MMA submits comments to the Department of Energy Resources regarding MOR-EV rulemaking proposal

Morgan Bowler
Massachusetts Department of Energy Resources
100 Cambridge St., #1020, Boston

Dear Ms. Bowler,

On behalf of the 351 cities and towns represented by the Massachusetts Municipal Association, the MMA respectfully submits the following comments with regards to the 2026 MOR-EV rulemaking proposal issued by the Department of Energy Resources on July 17, 2026.

The MMA appreciates DOER’s proposal to adjust and streamline the MOR-EV program within its existing statutory authority, with the goals of improving cost-effectiveness and equity. Municipalities across the Commonwealth continue to have strong interest in transitioning their vehicle fleets to electric vehicles (EVs) in ways that reduce long-term municipal costs and advance local and statewide environmental goals.

To ensure the program remains accessible for all cities and towns, the MMA urges DOER to consider the following:

• Equity in Block Structure: The existing block structure, paired with a steeper decline rate, risks disadvantaging smaller towns and communities with more limited administrative capacity, where it may be difficult to submit applications quickly and secure first-block rebate amounts. We appreciate DOER’s commitment to all 351 cities and towns, and encourage measures that align rebates as critical incentives for communities of all sizes.

• Expanded Eligibility for Used EVs: We strongly encourage DOER to make public fleets eligible for the MOR-EV Used program. Allowing municipal access to pre-owned EVs would significantly reduce upfront costs and expand access to affordable fleet electrification options.

Thank you for your consideration of these comments and for DOER’s continued work to improve and strengthen the MOR-EV program. We look forward to continued collaboration on this important issue.

If you have any questions or require additional information, please do not hesitate to have your office contact me or MMA Legislative Analyst Violet Gehr at any time.

Sincerely,

Adam Chapdelaine
MMA Executive Director and CEO