TURN strongly supports state goals to accelerate Transportation Electrification (TE), including for the non-light-duty EV sector. Electrification of this sector can decrease emissions, particularly criteria pollutants and NOx which adversely impact disadvantaged areas of the state causing severe health issues for vulnerable communities. Further, non-light duty infrastructure programs have an even greater potential than light-duty programs to result in incremental EV adoption and related increased load, which, in addition to environmental benefits, can result in downward pressure on electric rates for all ratepayers. However, the latter point is only true if programs are carefully designed to be effective and targeted to where subsidies can provide the most impact for each investment. Ideally, investments would be selected that maximize emissions reductions for each ratepayer dollar, with particular emphasis on how to accelerate emissions reductions in disadvantaged communities (DACs). Unfortunately, this is not how PG&E and SCE’s proposals are structured.