Understanding CARB’s ZEV Infrastructure Delay Extension

As we have discussed in previous posts, “An Update on Advanced Clean Fleets (ACF)” and “What are the Costs of Advanced Clean Fleets Noncompliance?,” it’s imperative that fleets move toward the Advanced Clean Fleets (ACF) regulation now in light of upcoming compliance deadlines. But what if your fleet is facing roadblocks? Some fleets will naturally face extenuating circumstances preventing compliance, which is why it’s important to be aware of ACF’s Zero-Emission Vehicle Infrastructure Delay Extension.

This temporary extension preemptively addresses circumstances in which a fleet owner would become non-compliant with the ACF regulation due to infrastructure delays beyond their control. Whether it is a construction delay (e.g., delays in manufacturing/shipping ZEV fueling infrastructure equipment, unexpected safety issues, change of a general contractor, or even a natural disaster) – or a utility delay in which the utility cannot supply enough power to the fleet owner’s site to support the required ZEVs – the extension grants fleet operators additional time to add zero-emission vehicles to their fleet.

An extension for a construction-related delay may be granted for up to two years after the compliance date. In contrast, a utility-related delay extension can be up to three years, with an option to renew the extension for an additional two years based on the situation.

However, building a path toward compliance not only hinges on following CARB’s guidelines but also minimizing these barriers from the get-go to expedite the transition.

Requirements to apply for an ACF compliance extension 

The requirements for a construction related-delay extension are rather clear cut. To be considered eligible, a fleet must:

1. Execute vehicle purchase orders at least one year prior to their ACF compliance deadline
2. Execute contracts for EVSE infrastructure installation at least one year prior to their ACF compliance deadline
3. Provide third-party documentation explaining the reason for delay

However, the requirements for a utility-related delay extension can be a bit more difficult to manage. To be eligible, a fleet must deploy the maximum number of vehicles and chargers that can be supported by a site’s existing electrical capacity. For example, if a project requires 1 MW of power but the site only has .3 MW of power available, a fleet must install chargers and deploy EVs up to that .3 MW threshold to be eligible for the extension. Moreover, fleets must prove to CARB that none of their other California sites have sufficient power to support the EVs needed to achieve their ACF compliance obligations.

This requires significant utility coordination and internal planning which can be a resource draining activity for most fleets.

Recommended best practices to stay compliant with ACF 

But how can fleets prepare for some of these hurdles before they emerge? From Day 1, fleets need to think about the road to ACF compliance, and we have outlined five best practices to get ahead.

Best practice #1: Choose your site wisely

The foremost consideration for any fleet is site selection. Fleets should prioritize sites that they either own or have long-term lease agreements to avoid sinking money into building charging infrastructure at a site where they don’t have a long-term future. For near-term compliance, fleets should prioritize sites that have sufficient energy capacity to charge the number of vehicles necessary to comply with ACF, and ideally, in which no service upgrade is required to power the entire onsite fleet. Site selection also coincides with engaging your utility providers early in the process to understand your sites’ existing electrical capacity (more on that next).

Best practice #2: Manage your stakeholders 

Early on in the electrification journey, fleet owners should identify and manage the relevant stakeholders, as successful collaboration is key to any electrification journey. That’s where single-source solutions like Revolv come in, helping to align key players like utilities, executives, facilities managers, drivers, landlords, and vendors.

Best practice #3: Think one step ahead

The electrification journey also requires forward-thinking that may not be intuitive for every fleet – especially with the long checklist of considerations. Fleets should plan for future compliance obligations, while simultaneously solving for near-term ones. For example, this could look like prioritizing low-hanging sites where no service upgrade is required to electrify the onsite fleet while also taking the first steps to initiate service upgrades at larger sites that will enable future compliance with ACF.

Best practice #4: Document, document, document 

We cannot emphasize enough how important it is that businesses document every step they are taking toward vehicle electrification. CARB has made clear they will be more likely to provide flexibility and leniency to those who document how they’re putting their first foot forward to electrification. Also, and just as important, keeping clean records of your electrification progress will promote collaboration between the many stakeholders involved in a successful EV project.

Best practice #5: Have the right partners on your team

While ACF’s infrastructure extension comes as a relief to many fleets across the state, there are still many steps to take and best practices to keep in mind before it comes to that – all while operating under ACF’s tight deadlines. 

That’s why a critical piece of the puzzle for fleets navigating the ZEV transition is having the right partners by their side. Amid all the moving pieces, Revolv can help fleets build a path to compliance so businesses can focus on what they do best.