October 8, 2021

Munger, Tolles & Olson supports Southern California Edison in forming the Clean Fuel Reward Program

Munger, Tolles & Olson represented long-term client Southern California Edison (SCE) in taking a lead role in forming and administering the California Clean Fuel Reward (CCFR) Program. 
This statewide point-of-sale program was created to help achieve California’s greenhouse gas reduction targets and accelerate electric vehicle adoption by offering an incentive on all new EV purchases or leases. 
Initiated and led by the state’s electric utilities in partnership with the California Air Resources Board, the program offers an instant price reduction of up to $1,500 on any eligible new electric vehicle. The CCFR can be combined with existing post-sale incentives to potentially help customers save over $10,000 on their electric vehicle purchases. The program is part of California’s phase out of gasoline-powered cars. In 2020, an executive order directed California to require that 100 percent of in-state sales of new passenger cars and trucks are zero-emission by 2035. 

Munger Tolles advised SCE throughout the creation of the program. After assisting with an advice letter to the California Public Utilities Commission requesting authorization for our client to act as the interim CCFR administrator for 3 years and to work with other utilities to establish the Governance Agreement defining the rules of operation for the program, SCE asked us to draft the Governance Agreement and assist it in negotiating its terms with a group of over 20 utilities from across the state.  

The MTO team included Judith Kitano, David Goldman, and Michael Greaney.