ZEV and Hybrid Priority Level Exemption Criteria
Pursuant to the State Administrative Manual (SAM) section 4121.1, state agencies and departments (Agencies) are required to select Zero-Emission Vehicles (ZEVs) over Internal Combustion Engine (ICE) vehicles when acquiring fleet assets. Agencies seeking an exemption from the SAM section 4121.1 policy must submit a completed OFAM 161Z - ZEV and Hybrid First Purchasing Mandate Exemption Request form with all supporting data to the Office of Fleet and Asset Management (OFAM). All exemption requests must:
- Be submitted as part of the agency's Fleet Acquisition Plan.
- Clearly demonstrate why a higher-priority vehicle cannot meet operational needs.
- Align with the exemption criteria outlined below.
ZEV and Hybrid First Purchasing Mandate Exemption Criteria
1. RANGE LIMITATIONS
For Light-Duty (LD) Vehicles and Medium-/Heavy-Duty (MD/HD) Non-Specialized Vehicles
The asset is frequently used for trips lasting less than 24 hours that exceed the practical range of pure ZEVs on the state vehicle contract in that vehicle category.
Required Justification: A narrative justification detailing the specific use case of the asset. This justification must be supported by telematics reports or trip logs demonstrating that the current vehicle, or a vehicle performing similar functions, is used at least 72 times in a 12-month period, or 36 times in a 3-month period, where each trip exceeds the practical range of pure ZEVs on the state vehicle contract in that vehicle category.
For MD/HD Specialized Vehicles
The asset is modified or configured for a specialized function that prevents the use of a temporary vehicle and is used for trips lasting less than 24 hours that exceed the practical range of pure ZEVs on the state vehicle contract in that vehicle category.
Required Justification: A narrative justification detailing the specific use case of the asset, including the modification or configuration that prevents the use of a temporary vehicle to perform its function. This justification must be supported by telematics reports or trip logs demonstrating that the current vehicle, or a vehicle performing similar functions, is used at least once in a 12-month period for trips lasting less than 24 hours that exceed practical range of pure ZEVs on the state vehicle contract in that vehicle category.
2. CHARGING/FUELING AVAILABILITY
For LD Vehicles and MD/HD Non-Specialized Vehicles
The asset is frequently used for trips lasting more than 24 hours in locations with limited or unreliable fueling/charging stations.
Required Justification: A narrative justification detailing the specific use case of the asset. This justification must be supported by telematics reports or trip logs demonstrating that the current vehicle, or a vehicle performing similar functions, is used at least 72 times in a 12-month period, or 36 trips in a 3-month period for trips lasting more than 24 hours in areas with limited or unreliable access to fueling/charging stations.
For MD/HD Specialized Vehicles
The asset is modified or configured for a specialized function that prevents the use of a temporary vehicle and is used for trips lasting more than 24 hours in areas with limited or unreliable fueling/charging stations.
Required Justification: A narrative justification detailing the specific use case of the asset, including the modification or configuration that prevents the use of a temporary vehicle to perform its function. This justification must be supported by telematics reports or trip logs demonstrating that the current vehicle, or a vehicle performing similar functions, is used at least once in a 12-month period for trips lasting more than 24 hours in areas with limited or unreliable access to fueling/charging stations.
3. OPERATIONAL ABILITY
For LD Vehicles
The asset must have a cargo/passenger capacity that exceeds the capacity of pure ZEVs on the state vehicle contract in the vehicle category.
Required Justification: A narrative justification describing the cargo/passenger capacity necessary to meet operational needs. This justification must include quantitative details such as interior or trunk space requirements and the number of individuals being transported or a list of the items regularly carried, and a comparison of the cargo/passenger capacity between the requested vehicle and pure ZEVs available on the state vehicle contract in that vehicle category.
For MD/HD Vehicles
The asset has a certain use case or operational need that prevents the use of one of the pure ZEVs on the state vehicle contract. Examples of acceptable use cases or operational needs include:
- High towing capability needs
- Frequent operation in extreme weather environments
- Frequent operation in mountainous terrain
- Large cargo/passenger/payload capacity needs
- Power Take Off (PTO) capability needs
- Vehicle configurations/modifications that prevent the use of a pure ZEV
Required Justification: A narrative justification describing the asset’s specific use case, demonstrating why its operational needs cannot be met with pure ZEVs on the state vehicle contract in that vehicle category.
4. INABILITY TO INSTALL EV CHARGING INFRASTRUCTURE - FOR MD/HD VEHCILES ONLY
It has been determined that the installation of EV charging infrastructure is not feasible at the site where the vehicle(s) will be domiciled.
Required Justification: A DGS OS-1 form that indicates that the installation of EV charging infrastructure at the current domicile site for the requested vehicle is not feasible and a narrative justification along with relevant quantitative data that demonstrates no publicly available infrastructure exists in the area that could be accessed to support the vehicle requested for exemption.
5. COST-EFFECTIVENESS - FOR MD/HD VEHICLES ONLY - BEGINNING FY 2026-27
The acquisition of a pure ZEV is not cost-effective, as the Total Cost of Ownership (TCO) of pure ZEVs on the state vehicle contract in that vehicle category, after applying available HVIP incentives, is greater than the TCO of the requested non-ZEV asset.
Required Justification: A TCO comparison analysis that demonstrates the TCO of pure ZEVs on the state vehicle contract, after applying available HVIP incentives, exceeds the TCO of the requested vehicle. The TCO analysis must include:
- A breakdown of total acquisition cost (purchase price, taxes, and fees), operating cost (fuel, maintenance, and repairs), and depreciation and resale value at the time of disposal.
- All applicable HVIP Incentives.
- Agencies may use the AFLEET Online TCO calculator as a resource.
1. OPERATIONAL ABILITY
For LD Vehicles
The asset must have a cargo/passenger capacity that exceeds the capacity of PHEVs on the state vehicle contract in that vehicle category.
Required Justification: A narrative justification describing the cargo/passenger capacity necessary to meet operational needs. This justification must include quantitative details such as interior or trunk space requirements and the number of individuals being transported or a list of the items regularly carried, and a comparison of the cargo/passenger capacity between the requested vehicle and PHEVs available on the state vehicle contract in that vehicle category.
For MD/HD Vehicles
The asset has a certain use case or operational need that prevents the use of one of the pure ZEVs on the state vehicle contract. Examples of acceptable use cases or operational needs include:
- High towing capability needs
- Large cargo/passenger/payload capacity needs
- Power Take Off (PTO) capability needs
- Vehicle configurations/modifications that prevent the use of a pure ZEV
Required Justification: A narrative justification describing the asset’s specific use case, demonstrating why its operational needs cannot be met with pure ZEVs on the state vehicle contract in that vehicle category.
2. INABILITY TO INSTALL EV CHARGING INFRASTRUCTURE - MD/HD VEHICLES ONLY
It has been determined that the installation of EV charging infrastructure is not feasible at the site where the vehicle will be domiciled.
Required Justification: A DGS OS-1 form that indicates that the installation of EV charging infrastructure at the current domicile site for the requested vehicle is not feasible and a narrative justification along with relevant quantitative data that demonstrates no publicly available infrastructure exists in the area that could be accessed to support the vehicle requested for exemption.
1. ENVRIONMENTAL IMPACT - All Weight Class Vehicles
The asset requested has a higher U.S. Environmental Protection Agency (EPA) Fuel Economy and Greenhouse Gas Emissions score (1 through 10 scale, with 10 being the best) than the Hybrids on the state vehicle contract in that vehicle category.
Required Justification: A comparison of the EPA Energy and Environment Score between the requested ICE and Hybrids available on the state vehicle contract in that vehicle category.
References AND RESOURCES
- SAM section 4121.1 - ZEV and Hybrid First Purchasing Mandate
- Exemption Criteria by Weight Class
- AFLEET Online
- EPA Find and Compare Car
- HVIP Incentive Program for MD/HD ZEVs
- FAP Forms Packet Request: FAMSSupport@dgs.ca.gov
- Fleet Policy Questions: FleetPolicy@dgs.ca.gov
CONTACT
Department of General Services
Office of Fleet and Asset Management
Sacramento, California 95834
FleetPolicy@dgs.ca.gov