ACC II and ACT, adopted by Maryland in 2023 and modeled after California’s zero-emission vehicle (ZEV) framework, require increasing percentages of electric and other zero-emission vehicles in the state’s auto and truck fleets. However, due to federal policy challenges—including stalled National Electric Vehicle Infrastructure (NEVI) funding and global supply chain volatility triggered by tariffs—original equipment manufacturers (OEMs) have warned that achieving compliance in the near term may be unrealistic.
In response, Governor Moore’s executive order directs the Maryland Department of the Environment (MDE) to temporarily ease enforcement of penalties for ZEV shortfalls in model years 2027 and 2028. It also establishes a multi-stakeholder working group to develop implementation recommendations, with a final report due by December 31, 2025.
The decision has been welcomed by industry groups, who view the action as necessary to navigate uncertainty without jeopardizing long-term regulatory alignment.
For automotive manufacturers and dealerships, the executive order provides breathing room as the state advances its zero-emission goals. By exercising enforcement discretion and delaying penalties, Maryland is signaling to the private sector that it recognizes the economic and logistical hurdles posed by the current federal landscape.
The ACC II and ACT Working Group—comprising up to 15 members from state agencies, OEMs, dealer associations, trucking groups, environmental organizations, and lawmakers—will meet monthly to inform a balanced and achievable compliance roadmap. The group’s recommendations are expected to shape how Maryland integrates EV adoption with grid reliability, charging infrastructure development, and market readiness.
Despite the state’s intention to preserve the long-term viability of its clean transportation strategy, some environmental organizations argue the executive order sets a dangerous precedent.
The Maryland Sierra Club voiced strong opposition, warning that any delay in ZEV mandates could undercut public health protections and derail critical emissions reductions. Senior Clean Transportation Representative Lindsey Mendelson has emphasized that postponing implementation harms both climate progress and community well-being, urging the state to pursue immediate and decisive action rather than concessions.
Meanwhile, the Maryland League of Conservation Voters (LCV) offered a more nuanced response. While it had previously opposed legislative efforts to delay the EV mandate, the group welcomed the executive order’s approach for working within the existing regulatory framework.
Former California Air Resources Board official Craig Segall also weighed in, suggesting that Maryland’s move came too soon and conceded to manufacturer pressure without fully exploring state-driven solutions to implementation concerns.
Maryland’s actions will likely be watched closely by other states that have adopted CARB-aligned standards under Section 177 of the Clean Air Act. The balance struck between regulatory flexibility and program integrity could serve as a model—or a cautionary tale—for jurisdictions seeking to navigate a turbulent transition toward transportation electrification.
Governor Moore’s administration has reiterated its commitment to the state’s climate goals, emphasizing that enforcement discretion is temporary and intended to avoid longer-term disruption to ZEV deployment. The executive order expressly calls for collaboration with CARB and other aligned states to counteract harmful federal policy impacts and restore momentum in clean vehicle adoption.
