Fleet Electrification Step 7: Coordinate Site Financial Planning with Headquarters

All Executive Branch agencies must submit an AFBS in FAST. There is no minimum inventory or cost threshold. There also are no exclusions for any types, sources, or uses of vehicles. All vehicles owned or leased by the agency must be reported, including so-called "special purpose" vehicles and vehicles provided to contractors. Agencies should use the fleet budget narrative template provided by the General Services Administration (GSA) for the Office of Management and Budget (OMB) A-11 process, which is available in the FAST Budget Data tab.

The AFBS should address and incorporate the funding necessary to meet the Executive Order (EO) 14057 fleet electrification goals and achieve the agency's Zero-Emission Fleet Strategic Plan. This includes the total funding necessary to meet the near-term cost estimates for ZEV and EVSE deployment, and how much of the proposed targets will be met through the agency's direct budget request and how much may be required from other sources.

Although the submission of the fleet budget and inventory projections is not finalized until late August, the closing of the primary FAST data call in mid-December has very important ramifications for the preparation of the budget submission. Actual (previous fiscal year) inventory and cost data are captured and frozen during the mid-December annual FAST reporting; they serve as the baseline for the OMB budget submission.

Prior to the close of the FAST data call in mid-December, agencies must review the draft fleet budget and inventory projections on FAST's Budget Data tab to ensure that the baseline inventory data, the baseline cost data, and the planned, projected, and forecast vehicle acquisition and disposal data are correct and complete.

Resources and information on leasing or purchasing AFVs, including ZEVs, through GSA is available from GSA's Alternative Fuel Vehicles website, and summarized below.

Leasing ZEVs Through GSA

Agencies acquire most of their vehicles, including ZEVs, through leasing or purchasing from GSA. For vehicles leased through GSA Fleet, vehicle funding requirements (i.e., monthly lease rates) are determined based on the number and type of vehicles in the fleet. Additionally, ZEVs typically require incremental costs for acquisition that cover the difference between the vehicle's acquisition cost and the lowest cost vehicle in that vehicle type or Standard Item Number (SIN).

These costs are not allocated to a specific fleet location or vehicle; EPAct 2005 requires GSA Fleet to spread the incremental costs across the entire agency fleet.

The incremental costs for ZEVs are expected to decrease over the next few years, and likely will reach cost parity with conventional vehicles.

Purchasing ZEVs Through GSA

For the purchase of agency-owned ZEVs, GSA is a mandatory source under Federal Property Management Regulation (FPMR) (41 CFR § 101-26.501-1). Vehicle funding decisions are simply based on comparing the available budget with the total cost of vehicles, which reflects the total cost of ZEVs including incremental costs. The agency is responsible for determining which of its vehicles are eligible for replacement, and the availability of funds to support those acquisitions.

In early 2022, GSA awarded Blanket Purchase Agreements (BPAs) for EVSE (charging stations) and ancillary services. These agreements provide a wide range of EVSE options supported by a streamlined ordering process and reduced administrative burden.

The BPA encompasses a wide range of commercially available EVSE options:

• Level 1 single or dual port, wall or pedestal mounted (non-networked without the ability to capture and collect data)
• Level 2 single or dual port, wall, pole, or pedestal mounted stations (with the ability to capture data for networked stations)
• DC Fast Charge, single or dual port, wall or pedestal mounted, with access to a connected data network.

Planning, design, and installation services are also available through the BPA.

Some offerings include data subscriptions, which include collection of station-level and vehicle transactional data, automatic data transmission, and management of data on a web-based portal or network. At the time of award, networked hardware was not available for ordering through the BPA as they were awaiting approval for FedRAMP. Federal agencies could make their own determinations on IT security and supply chain risk management (SCRM) requirements if they choose to acquire EVSE through GSA Advantage.

Installation staff can either install and manage EVSE themselves or hire a contractor to do so. Installing the EVSE requires staff with the necessary electrical and construction expertise but can reduce costs. Contracting out the work is generally simpler, but more expensive. At GSA managed facilities, GSA's Public Building Service (PBS) will assist with conducting assessments for EVSE deployment.

Complementing the GSA BPAs for EVSE, GSA's PBS awarded government-wide Indefinite Delivery Indefinite Quantity (IDIQ) contracts for design, build, and construction services for infrastructure installation, including:

• EVSE installation
• Feasibility studies and site assessments
• Construction and design-build services
• Utility company coordination
• Electrical infrastructure upgrades like switchgear and transformers, and more
• Site work services like trenching, bollards, signage, pavement markings, and more
• Equipment testing and commissioning.

See more information on IDIQ contracts.

Funding decisions should account for fuel and vehicle maintenance savings achieved through ZEVs, while preparing for the O&M costs to support the EVSE units and pay for network fees, if applicable, in the coming years. For GSA full-service or "wet-leased" vehicles, the mileage rate for ZEVs, which accounts for public fuel and all maintenance costs, is significantly less than for the equivalent conventional vehicle. For example, in FY 2022, the mileage rate for BEV sedans was 56% less than for gasoline versions, and 23% less for PHEV sedans.

EVSE may be funded by AFFECT grants in some circumstances. DOE manages the Assisting Federal Facilities with Energy Conservation Technologies (AFFECT) grant program for federal agencies. The 2022 guidance for AFFECT grants clarified that "EVSE that provides load management services" may be funded through the program.

AFFECT is designed to leverage appropriated money, other grants, and energy savings performance contracts (ESPCs), which fund the "design, acquisition, installation, testing, measurement and verification, and, where appropriate, operation, maintenance, repair, and replacement, of an identified energy conservation measure [ECM], water conservation measure, [or a combination of both]."

EVSE and components of EVs may be incorporated into ESPCs in some circumstances. DOE guidance on Federal Energy Savings Performance Contracts provides that EVSE and components of EVs may qualify as energy conservation measures (ECMs) in ESPCs in specific circumstances, described below.

Can federal agencies use ESPCs to purchase electric vehicle supply equipment?

Electric vehicle supply equipment (EVSE) may be incorporated into an ESPC if it is part of an energy conservation measure (ECM) or if it is demonstrated that the EVSE results in energy savings to a federal building. Three examples demonstrate permissible instances: (1) a power generation ECM, such as photovoltaics or cogeneration, that includes equipment such as EVSE to facilitate delivery of power to an end use; (2) an ECM that includes EVSE with charging capabilities employed for load management (e.g., kW savings and energy related cost savings), such as participation in a demand response program; or (3) an ECM that replaces existing EVSE with more efficient EVSE, where doing so results in energy savings to the federal building.

Where EVSE is incorporated in an ESPC, the energy used by the EV (e.g., gasoline, electricity, or other) for non-building purposes would not be included in the ESPC building energy use calculations.

Because ESPC applications for EVSE could be complex, agencies should contact FEMP as they consider the incorporation of EVSE in an ESPC.

Can federal agencies use ESPCs to purchase electric vehicles?

The ESPC statute does not confer authority for agencies to procure electric vehicles (EVs) as part of an ESPC. In limited circumstances, however, there may be an opportunity for components of EVs to be included in an ESPC. For example, a load management ECM that incorporates bi-directional charging from an EV to provide power for building backup or load management (e.g., for the purpose of participating in a demand response program) could incorporate the EV components used for those purposes (e.g., the vehicle's battery, charging unit, controls, related construction and/or supporting infrastructure, and related components) in an ESPC.

Where EV components are incorporated in an ESPC, the energy used by the EV (e.g., gasoline, electricity, or other) for non-building purposes would not be included in the ESPC building energy use calculations.

Because ESPC applications for EV components are limited, agencies should contact FEMP as they consider the incorporation of EV components in an ESPC.

EVSE has been installed through ESPCs at federal facilities in the past, including Fort Buchanan in Puerto Rico. However, in that instance and others, the EVSE was only accounted for as an additional expense, and the overall project remained life cycle cost effective.

Under GSA Areawide Contract (AWC) Exhibit A, the serving utility can fund the upfront cost of charging infrastructure, including electrical upgrades. The costs must be repaid over 10 or more years through utility bills as a special facility charge. Utilities determine what costs they will fund through areawide contracts. Therefore, this funding approach requires working closely with local utilities.

Utility energy service contracts (UESCs) have been used by federal agencies to install EVSE as part of larger projects. However, UESCs, like ESPCs, require that EVSE qualify as energy conservation measures with positive lifecycle cost impacts.

The integration of EVSE and EVs into UESCs is a new potential application of 42 United States Code (U.S.C.) 8256. Agencies are encouraged to work with this legal and contracting teams to determine what is appropriate to include in a UESC executed outside of a GSA AWC. If using a GSA AWC, contact GSA with any questions regarding what may be included. FEMP currently does not have a collection of case studies or information upon which to recommend best practices.