission vehicle. There are exemptions for lack of sufficient funding or availability of a vehicle that meets the performance requirements. The CSNA also permitted electric utilities to provide rebates for school buses subject to certain limitations.
Baltimore is now preparing to launch its own pilot, following its neighbor’s model and partnering with a private contractor. A depot with 25 charging stations was constructed in the summer of 2023. Twenty-five electric school buses are scheduled for delivery by the end of 2023. Baltimore City’s contractor will offer training for the drivers on best practices for things like maximizing energy efficiency, and then the buses can hit the road.
Advanced Clean Fleets (potential)
The California Advanced Clean Fleets (ACF) regulation applies to fleets performing drayage operations (freight from an ocean port to a destination), those owned by state, local, and federal government agencies, and high-priority fleets. High-priority fleets are entities that own, operate, or direct at least one vehicle in the state, and that have either $50 million or more in gross annual revenues, or that own, operate, or have common ownership or control of a total of 50 or more vehicles (excluding light-duty package delivery vehicles). The regulation affects medium- and heavy-duty on-road vehicles with a gross vehicle weight rating greater than 8,500 pounds, off-road yard tractors, and light-duty mail and package delivery vehicles. Under the ACF program, covered fleets are required to make an increasing amount of their new purchases be ZEVs. These ZEV purchase requirements are phased-in beginning in 2025. Between 2035 and 2042, all covered fleets are required to make 100% of their new vehicle purchases ZEVs. This regulation would work in conjunction with the ACT regulation, which helps ensure that ZEVs are brought to market.
ACF is modeled to avoid annual GHG emissions of 1.8 MMTCO2e in 2045, however, more detailed analysis is needed to determine the incremental emissions impact of ACF compared with ACT. MDE would be responsible for developing, adopting, and implementing regulations to enact and enforce ACF in Maryland. MDE intends to work with stakeholders in 2024 to analyze and determine if adopting ACF would result in emissions reductions beyond those expected by Maryland’s adoption of the ACT regulation.
Maryland Transportation Plan
(new)
Vehicle miles traveled (VMT) is a major indicator of transportation sector GHG emissions. VMT has steadily increased in Maryland since 2014, with over 60 billion VMT in 2019. VMT dropped in 2020 due to the COVID-19 pandemic but had mostly rebounded to pre-pandemic levels. While MDOT anticipates that VMT will return to 2019 levels over the next five years, there is uncertainty regarding the exact timeline and pace of the recovery.
Reducing projected traffic on Maryland’s roads is crucial to reducing GHG emissions from the transportation sector. This is why MDOT’s draft 2050 Maryland Transportation Plan (MTP) includes an objective to reduce VMT per capita by 20%, which will guide transportation project selection and development.
MDOT has a track record of investments and measures that help reduce VMT. For example, the Kim Lamphier Bikeways Network Program identifies and funds projects that maximize bicycle access, fill missing gaps in the state’s bicycle network, and enhance last-mile connections to work, school, shopping, and transit. MDOT also administers the statewide transportation demand management (TDM) program Commuter Choice Maryland, which works collaboratively with 12 local government agencies that implement localized TDM programs. Commuter Choice works with employers across the state to implement commuter benefits and administers statewide incentives for commuters and employers, including the incenTrip app, Employer Partner Program, and the Maryland Commuter Tax Credit.
New VMT reduction measures will include investments to deliver more transportation choices as well as incentives to encourage the use of such options. Specifically, MDOT initiatives include launching new public transportation infrastructure such as rail and clean bus lines, making transit safe, efficient, and easy to use, and actively catalyzing Transit-Oriented-Development (TOD) to help increase transit ridership and support housing and economic development. MDOT will ramp up investments and policies to accommodate bicyclists and pedestrians routinely and safely on our extensive road network by retrofitting streets with bike lanes, sidewalks, and traffic calming measures. MDOT will also increase our commitment to TDM measures. For example, Commuter Choice Maryland has helped expand IncenTrip statewide and is exploring options to implement a statewide vanpool incentive and support the Maryland Jobs Access Reverse Commute (MD-JARC) program.
State Incentives for Purchasing Electric Vehicles
(current, modified)
The state will increase its investment to help people purchase EVs and install electric vehicle supply equipment (EVSE). This investment will significantly reduce GHG emissions and transportation costs for individuals, businesses, and other entities in Maryland.
Maryland currently offers an EV excise tax credit, administered through the Maryland Vehicle Administration (MVA). New point-of-sale rebates will lower the upfront cost of buying new and used EVs. Several EVs are now priced below the national average price of new cars but the options of EVs are still limited and many EVs are still priced above levels that are affordable for low and moderate income consumers, so state incentives in the near term will help accelerate the adoption of EVs. The proposed new incentives, presented here, were recommended by the Maryland Commission on Climate Change in 2023 with input from consultants, automotive dealers, and other stakeholders.
A new Maryland Clean Vehicle Rebate program will provide a point-of-sale rebate of $2,500 for a new EV and $1,000 for a used EV to all Marylanders who meet the criteria to qualify for the federal Clean Vehicle Credit. The state incentive will stack on top of the federal incentive, which offers up to $7,500 for a new EV and $4,000 for a used EV. Combined, qualifying Marylanders would save $10,000 on a new EV and $5,000 on a used EV, making it even easier and less expensive for all low, moderate, and middle income individuals, businesses, and tax-exempt organizations to purchase EVs.
Low and moderate income Marylanders will be eligible for an additional bonus rebate of $5,000 for a new EV and $3,000 for a used EV, which brings the combined federal and state incentives for low and moderate income households to $15,000 for a new EV and $8,000 for a used EV. These stacked rebates roughly cut in half the purchase price of the more affordable new and used EVs currently available for sale. The new state rebate is designed to reduce a low and moderate income household’s transportation costs to around 10% of annual income, which could significantly reduce the energy cost burden for many Maryland households.
A Superuser Bonus program will provide additional incentives for Marylanders, including individuals and businesses/tax-exempt organizations located in Maryland, that commute the farthest and consume much more than the average amount of fuel for drivers in the state. Superusers in Maryland consume approximately two or more times the amount of motor fuel used by average drivers and tend to drive long distances for work. Helping superusers, who represent roughly 10% of Maryland drivers, switch from internal combustion vehicles to EVs would reduce on-road gasoline emissions by 30% or more.
The state will also provide technical assistance grants to owners of small fleets (with 10-199 vehicles) to help develop fleet electrification plans. Fleet vehicles are typically driven more miles annually than average vehicles, so they have an outsized impact on transportation sector emissions and an outsized opportunity to reduce emissions through electrification. Additional details on these incentives can be found in the 2023 Annual Report of the Maryland Commission on Climate Change.
Table 1: Maryland’s potential new EV incentive programs (contingent on funding)
