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What is the Zero-Emission Forklift Infrastructure Site Electrification Delay Extension? 

The Zero-Emission Forklift Infrastructure Site Electrification Delay Extension is available to allow a Fleet Operator to remain in compliance with the Zero-Emission Forklift (ZEF) regulation if there is insufficient power at the site where ZEFs will be charged or fueled. Fleet Operators may request this extension if their utility provider determines it cannot provide the requested power to the site prior to the upcoming compliance date.

What criteria qualifies for the Infrastructure Site Electrification Delay Extension?

To qualify for the Infrastructure Site Electrification Delay Extension, the following criteria must be met:

1. The Fleet Operator has formally requested, pursuant to Sections 3007(b)(3)(B)1.a.i through 3007(b)(3)(B)1.a.iii, below, from the electric utility provider the electrical-service installation or upgrades necessary to charge, or to provide power to the infrastructure needed to fuel, anticipated ZEFs to be deployed to comply with the upcoming compliance date.
2. The electric utility provider has notified the Fleet Operator that it cannot provide the requested power prior to the upcoming compliance date.
3. The Fleet Operator has deployed the maximum number of ZEFs that can be supported by the electric utility provider.
4. If the Fleet Operator operates at multiple sites, the Fleet Operator has relocated Forklifts to the extent possible in order to maximize compliance across its sites.
5. The Fleet Operator has submitted the information in Section 3007(b)(3)(B)4.a prior to the upcoming compliance date.

Are there any additional requirements after being approved for an Infrastructure Site Electrification Delay Extension?

Yes. After approval, all Large Spark Ignition (LSI) Forklifts covered by the extension must be labeled with their California Air Resources Board (CARB) issued Equipment Identification Number (EIN) in accordance with Section 3010.

When can I apply for the Infrastructure Site Electrification Delay Extension?

Fleet Operators may request the Infrastructure Site Electrification Extension if their utility provider determines it cannot provide electricity prior to the upcoming compliance date. To be eligible for this extension Fleet Operators must apply before the compliance dates listed below:

1. 1. For the January 1, 2028, compliance date, the formal request to the electric utility provider shall have been submitted by January 1, 2027;
   2. For the January 1, 2029, compliance date through the January 1, 2036, compliance date, the formal request to the electric utility provider shall have been submitted at least two years prior to said compliance date; and
   3. For the January 1, 2038, compliance date, the formal request shall have been submitted by January 1, 2034.

How long will the Infrastructure Site Electrification Delay Extension last and what if I need to extend it longer?

An Infrastructure Site Electrification Delay Extension may be granted for a period of up to three years, based on the amount of time the utility determines it needs to supply the needed power to the site. This extension can be renewed for a period of up to two years if the utility provider still cannot deliver the needed power. Each subsequent renewal, if granted, will be for a period of one year. The extension can continue to be renewed until the electrical utility provider delivers the needed power to the site, or up to a maximum extension term of ten years, whichever occurs first.

Can I replace my LSI Forklift covered by an Infrastructure Site Electrification Delay Extension?

Yes. Per Section 3007(b)(5), subject to the following conditions, a Fleet Operator may acquire a 2026 Model Year (MY) or newer LSI Forklift to replace an LSI Forklift covered by an Infrastructure Site Electrification Extension that has been removed from the fleet.

1. The LSI Forklift being replaced must be covered under a valid Electrification Delay Extension at the time of replacement.
2. The LSI Forklift being replaced must be removed from the fleet within 30 calendar days of the delivery of the replacements LSI Forklift.
3. Prior to taking delivery of the replacement LSI Forklift, the Fleet Operator shall provide the following to the Executive Officer (EO):

1. EIN of Forklift covered by Infrastructure Site Electrification Delay Extension
2. The purchase or lease agreement identifying the make and model of the replacement LSI Forklift

4. The Fleet Operator shall provide the following to the EO within 30 calendar days of delivery:

1. For replacement LSI Forklift, Forklift info specified in Section 3009(b)(2), as applicable
2. For the LSI Forklift being replaced, documentation that Forklift has been removed from service, such as sales contract or certificate of destruction

5. Any LSI Forklift acquired pursuant to an Infrastructure Site Electrification Delay Extension shall be Phased Out of the fleet by the date said extension expires or otherwise becomes invalid.

How do I apply for a Zero-Emission Forklift Infrastructure Site Electrification Delay Extension? 

Make sure the fleet information reported in DOORS is up to date. Extension requests may be submitted to CARB by email to zeforklifts@arb.ca.gov (mailto:zeforklifts@arb.ca.gov). The following information is required for fleets applying for the Infrastructure Site Electrification Delay Extension:

5. 1. Entity information specified in Section 3009(b)(1);
   2. For each LSI Forklift required to be phased out pursuant to Section 3006 during the term of the extension:
      1. Forklift information specified in Section 3009(b)(2) or EIN, as applicable; and
      2. Primary operating location address;
   3. A copy of the application submitted to the electric utility provider requesting site electrification that is consistent with the number of ZEFs the Fleet Operator shall be required to deploy each calendar year to meet their compliance requirements during the requested extension period;
   4. Documentation and correspondence received from the electrical utility provider:
      1.  The electrical utility provider’s response to the application requesting site electrification stating that the project will not be complete until after the upcoming compliance date;
      2. Documentation indicating the reason for the delay;
      3. An estimate provided by the electric utility provider of the available electrical capacity in kilowatts the electric utility provider is able to supply to the site within one year of the extension request, and for each year of the requested extension; and
      4. Estimated project completion date.
   5. Load profiles depicting the location’s typical electricity usage on an hourly basis from the electrical utility provider covering the previous 12-month period;
   6. Information about the ZEF charging or fueling infrastructure equipment that can be installed consistent with the electric utility provider’s capacity estimate for each year of the requested extension and the associated number of ZEFs that can be supported by such equipment:
      1. The number, type, and rated power capacity for chargers in kilowatts; or
      2. For hydrogen stations, dispensing capacity in kilograms per day and the electrical demand in kilowatts;
6. If the Fleet Operator has multiple sites where Forklifts are operated, an infrastructure capacity evaluation for each site from the electric utility provider, a third-party licensed professional electrical engineer, or other qualified person, with the information required in Sections 3007(b)(3)(B)4.a.iv and 3007(b)(3)(B)4.a.vi; and
7. The executed utility contract, or in lieu of the executed utility contract, the Fleet Operator’s initial contract or application requesting site electrification from the utility and a signed attestation from the electric utility provider stating they will proceed with the project.

After reviewing the information, CARB staff will update the compliance status in DOORS to reflect the Infrastructure Construction Delay Extension.

A draft template application can be found below. Use of the template is encouraged and may help submit a complete application. When filling out the application please refer to the regulation language for all requirements.

ZEF Infrastructure Site Electrification Delay Extension Request Template (https://ww2.arb.ca.gov/sites/default/files/2026-01/TEMPLATE%20ZEF%20Infrastructure%20Site%20Electrification%20Delay.docx)

This document is provided to assist regulated entities in complying with the ZEF regulation. In the event any discrepancy exists between this document and the ZEF regulation, the regulatory text of the ZEF regulation applies.