Advance Clean Trucks Needs Assessment Released.

December 30, 2025

When Maryland passed the Advance Clean Trucks Rule (ACT) in 2023, MMTA had language inserted that required the state to complete a needs assessment that evaluated grid capacity, product availability, funding, infrastructure, etc. prior to implementation. The ACT requires manufacturers to sell an increasing percentage of zero emission medium and heavy-duty trucks. Congress revoked the ability for any states to move forward with the ACT last Spring; however, those actions are being challenged in court. While Maryland has not joined in the litigation, the state did complete the required needs assessment on December 1. It presents a pragmatic evaluation of what is needed for Maryland to support adoption of ZEV trucks.

Findings include:

Nearly all Class 2b-3 (8,501–14,000 lbs. GVWR) vehicles can charge using relatively inexpensive “Level 2” charging at a depot or home. The most expensive charging infrastructure (DC fast charging), is needed by Class 7 and 8 vehicles with shorter dwell times.
Class 2b-3 vehicles will need a cumulative 23,600 Level 2 charging ports by 2035. Class 4-8 straight trucks will require 15,800 charging ports (12,800 Level 2 ports, plus 3,000 DC fast charging ports). Long-haul trucks will need 900 enroute charging ports by 2035.
Electric distribution network constraints, particularly along freight corridors and at depot locations, represent the primary grid infrastructure challenge from electric vehicles, rather than generation or transmission capacity.
Implementing the ACT is estimated to result in a modest 2.6% increase in total statewide electricity consumption by 2035, but potential transmission and generation constraints could occur if large data centers materialize in the state.
The cumulative investment needed for charging equipment, installation, and utility upgrades is $805 million by 2035. This does not include vehicle costs.
A combination of financial incentives and policy mechanisms is needed to accelerate ZEV purchases and charging infrastructure installation.
Vehicles that run short, fixed, and predictable routes with regular downtimes are the best fit for early electrification, including trash trucks, school buses, regional haul straight trucks and vans for local delivery.

The complete report is at https://dlslibrary.state.md.us/publications/Exec/MDE/EN2-1103.1_2025.pdf.