BACK
Development of Rates and Infrastructure for Vehicle Electrification ("DRIVE")
R. 18-12-006
November 8, 2022

CCA Parties Submit Comments & Reply Comments on Transportation Electrification PD

In opening comments, the CCA Parties supported the PD's focus on the medium- and heavy-duty sector ("MDHD") and multi-unit dwellings ("MUD"), its emphasis on disadvantaged communities ("DACs"), its prohibition of utility-ownership behind-the-meter ("BTM") infrastructure, and the Locally Invested Transportation Electrification ("LITE") pilot program. The CCA Parties expressed concern that the PD does not permit CCAs to directly administer a ratepayer-funded, locally tailored TE program, and offered comments to recommend certain targeted improvements to the structure of the LITE program. In reply comments, the CCA Parties replied to SDG&E's comments to clarify the factual premise that LITE pilots would serve both bundled and unbundled customers.

LITE Program - Joint CCAs strongly support the concept of the concept of the LITE program, but have the following concerns:

  • A Request for Proposals ("RFP") process is not appropriate - the Commission should give CCAs the opportunity to implement transportation electrification ("TE") programs by directly administering ratepayer funds
  • The LITE pilot program requires additional funding - the Commission should increase the budget from $25 million to $50 million, adopt a $10 million cap for regional LITE pilot proposals, and reduce the administrative costs cap from 8% to 2% of the total budget
  • Pilot implementation and evaluation timeline - the Commission should establish a three-year implementation period for LITE pilot program (pilots to begin in 2025 and ending 2028), including a six-month evaluation period
  • The Commission should offer clarification regarding shortlist process and subcontract

In reply comments, the Joint CCAs clarified that the LITE pilot program will be available to both bundled and unbundled customers.

Update Links
Opening CommentsReply Comments
SEE PROCEEDING
RELATED UPDATES

Client Resources

Land Use

Regulatory

Litigation

About

845 15th Street, Suite 103
San Diego, CA 92101
858-224-3068