Joint CCAs Submit Opening Comments in DRIVE Proceeding

Comments on Staff's Proposed Funding Cycle, Structure, Design and Funding Priorities:

In order to meet the needs of underserved communities, funding cycle 1 ("FC1") should accommodate the local customization of incentives.

1. The design of the statewide program described in the Staff Proposal could disadvantage underserved communities and customers.
2. Existing statewide incentive programs have driven inequitable outcomes.
3. While higher rebates and an "investment minimum" for underserved communities are important program elements, those elements will not on their own ensure that disadvantaged and marginalized communities and customers benefit from the statewide program.
4. Program design should allow for the development of localized offerings tailored to address the needs of specific customer segments or use cases.

FC1 should allow flexibility over incentive allocation on a local basis to ensure that incentives reach target customer segments.

Local Marketing, Education and Outreach ("ME&O") administration will allow for more effective outreach customized to local needs and barriers.

Local technical assistance ("TA") administration will more effectively address the needs of target customer segments.

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Joint CCA's Proposed Modified FC1 Structure:

CCAs should be permitted to design and allocate equity-focused incentives on a local basis and to administer ME&O and TA to support those incentives.

The Joint CCAs' proposed modified FC1 structure draws from existing commission precedent for CCA incentive program design and implementation.

The Joint CCAs' proposed modified FC1 structure aligns with the Commission's environmental and social justice action plan.