Covered state and alternative 

fuel provider fleets have a choice 

when it comes to complying 

with EPAct fleet requirements: 

Standard Compliance or 

Alternative Compliance. 

The Energy Policy Act (EPAct) of 1992 

was amended several times, allowing state government and alternative 

fuel provider fleets multiple means to 

comply with EPAct 1992’s alternative 

fuel vehicle (AFV) acquisition requirements. Originally, under what is termed 

Standard Compliance, these fleets 

had to acquire a certain percentage of 

AFVs each model year.

Since 2001, fleets have been able to 

obtain some compliance credit for 

the purchase and use of biodiesel. 

More recently, the U.S. Department 

of Energy (DOE) authorized covered 

fleets additional compliance flexibility under what is termed Alternative 

Compliance. This allows the covered 

fleets to employ petroleum reduction 

measures in lieu of simply acquiring 

AFVs under Standard Compliance. 

DOE’s Alternative Fuel Transportation 

Program is responsible for implementing the two compliance options. 

What fleets are covered?

All state government fleets and those 

of businesses whose principal activity 

is based on the production or sale of 

EPAct-authorized alternative fuels may 

be subject to EPAct fleet requirements. 

Typically, covered alternative fuel 

providers have included electric and gas 

utilities and propane providers.

Covered fleets are those state or business fleets that operate, lease, or control 

50 or more light-duty vehicles (LDVs) 

within the United States. Of those 50 

vehicles, at least 20 are used primarily 

within a single Metropolitan Statistical 

Area/Consolidated Metropolitan 

Statistical Area (MSA/CMSA) with a 

population of at least 250,000 under 

the 1980 census. Importantly, those 

same 20 vehicles must also be centrally 

fueled or capable of being centrally 

fueled.

Exclusions that apply to specific vehicle 

types may affect whether a fleet is 

covered. Fleets must notify DOE of 

their covered status, and DOE works 

with fleets to help them understand the 

relevant EPAct requirements.

What are the compliance 

options for covered fleets?

Standard Compliance. Under Standard 

Compliance, covered fleets must 

acquire a certain percentage of AFVs 

each year based on the number of 

LDVs they purchase. Seventy-five 

percent of the new covered LDVs that 

state fleets acquire must be AFVs; 

for alternative fuel providers, this 

number is 90%. Additionally, covered 

alternative fuel provider fleets must use 

alternative fuels in their AFVs, unless 

they operate in an area where the fuel is 

not available. Fleets also may meet up 

to 50% of the AFV acquisition requirements through the purchase and use of 

biodiesel. 

Alternative Compliance. Under 

Alternative Compliance, covered fleets 

may obtain a waiver from Standard 

Compliance to implement petroleum 

reduction measures in their vehicle 

fleets in lieu of the AFV acquisition 

requirements. Covered fleets must demonstrate an annual petroleum reduction 

equal to that which would have been 

achieved in the AFVs it would have 

acquired under Standard Compliance, 

as well as in all the existing fleet AFVs 

that were reported for previous compliance with Standard Compliance 

Requirements. 

State and Alternative Fuel Provider Fleet Compliance Methods

VEHICLE TECHNOLOGIES PROGRAM

EPAct

Fleet Information

& Regulations

continued >
How do fleets comply with 

Standard Compliance?

•	 Acquire new or used LDVs that

are capable of operating on alternative fuels.

•	 Use banked AFV acquisition credits 

or purchase credits from another fleet 

or third party.

•	 Earn AFV acquisition credits 

through the purchase and use of 

biodiesel blends. Fleets must use 

fuel blends containing at least 20% 

biodiesel (B20) in medium- and 

heavy-duty vehicles to earn one credit 

for every 450 gallons of pure biodiesel (B100) that is used. Covered fleets, 

other than biodiesel providers, can 

satisfy as much as 50% of their annual requirements by using biodiesel. 

Biodiesel credits must be used in the 

year they are earned and may not 

be banked or sold. To learn more 

about using biodiesel to comply with 

Standard Compliance, visit www.eere.

energy.gov/vehiclesandfuels/epact/

pdfs/biodiesel_guidance.pdf.

In some cases, DOE may grant exemptions from AFV acquisition requirements if alternative fuels or AFVs are 

not available. For more information on 

exemptions, see the guidance document 

at www.eere.energy.gov/

vehiclesandfuels/epact/pdfs/

exemption_guide.pdf. 

How do fleets participate 

in Standard Compliance?

Fleets must report their AFV acquisitions and any biodiesel purchases to be 

applied for EPAct compliance credit to 

DOE no later than December 31 for the 

model year for which they are reporting. Fleets may enter their compliance 

data into the reporting database on the 

EPAct Web site at www.eere.energy.

gov/vehiclesandfuels/epact/state/progs/

poc_login.html.

Acquisition Credits 

Every light-duty AFV purchased earns 

covered fleets one credit that counts 

toward one AFV requirement for that 

year. If a fleet earns more credits than 

required in one model year, the additional credits may be banked for future 

use or sold to other covered fleets 

participating in Standard Compliance. 

In addition, once the fleet’s lightduty AFV purchase requirements are 

fulfilled, fleets may also earn credits 

for medium- or heavy-duty AFV 

acquisitions. Again, biodiesel purchases 

and use cannot be used to generate 

credits that can be banked or traded. 

A fleet that both maximizes its allowable biodiesel fuel use and exceeds its 

requirements for AFVs, however, will 

end up with surplus credits generated 

by the excess AFV acquisitions. For 

a list of fleets that are looking to buy 

or sell credits, visit the Credit Trades 

Bulletin Board at www.eere.energy.gov/

vehiclesandfuels/epact/state/progs/

vwb/vwb.cgi, or check the list of Fleets 

with Excess Credits at www.eere.energy.

gov/vehiclesandfuels/epact/state/progs/

public_rpt.cgi.

Who should consider 

Alternative Compliance?

Alternative Compliance may be a 

good option for fleets that have limited 

access to light-duty AFVs and alternative fuel infrastructure or those that 

must comply with other policies calling 

for petroleum reduction. Additionally, 

fleets that can readily use biodiesel or 

reduce petroleum consumption may 

find Alternative Compliance an excellent option.

Unlike Standard Compliance, 

Alternative Compliance allows petroleum reductions achieved in excluded 

LDVs and limited numbers of qualified 

non-road vehicles to be counted toward 

compliance with annual requirements.

*MSA/CMSAs were determined by 1980 census data.

Locations of Covered EPAct Fleets*

VEHICLE TECHNOLOGIES PROGRAM

continued >
How can fleets comply 

with Alternative 

Compliance? 

•	Increase alternative fuel use.

•	 Use biodiesel blends.

•	 Purchase hybrids and other advanced 

technology vehicles.

•	Increase fleet fuel efficiency.

•	 Reduce vehicle miles traveled. 

To learn more, consult the Alternative 

Compliance guidance document at 

www.eere.energy.gov/vehiclesandfuels/

epact/pdfs/alt_compliance_guide.pdf.

How do fleets 

participate in Alternative 

Compliance?

To be considered for Alternative 

Compliance, fleets must submit the 

following items to DOE each year by 

the specified deadlines. 

•	Intent to Apply for a Waiver.

Submitted online, the intent informs 

DOE of a fleet’s interest in participating in Alternative Compliance. The 

waiver is due March 31 before the 

model year for which an Alternative 

Compliance waiver is sought. A fleet 

that submits an intent may still optout of Alternative Compliance and 

return to Standard Compliance.

•	 Waiver Request. The waiver request 

is applicable to the entire fleet for 

the full model year and includes 

a required petroleum reduction 

amount based on the fleet’s current 

Alternative Compliance vehicle 

inventory and average-per-LDV fuel 

use and a detailed plan for achieving that reduction requirement. The 

request is due July 31 before the 

model year for which an Alternative 

Compliance waiver is sought.

•	 Annual Report. The annual report 

certifies the actual amount of petroleum fuel a fleet reduced during the 

Alternative Compliance model year. 

It is due December 31 following the 

waiver year.

How do Standard and Alternative Compliance compare?

Technology Standard Compliance (AFV Acquisition) Alternative Compliance

(Petroleum Reduction)

Hybrid electric vehicles (or other 

energy-efficient conventional 

fuel technologies)

No AFV credit 

Petroleum reduction from hybrids or other 

fuel-efficient conventional vehicle technologies 

counts toward petroleum reduction in model 

year efficiencies occur

Light-duty AFVs One credit per AFV Credit for alternative fuel use on gasoline gallon 

equivalent (GGE) basis

Medium- and heavy-duty AFVs Credit only after requirement is met

with LDV acquisitions Credit for alternative fuel use on a GGE basis

Method Standard Compliance 

(AFV Acquisition)

Alternative Compliance

(Petroleum Reduction)

Biodiesel blends

Credit for every 450 gallons 

of biodiesel in blends of B20 or higher; 

capped at 50% of annual requirements

Credit for biodiesel used in any blend percentage 

on a GGE basis if it exceeds the amount already 

prescribed by state and federal law; no cap on 

amount of biodiesel used to meet requirements

Vehicle miles traveled (VMT) 

reduction No credit Credit for petroleum reduction in the model year VMTs are reduced

Idle reduction No credit Credit toward petroleum reduction

Truck stop electrification No credit For covered fleet only; no credit for

third-party use

continued >

VEHICLE TECHNOLOGIES PROGRAM
Where can fleets find 

more information on 

Alternative Compliance?

DOE developed the following tools to 

help fleets understand the Alternative 

Compliance option.

•	 Alternative Compliance: Guidelines 

for Preparing and Submitting 

a Waiver Request and Other 

Documentation Requirements

www.eere.energy.gov/

vehiclesandfuels/epact/pdfs/

alt_compliance_guide.pdf 

•	 Alternative Compliance Tutorial

www.eere.energy.gov/

vehiclesandfuels/epact/state/

alt_tutorial.html 

•	 Alternative Compliance

Planning Tool

www.eere.energy.gov/

vehiclesandfuels/epact/state/

acp_tool/

Where can fleets find 

more information on 

Standard Compliance?

DOE’s Office of Energy Efficiency 

and Renewable Energy Vehicle 

Technologies Program Web site features 

complete information on the Standard 

Compliance requirements of the State 

and Alternative Fuel Provider Fleets. 

Visit www.eere.energy.gov/

vehiclesandfuels/epact/

state_alt_fleets.html.

What if I have specific 

questions about 

Alternative and Standard 

Compliance?

DOE has a Regulatory Information 

Line you may contact with questions 

on the compliance options. 

Call the line at 202-586-9171, or e-mail 

at regulatory.info@nrel.gov.

What Is EPAct?

The Energy Policy Act of 1992 

(EPAct) was passed by Congress to 

reduce the nation’s dependence on 

imported petroleum. Provisions of 

EPAct require certain fleets to 

purchase AFVs. DOE administers 

these requirements through 

its State & Fuel Provider Rule, Federal 

Fleet Requirements, and Alternative 

Fuel Designation Authority.

For more information, visit www.eere.

energy.gov/vehiclesandfuels/epact, or 

call the Regulatory Information Line 

at 202-586-9171.

State and alternative fuel provider fleets have two options to comply with EPAct fleet requirements: 

Standard Compliance or Alternative Compliance.

Front page photo: © GM Corp.

VEHICLE TECHNOLOGIES PROGRAM

EERE Information Center

1-877-EERE-INF (1-877-337-3463)

www.eere.energy.gov/informationcenter 

Printed with a renewable-source ink on paper containing at least 50% wastepaper, including 10% post consumer waste.

Prepared by the National Renewable Energy Laboratory (NREL)

NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

NREL is operated by the Alliance for Sustainable Energy, LLC

DOE/GO-102009-2954 • Revised December 2009