Alternative Compliance

Under the Alternative Compliance method, covered state and alternative fuel provider fleets may obtain a waiver from the alternative fuel vehicle (AFV)-acquisition requirements of Standard Compliance by submitting and then implementing a plan to reduce petroleum consumption.

Alternative Compliance may be a good option for fleets that:

  • Have a significant number of medium- or heavy-duty vehicles capable of using biodiesel in excess of the 50% cap associated with Standard Compliance or capable of using other alternative fuels
  • Wish to combine hybrid electric vehicles and alternative fuel use
  • Are subject to state or local requirements or policies calling for petroleum reduction, or reductions in carbon footprint or greenhouse gas emissions.

Fleets opting into Alternative Compliance must provide a sufficient level of data and information to support their compliance claims, particularly information on fuel use. Fleets are required to submit the following items to the U.S. Department of Energy (DOE):

Submitted online, the intent to apply for a waiver informs DOE of a fleet's interest in participating in the Alternative Compliance option. The intent form is due March 31 before the model year for which an Alternative Compliance waiver is sought.

2026 Model Year Due Date

March 31, 2025

To be considered for Alternative Compliance, a fleet must submit a waiver application that is applicable to the entire fleet for the full model year and includes:

  • An Alternative Compliance vehicle inventory
  • The calculated total annual petroleum reduction requirement
  • A plan to reduce petroleum consumption by at least the calculated petroleum-reduction requirement.
  • Certification that all plan elements are in compliance with the Clean Air Act.

A complete waiver application must be submitted to and received by DOE by July 31 before the model year for which an Alternative Compliance waiver is sought. DOE requests that applicants submit the waiver application electronically, if possible, to the DOE regulatory manager.

DOE will review each fleet's waiver application and notify the fleet of its approval to proceed with the Alternative Compliance option in the upcoming model year.

2026 Model Year Due Date

July 31, 2025

Next Steps

Review Module 3: Maintaining Your Alternative Compliance Vehicle Inventory and Module 4: Assembling a Waiver Request, or download the interactive Alternative Compliance tutorial.

Find fuel conversion factors.

If you are ready to calculate your fleet's total annual petroleum reduction requirement and develop a plan to reduce petroleum consumption by at least the calculated petroleum-reduction requirement, you may download the Alternative Compliance Planning Spreadsheet. View a sample plan.

Download plan template

An annual report that certifies the actual amount of petroleum a fleet achieved during the Alternative Compliance model year is due December 31 following the Alternative Compliance waiver year.

The annual report should explain how the data demonstrating compliance were collected. DOE is authorized to request additional documentation to verify the claimed petroleum use reductions. Examples of documents that verify petroleum use reductions include:

  • Pumping or other records that show the quantity of alternative fuel/biodiesel blends actually used
  • Retail fuel purchase receipts or logs together with pumping or other records
  • Bulk fuel-use purchase/delivery records (for fleets with their own fueling sites) together with pumping or other records
  • Fuel-use logs maintained by vehicle operators.

The annual report must be sent to DOE on company letterhead and be signed by a senior official.

2024 Model Year Due Date

Dec. 31, 2024

Next Steps

Review Module 5: Completing an Annual Report or download the interactive Alternative Compliance tutorial.

Learn more about the types of information needed for the annual report in the Annual Reporting Guidance and view a sample report.

Download report template

The DOE Regulatory Information Line can help state and alternative fuel provider fleets understand Alternative Compliance requirements, or fleets can review the Alternative Compliance Guidance.