California Air Resources Board

August 1, 2025

The Honorable Gavin Newsom
Governor of California
1021 O Street, Suite 9000
Sacramento, CA 95814

Cc:
David Hochschild; Chair, California Energy Commission
Liane Randolph; Chair, California Air Resources Board
Dee Dee Myers; Senior Advisor to the Governor & Director, GO-Biz
Nichole Quick; Director, Department of Consumer Affairs
Toks Omishakin; Secretary, California State Transportation Agency

Re: Executive Order N-27-25 and CA ZEV Forward

Dear Governor Newsom,

Voltera Power, LLC (Voltera) and Greenlane Infrastructure, LLC (Greenlane) thank you for your ongoing leadership on transportation electrification, evidenced by the June 12, 2025 Executive Order N-27-25. That leadership is more critical now than ever, as the state and industry must take aggressive forward steps to ensure American competitiveness in vehicle, battery, infrastructure, and business model innovation, production, and deployment.

Voltera and Greenlane appreciate the approach taken with the ZEV Forward listening and dialogue sessions, including the engagement of critical state agencies and their leaders, to help inform policy and incentives necessary to strengthen the industry’s path forward and respond to evolving federal policy.

The central question posed during the ZEV Forward sessions sought to identify the most necessary and impactful action for California to take to enable continued and accelerating progress to support the industry and achieve California’s robust economic, climate, and electrification objectives. In short, Voltera and Greenlane believe the most necessary and impactful action for California to take is to ensure the economics of and the economic signals for electrification are adequate to drive accelerated growth and scaling of vehicle adoption and infrastructure deployment.

Accomplishing this implicates – at a minimum – strategic changes to a limited number of existing policies and incentive programs, and may implicate the development of a limited number of new programs up to a whole-of-government approach to ensure that California’s combined portfolio of policies and incentives creates or enables these economics.

The economics for electrification must work for manufacturers and dealers producing and selling electric vehicles, fleets and individuals buying electric vehicles, fleets and individuals who have already bought or leased electric vehicles, infrastructure developers who are investing in charging facilities, and infrastructure owners who have already invested in charging facilities.

Key policy and incentive changes or developments to accomplish this economic state include:

1. Replace the Federal 45W Credit: California must address the gap for businesses presented by the sunsetting of the federal 45W commercial clean vehicle credit, for vehicles of all weight classes, including light-duty vehicles.
2. Protect and Strengthen HVIP and CCFR: Ensure that the incentive levels of the Hybrid and Zero Emission Truck and Bus Voucher Incentive Program (HVIP) and the future California Clean Fuel Reward (CCFR) program authorized by the California Air Resources Board are sufficient to match or surpass the economics of purchasing traditional combustion engine vehicles, including considerations such as sales tax and insurance premiums.
3. Prioritize Infrastructure Access Flexibility: Create flexibility in existing vehicle and infrastructure incentive programs to enable vehicle owners/fleets the ability to utilize infrastructure incentives to access infrastructure in addition to the historic approach of incentive provision only for building or installing infrastructure; and evaluate the development of new incentive programs to ensure infrastructure access for fleets and vehicle owners that cannot or do not wish to charge their vehicles at their own facilities, either because they lack such facilities; or they lack the necessary landlord permissions, access to power, or the desire, expertise, or funding to install infrastructure at their own facilities.

The above actions and continued attention to enabling the state’s utilities to efficiently energize charging projects, and the state’s various authorities having jurisdiction to efficiently permit charging facilities will help ensure continued growth and competitiveness in this critical industry.

Voltera, Greenlane, and many others in industry are looking to you and California to take decisive action to meet the moment, and we stand at the ready to engage and partner with the state to scale our infrastructure investment and deployment to serve California’s fleets and electrifying businesses.

Sincerely,
Thomas Ashley
Vice President, Government & Utility Relations
Voltera

Andrea Pratt
Vice President, Government & Utility Relations
Greenlane

Voltera Power, LLC (Voltera), headquartered in California, sites, designs, builds, owns, operates, and maintains charging infrastructure for fleets and branded charging networks that enables customers to fully transition to zero emission vehicles (ZEVs) at speed and succeed with them at scale. Voltera currently operates four charging facilities in California, serving a range of fleets from light-duty ride hail to heavy-duty drayage. For more information, please visit www.volterapower.com.

Greenlane Infrastructure, LLC (Greenlane), headquartered in California, is an industry leader in providing publicly accessible electric vehicle charging centers exclusively for medium- and heavy-duty (MHD) zero emission vehicles (ZEVs). Greenlane addresses the urgent need for a publicly available, nationwide network of high-powered electric charging infrastructure for commercial fleets, including regional and long-haul freight and logistics carriers, and is a critical step toward the development of a sustainable ZEV ecosystem across North America. For more information, please visit www.drivegreenlane.com.