Comment Log Display

SCE supports the proposed amendments to the LCFS regulation with
the following modifications, which are discussed in detail in the
attachment: (1) combine the separate holdback project lists
proposed for equity and nonequity projects; (2) specify that
utilities have discretion to select the most appropriate projects
for their customers and require the large  investor-owned utilities
(IOUs) to fund at least three program options; (3) retain the 10%
administrative cost cap for Holdback programs because 5% is
insufficient; (4) align the administrative cost cap for the
statewide Clean Fuel Reward Program with other large utility
incentive programs; (5) update vehicle eligibility for the
Statewide Clean Fuel Reward Program to conform to CARB's goals; and
(6) reject the 1-mile requirement for capacity credits in favor of
greater flexibility.