91TV

Why fleet electrification stopped being a compliance play—and became the sharpest contract-qualification weapon in the business.
By Samuele Barrili

Let me tell you about a hauler I will call Dave, because I have met a dozen Daves and you probably have too. In the middle of 2024, Dave did what every conference keynote and every trade-press headline told him to do. He signed a purchase order for a run of electric front-loaders. His logic was clean, and it was completely wrong. One: California’s Advanced Clean Fleets rule was going to force his hand anyway, so better to move first. Two: the federal government was going to hand him up to $40,000 per truck through the §45W commercial clean vehicle credit. Three—and this was the part he loved most — he was going to repaint the whole operation as the “green leader” in his market and let the trucks do his marketing for him. Rolling billboards, somebody told him.

Then 2025 happened. In January, the California Air Resources Board withdrew its EPA waiver request for Advanced Clean Fleets, gutting the mandate before it ever bound a single private hauler. By May, Congress had used the Congressional Review Act to revoke the Advanced Clean Trucks waiver too—and told California it could not come back with a “substantially similar” rule. By summer, CARB had agreed in a legal settlement to formally repeal the High-Priority and Drayage fleet requirements outright. And on July 4th, the One Big Beautiful Bill Act quietly moved the §45W credit’s expiration from 2032 to September 30, 2025. Dave’s $40,000 per truck evaporated on a Tuesday.

The mandate that was supposed to protect his bet: gone. The subsidy that was supposed to pay for it: gone. And the “green leader” halo he’d bought the trucks to project? That turned into a liability the first time a serious client’s procurement team asked him a question he could not answer: “Show us the audited emissions data, per pickup, so we can put it in our Scope 3 report.” Dave had bought the trucks for every reason except the two that survive. This article is about those two. The market did not stop. The story just changed.

Here is the part that trips people up. Everything I just described did not slow adoption down. California alone had logged more than 6,000 zero-emission truck deployments by the middle of 2024—roughly 15 percent of the national total—according to CALSTART, the group that administers the state’s voucher program. Republic Services has said it is targeting 50 percent of its new vehicle purchases to be electric or alternative fuel by 2028, and the other national players are investing along the same lines. The big operators did not read the 2025 repeals as a reason to stop. They read them as a filter.

Why? Because the refuse truck is one of the few heavy vehicles on Earth that is genuinely well-suited to electrification, independent of any subsidy. Fixed daily routes. Predictable mileage. Return-to-depot every night, so you charge on your own schedule and never need public infrastructure. Endless stop-and-go, which is where regenerative braking recovers energy. On the routes that fit that profile, lower fuel and maintenance costs can pull the total cost of ownership below diesel over the life of the truck, and compressed natural gas has competed with diesel on cost for years already. Diesel exhaust fluid, oil changes, the entire aftertreatment headache: gone.

So, the economics did not die with the mandate. The economics were always the real story. The mandate and the subsidy were just noise loud enough to make people stop doing the math.

What Actually Survived
Do not mistake “the federal mandate collapsed” for “there are no rules.” The compliance pressure did not disappear. It moved down the map, from federal to local, and it changed shape, from mandate to money and contracts.

New York City is the sharpest example. Under its commercial waste zone system, private carters are on the hook to run at least 50 percent zero-emission trucks by 2030 and 100 percent by 2040. That is a live, binding, local mandate in one of the densest hauling markets in the country—and it survived everything that happened in Washington. In July 2025, Interstate 91TV Services, through its Action Carting subsidiary, put its first all-electric refuse truck—a Mack LR Electric—on New York City streets, explicitly tied to its selection as a designated hauler under that program. That is a hauler positioning for zone awards.

On the money side, while the federal check is gone, state and regional vouchers are not. California’s Hybrid and Zero-Emission Truck and Bus Voucher program (HVIP) has offered vouchers up to $420,000 per truck, with an added enhancement for refuse vehicles specifically—a state instrument that does not depend on any EPA waiver, though amounts and windows change funding round to funding round. Regional air districts stack more on top. The subsidy map is now a patchwork you must read district by district, and the operators who read it carefully will buy trucks that their competitors are paying full freight for.

Ultimately, the operator who wins is not the one with the greenest brochure—it is the one who can hand a client a defensible, auditable number: this is the measured emissions profile of your collection, per pickup, documented, third party-verifiable. One of those is a slogan. The other is an asset. Learn to tell them apart and you have understood this entire transition better than most of the companies competing against you. There are three ways to make money on this.

Pathway 1: The Route-Level Swap
Stop thinking “electrify the fleet.” Think “electrify the routes where the math wins and leave the rest alone.” Dense residential and commercial routes with high stop counts and short daily mileage returning to a depot: electric wins there today. Long-haul roll-off runs, rural collection, transfer hauls: often it does not, and CNG is frequently the smarter bridge because parity already exists and the fueling problem is solved. Match the powertrain to the duty cycle, truck by truck, and you will beat the operator who converted everything for a photo op.

Pathway 2: The Contract-Qualification Play
Every large corporation your commercial clients report into is now being squeezed on Scope 3 emissions—the emissions in their supply chain, which includes how their trash gets hauled. When a Fortune 500 facility puts its waste contract out to bid, its procurement scorecard increasingly asks for measured, reportable emissions data from the hauler. Most haulers cannot produce it. If you can if you can walk into that bid with audited numbers instead of adjectives — you are not competing on price anymore. You have moved yourself into a shortlist of one or two. The electric truck is the enabler of that data story. The data is what closes the contract.

Pathway 3: Local-Mandate Arbitrage
Where a real local mandate exists—the NYC zones being the clearest—early movers lock in position while competitors wait for certainty that never comes. Where no mandate exists, do not chase the ghost of one. The discipline is knowing which map you are standing on.

Business Models: Stop Treating the Byproduct as Free
In every waste stream, the money is in the byproduct nobody bothered to capture. This transition has a byproduct almost everyone is giving away: the emissions data itself. You are going to generate it anyway to run the trucks. The telematics are already logging it. So, package it. Sell emissions reporting to your commercial clients as a paid line item, not a courtesy—because it is the exact document their sustainability team needs and currently pays a consultant to fabricate. That is found margin sitting on hardware you already bought.

On the capital side, de-risk the CapEx instead of eating it. Truck leasing and battery-as-a-service structures move the balance-sheet weight off you. Charging-as-a-service and shared-depot arrangements let you avoid fronting the grid upgrade alone. The operators who survive will be the ones who structured the deal so they did not need deep pockets.

The Challenges
The upfront capital is brutal. An electric refuse truck can run well north of half a million dollars before you have poured a single yard of concrete, and the depot itself—transformers, switchgear, chargers, the utility interconnection—routinely adds another $500,000 or more. That interconnection is often the real killer: utility queues can stretch a year or longer, and no amount of enthusiasm shortens them. You order the trucks and then wait to be able to plug them in.

Range and duty cycle bite on the hard routes—long, hilly, hot-climate runs with heavy compaction loads will test a battery in ways a vendor’s spec sheet will not. Drivers need real training, not a memo. Residual values on used electric refuse trucks are still an open question, which makes your five-year TCO model partly an act of faith. And the reputational risk I already named: make a green claim you cannot defend and it becomes the story instead of your service. None of that is a reason not to move. It is a reason to move deliberately—route by route, with the deal structured to survive the parts you cannot control.

The Operators Who Win
Go back to the NYC example. Action Carting did not put an electric truck on New York streets because California told them to, or because Washington paid them to. Neither of those was true. They did it because a local zone system made zero-emission capability a condition of doing business in the highest-value hauling market in the country, and they wanted to be first in line when zones got awarded. That is the whole model in one move: the mandate that matters is local, the reward is a contract, and the truck is the price of admission.

The winners in this next phase will not be the companies with the greenest press releases. They will be the operators who can hand a serious client a serious number—measured, auditable, contract-ready.

The Reframe: The Data is the Asset
The truck is not the asset. The data is the asset. It is the secondary raw material of this entire transition—generated as a byproduct, worth real money to your customers, and packaged by almost nobody. Control the emissions ledger and you control the Scope 3 conversation. Control that conversation and you control which contracts you are even allowed to bid on. Control that, and you control your margin.

The mandate died. The subsidy died. What is left is what was always the only thing that mattered: the operators who understand what they actually control, and monetize it, versus the operators still waiting for someone in Sacramento or Washington to make the decision for them. | WA

Samuele “Sam” Barrili is a waste management strategist, entrepreneur, and author of The 91TV Alchemy. Active in the sector since 2009, he works at the intersection of waste operations, secondary raw materials, compliance strategy, and international business development across Europe, the U.S., and emerging markets. Known as “The 91TV Management Alchemist,” he helps operators move beyond hauling-and-disposal thinking to build resource-based businesses with stronger margins, tighter control of their material—and data—streams, and durable market positioning. Sam can be reached at [email protected] or visit www.sambarrili.com.

If you want to pressure-test whether electrification pencils out on your specific routes—and how to turn your emissions data into a paid contract weapon instead of a paint job—book a free 20-minute call: https://sambarrili.com/schedule-free-20min-call. And if you have not yet, The 91TV Alchemy lays out the full framework for treating what you already touch every day as an asset instead of a burden: https://bit.ly/4sQt4LQ.

Reference

Federal Incentive—§45W termination

• Internal Revenue Service. “Commercial Clean Vehicle Credit.” IRS.gov (updated for the One Big Beautiful Bill Act; no credit for vehicles acquired after September 30, 2025). www.irs.gov/credits-deductions/commercial-clean-vehicle-credit
• 26 U.S.C. § 45W(g) (Termination), as amended by Pub. L. 119-21 (One Big Beautiful Bill Act), July 4, 2025. U.S. House Office of the Law Revision Counsel. https://uscode.house.gov/view.xhtml?req=(title:26%20section:45W%20edition:prelim)
• Plante Moran. “The OBBB and the End of EV Tax Credits: Opportunities Still Exist On or Before September 30.” September 2025. www.plantemoran.com/explore-our-thinking/insight/2025/09/the-obbb-and-the-end-of-ev-tax-credits

California Advanced Clean Fleets—Withdrawal and Repeal

• Trucking Info. “California Abandons Advanced Clean Fleets Rule.” January 15, 2025. www.truckinginfo.com/10234488/california-abandons-advanced-clean-fleets-rule
• 91TV Dive. “California Withdraws Advanced Clean Fleets EPA Waiver Request.” January 2025. www.wastedive.com/news/california-air-resources-board-advanced-clean-fleets-rule-epa-waiver-request-withdrawn/737452/
• 91TV Dive. “Congress Revokes Advanced Clean Trucks Waiver, Creating Ambiguity for Refuse Fleets.” May 28, 2025. www.wastedive.com/news/advanced-clean-trucks-waiver-revoked-refuse-fleets/749130/
• Heavy Duty Trucking / Trucking Info. “California to Officially Repeal Advanced Clean Fleets Rules.” February 3, 2026. www.truckinginfo.com/news/california-to-officially-repeal-advanced-clean-fleets-rules
• Hanson Bridgett LLP. “Untangling the Status of California’s Vehicle Emission Waivers” (state and local government fleet provisions retained). October 2025. www.hansonbridgett.com/publication/250226-2340-clean-air-act-waiver

Local Mandate—NYC Commercial 91TV Zones

• NYC Department of Sanitation. “Commercial 91TV Zones” (mandated under Local Law 199 of 2019). www.nyc.gov/site/dsny/businesses/commercial-waste-zones.page
• 91TV360. “Dissecting NYC’s Commercial 91TV Zones Bill” (targets of 50% zero-emission trucks by 2030 and 100% by 2040). www.waste360.com/waste-legislation/dissecting-nyc-s-commercial-waste-zones-bill

State Vouchers—California HVIP

• California Air Resources Board. “Clean Truck and Bus Vouchers (HVIP)” fact sheet (vouchers range from $7,500 up to $420,000 per truck). https://ww2.arb.ca.gov/resources/fact-sheets/clean-truck-and-bus-vouchers-hvip
• California HVIP / CALSTART. “Industry Initiatives” (25% Refuse Voucher Enhancement). https://californiahvip.org/industryinitiatives

Adoption Data

• California HVIP / CALSTART. “HVIP Hits Record Growth as Zero-Emission Truck and Bus Market Expands” (more than 6,000 zero-emission truck deployments in California — roughly 15% of nationwide deployments — as of mid-2024). April 2025. https://californiahvip.org/news/hvip-hits-record-growth-as-zero-emission-truck-and-bus-market-expands

Operator Commitments—Republic Services

• ACT News. “2025 ACT Expo Fleet Awards” (Republic Services trgeting 50% of new vehicle purchases to be electric or alternatively fueled by 2028). April 30, 2025. www.act-news.com/news/2025-act-expo-fleet-awards-recognizing-excellence-in-sustainable-fleet-management

Case Study—Interstate 91TV Services / Action Carting

• Interstate 91TV Services. “Action Carting Environmental Services Debuts First Electric Collection Truck, Featuring Sesame Street’s Oscar the Grouch.” July 1, 2025. https://interstatewaste.com/action-carting-debuts-first-ev-collection-truck
• Recycling Today. “Action Carting Environmental Services Unveils Electric Collection Truck.” July 1, 2025. www.recyclingtoday.com/news/action-carting-environmental-services-launches-electric-collection-truck