Widespread adoption of zero-emissions vehicles (ZEVs) could assist many regions in achieving robust greenhouse gas mitigation goals. Government mandates, market-based incentive programs, and innovative technologies have been building momentum, and the transportation sector seems to have reached a tipping point. To meet its ambitious targets, the United States needs a solid suite of electric vehicle (EV) charging and refueling infrastructure. So far, California is the leading state in the deployment of EVs, and has set aggressive climate goals. By 2025, the state hopes to have adequate infrastructure to support 1.5 million ZEVs, and provide 250,000 battery EV chargers.
EXPANDING CLEAN FUELS INFRASTRUCTURE
Clean transportation is developing nationwide, but is particularly present in California due to both the proliferation of EV charging infrastructure and the availability of EV purchase incentives. There is wide agreement that the availability of clean energy infrastructure is required to enable wide-scale EV adoption. To further catalyze the rapid expansion of EV charging stations in California, a ZEV infrastructure crediting provision was added to the state’s Low Carbon Fuel Standard (LCFS) in 2018 and updated in 2025 to further increase EV charger deployments.
While most credits generated under the LCFS are related to fuel dispensed, the infrastructure provisions enable entities to generate credits for available fueling capacity instead of actual fueling activity. The infrastructure provision covers both Hydrogen Refueling Infrastructure (HRI) and Direct Current (DC) Fast Charging Infrastructure (FCI), also known as Level 3 chargers.
Chargers are typically split into 3 categories based on their relative speed:
- Level 1 chargers use standard 120V AC power and can typically charge at ~1.4 – 1.8 kW
- Level 2 chargers use 240V AC power and can typically charge at up to 20 kW
- Level 3 chargers provide DC power directly to the vehicle and can range in capacity from 50 – 400+ kW
Fast charging provides the fastest available fill-up, but not every EV model is equipped for it. DC fast charging uses three different connector systems: CHAdeMO (largely being phased out), CCS Combo, and NACS (originally found on Teslas). When installing EV infrastructure, it is important for station owners to consider the type of charger they offer. In some cases, the amount of possible FCI credits may be limited if only one charger type is available at a site. Understanding what variables to consider in an installation project will help your organization maximize its cost savings.
WHAT ARE INFRASTRUCTURE CREDITS?
The infrastructure crediting provisions come from an attempt to solve a chicken-or-egg problem. While consumers want assurance that they will have access to charging stations in a variety of locations, infrastructure owners want to know demand will exist to drive utilization. The LCFS Charging Infrastructure crediting provisions ensure infrastructure owners are able to recoup their investments by providing a revenue stream for fueling stations based on the capacity made available, rather than the actual fuel dispensed.
Incentivizing the expansion of charging infrastructure is critical during this early stage of ZEV adoption. As fueling activity increases, the number of credits generated under the infrastructure provision decreases, until eventually all of the credit activity is derived from actual fueling. Each site has a fueling capacity limit — the maximum is 2,500 kW for stations serving vehicles Class 4 and below and 40MW for stations serving vehicles Class 5 and above.
Each charger at the FCI station must have a nameplate capacity of at least 50 kW. The FCI crediting rate is 10% (for private fast chargers) or 20% (for public) of the theoretical maximum amount of electricity the station could dispense. Credits from the FCI provision can be generated for up to 10 years from application approval, and the lifetime value from infrastructure credits is 150% of site CapEx.
ELIGIBILITY AND APPLICATION APPROVAL
There are limits to the number of facilities that can be approved by California Air Resources Board (CARB). As of August 15, 2025, 5,875 chargers have been approved for crediting under the FCI provisions at 969 sites across California. Applications for new stations can be accepted as long as the estimated potential FCI credits from all approved stations does not exceed 2.5% of LCFS deficits in the prior quarter. This potential is evaluated separately for charging stations designed to serve light- and medium-duty vehicles as opposed to those designed to serve heavy-duty vehicles.
In addition to the general program requirements, public (light- and medium-duty) stations must be publicly accessible 24 hours a day. An eligible station cannot have any gates or codes to access, and should not require any special training to be used, and the site must accept major credit and debit cards at the point of sale terminal. Shared heavy-duty sites must be open to at least two fleets and meet other location and grant requirements.
The application and documentation process can be complex and onerous. Fuel station owners must report fuel transactions on a quarterly basis to CARB, they must include cost and revenue data in their annual reports, and there are additional annual reporting requirements. With so many specific rules, infrastructure crediting can be difficult to navigate. Working with an advisor like 3Degrees can help alleviate the administrative burden of program participation while ensuring the highest possible return.
