California’s New FCI Rules: How DC Fast Chargers Earn 10 Years of Credits

Recent updates to the Low Carbon Fuel Standard (LCFS) have expanded how DC fast-charging equipment can earn credits. Instead of being paid only for the kilowatt-hours (kWh) actually dispensed, site owners can now lock in 10 years of “capacity” credits under the Fast-Charging Infrastructure (FCI) pathways.

Below is a practical breakdown of what changed, who qualifies, how the math works, and the pitfalls to avoid.

Two distinct pathways — two application deadlines

Applications are first-come, first-served. Once the potential credits from all approved FCI projects equal 2.5% of statewide LCFS deficits, CARB will stop accepting new submissions. Each company is also capped at 0.5% of statewide deficits.

Eligibility & power ceilings

• Location & date — Chargers must be in California and permitted on or after 1 Jan 2022.
  
• Networked charging — Every unit must report real-time availability.
  
• Site capacity caps
  
  • LMD-FCI: ≤ 2.5 MW per address
    
  • HD-FCI: ≤ 40 MW per address

• Max Site Deliverable Power: The maximum power the site can deliver at once. This value must be reported to meet FCI program requirements.
  
• Shared HD FCI Requirements: Shared heavy-duty sites must be within 5 miles of an Alternative Fuel Corridor, be on/adjacent to truck parking, or have won a competitive grant that scored location.
  
• HD-FCI Class 8 Accessibility: Proof that the site can accommodate Class 8 heavy-duty trucks (≥33,000 lbs GVWR) is required for the Heavy-Duty FCI pathway. This can be been demonstrated with satellite imagery, site measurements, or official permitting documents showing truck access.

How the new “capacity-credit” formula works

Each quarter, you compare:

1. Consumption Credits – The traditional LCFS credit for kWh actually sold.
   
2. Capacity Credits – A fixed allowance based on nameplate power × 24 hours × a site-type factor:
   

The factor is fixed in the rule for both LMD and HD sites.

Example — 350 kW public charger
Capacity baseline = 350 kW × 24 h × 20% = 1,680 kWh/day.
If the site dispenses only 800 kWh on a slow day, you still claim the higher 1,680 kWh equivalent.
Uptime (network-reported) scales the credit: higher availability means more credits; prolonged outages reduce them.

Financial guardrails

• Return-on-capital cap — Once cumulative FCI revenue exceeds 1.5× net capex (after grants), a site can earn only consumption credits, not capacity credits.
  
• 24-month operability clock — If the station is not online within two years of approval and the 2.5% system cap is already reached, approval is canceled.
  

Reporting & verification essentials

• Quarterly uploads of kWh dispensed and charger availability
  
• Annual cost-revenue report (capex, O&M, land rent, grants, retail electricity price)
  
• Third-party verification for all electricity reports starting with data year 2026
  

Key takeaways

The new FCI rules shift the model from “credits follow energy dispensed” to “credits finance hardware readiness.” By monetizing spare capacity for a full decade, CARB is effectively front-loading revenue so bigger, faster chargers can pencil out while utilization catches up.

Early movers — especially those who keep stations public and highly available — stand to capture maximum capacity credits while the door is still open.

Questions about modeling FCI revenue or assembling an application packet?
Our team has guided projects from concept through LCFS/FCI credit generation and verification.

Disclaimer: This blog is for informational purposes only and does not constitute legal or tax advice.