Fleet Electrification Step 3: Review Sustainability Requirements and Site Data

Step 3 of the site-level federal fleet electrification process includes reviewing fleet sustainability requirements, how zero-emission vehicle (ZEV) acquisition helps meet those requirements, and data on existing fleet operations.

A critical step in developing a fleet electrification strategy and plan is understanding:

• Federal fleet sustainability requirements
• How incorporating ZEVs into fleets can help with meeting those requirements
• How data collection and reporting help to determine compliance with EV and EVSE requirements and evaluate progress in electrifying fleet vehicles.

Reduce Petroleum Consumption

The Energy Independence and Security Act (EISA) Section 142 petroleum reduction goal (42 U.S.C. § 6374e(a)(2)) requires each fleet to reduce their annual petroleum consumption by at least 20% compared to a FY 2005 baseline by FY 2015 and for each year thereafter. 

Other energy and environmental statutory requirements support this goal, including requirements to increase alternative fuel use, use alternative fuel in dual-fueled alternative fuel vehicles (AFVs), deploy alternative fuel infrastructure, acquire AFVs and low-GHG emitting vehicles, and right-size the fleet using a vehicle allocation methodology (VAM) study.

Primary Federal Fleet Statutory Requirements

The current regulatory landscape is centered around the Energy Independence and Security Act (EISA) Section 142 petroleum reduction requirement (42 U.S.C. § 6374e(a)(2)), which requires each fleet to reduce their annual petroleum consumption by at least 20% compared to a FY 2005 baseline by FY 2015 and for each year thereafter.  

The best strategy for an agency to reduce its fleet's petroleum consumption is through compliance with the four primary Federal fleet sustainability statutes: the Energy Policy Act (EPAct) of 1992, EPAct 2005, the Energy Independence and Security Act (EISA) of 2007, and the General Services Administration (GSA) Federal Management Regulation (FMR). These statutes require Federal fleets to (1) reduce their annual petroleum consumption, (2) use alternative fuels where available, (3) acquire alternative fuel vehicles, and (4) create strategic plans and manage their fleets. The Federal Fleet Requirements Resource Center summarizes these statutory requirements and offers best practices and resources for compliance.
 

Federal Fleet Requirements

EISA Section 142: Petroleum Reduction

ZEVs help agencies achieve their EISA Section 142 petroleum reduction goals by using electricity to displace petroleum use in completing the vehicles fleet's mission. Replacing a conventional-fueled vehicle with a BEV or fuel cell vehicle provides a 100% reduction in that vehicle's petroleum use. Replacing a conventional-fueled vehicle with a PHEV provides substantial reductions in petroleum use, depending on the amount of electricity as well as the amount and type of conventional or alternative fuel used.

EISA Section 142: Alternative Fuel Use

Electricity is considered an alternative fuel under the Energy Policy Act (EPAct) of 1992 (see 42 U.S.C. § 6374(g)(2)). The use of electricity by EVs is counted toward meeting each agency's EISA Section 142 goals to increase annual alternative fuel use by at least 10% relative to an FY 2005 baseline by FY 2015 and for each year thereafter.

EPAct 1992: AFV Acquisition

EPAct 1992 Section 303 (42 U.S.C. § 13212(b)) requires at least 75% of covered LDV acquisitions by federal agencies be AFVs. Agencies must accumulate 75 credits per 100 covered vehicles acquired within each fiscal year to comply and agencies receive one acquisition credit for each non-exempt BEV or PHEV acquired.

EISA Section 246: Renewable Fuel Pumps

Agencies may satisfy EISA Section 246 requirements by installing EV charging stations at federal fleet fueling centers, provided either (1) the electricity used to charge the vehicle(s) is from a renewable source, or (2) agencies have purchased renewable energy credits (RECs) equal to or greater than the amount of electricity used to charge the vehicles.

EISA Section 141: Low GHG-Emitting Vehicle Acquisition

Almost all BEVs and PHEVs meet the definition of low-GHG emitting vehicles in compliance with the EISA Section 141 acquisition requirements.

GSA FMR Section 102-34.50: Right-Size Fleets

Agencies should consider conducting a VAM to identify the optimal vehicle size and mix. Conducting a new VAM study to update an agency's optimal fleet profile in FAST may identify opportunities to replace inefficient vehicles, eliminate underutilized vehicles, and maximize ZEV deployment. Replacing inefficient vehicles yields greater environmental benefits, and higher utilization rates for ZEVs offer a better return on investment.

EPAct 2005, Sec. 701: Alternative Fuel Use in Dual-Fueled AFVs

PHEVs are considered dual-fueled AFVs for Section 701 compliance. These vehicles are expected to use only alternative fuel (i.e., fully charge with electricity) at their garaged locations.

As part of the Commitment Ready component of the ZEV Ready certification, the agency headquarters fleet manager, site ZEV champion, and site location fleet manager(s) should review the information in this section, including the federal fleet sustainability requirements, how the acquisition and deployment of ZEVs and EVSE help agencies meet those requirements, and capturing, managing, reporting, and evaluating fleet data.