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Comment 236 for 2013 Investment Plan for Cap-and-Trade Auction Proceeds (2013investmentpln-ws) - 1st Workshop.


First Name: Lauren
Last Name: Michele
Email Address: lauren.michele@policyinmotion.com
Affiliation: TRANSPORTATION COALITION

Subject: TRANSPORTATION COALITION FOR LIVABLE COMMUNITIES' PROPOSAL FOR INVESTMENT PLAN
Comment:
*PLEASE SEE ATTACHED LETTER AND PROPOSAL FROM THE TRANSPORTATION
COALITION FOR LIVABLE COMMUNITIES*

The Transportation Coalition for Livable Communities includes the
California Transit Association, League of California Cities,
California State Association of Counties, Sacramento Metropolitan
Air Quality Management District, CALCOG, and major Metropolitan
Planning Organizations including SACOG, MTC, SCAG, SANDAG and San
Joaquin Valley Policy Council, as well as the Natural Resources
Defense Council, California Alliance for Jobs, and Transportation
California - in short, the agencies and institutions responsible
for operating, maintaining, and advancing a sustainable
transportation system in California.  

The Coalition has developed a proposal to invest cap and trade
revenue to address both the greenhouse gas reduction goals of AB 32
and critical transportation system needs identified in the
California Transportation Commission’s Statewide Transportation
Needs Assessment over the next ten years.  Our uniting principle is
that auction revenues derived from vehicle fuels should be used to
fund transportation system needs in a way that achieves AB 32
objectives and builds on the framework of SB 375 and other GHG
reduction strategies.

The proposal would allocate funds equitably to regional governments
to establish a competitive grant process for local entities, under
state criteria, to incentivize integrated strategies that combine
land use changes with infrastructure investments at the
neighborhood scale to achieve greatest long term greenhouse gas
emission (GHG) benefits.

California faces a significant shortage in funds to maintain our
existing transportation system, and lacks adequate funding to build
an active transportation network.  This proposal would provide
funding for livable community investments to meet the challenges of
increasing development in existing urban and developed areas to
meet the requirements of SB 375.  Further, it would fund
GHG-reducing investments at the local level that implement regional
Sustainable Communities Strategies within existing urbanized or
developed areas – while also helping local governments meet
critical sustainable transportation infrastructure and maintenance
needs.

This approach of integrating livable community infrastructure,
maintenance, and operations of the transportation system at the
neighborhood scale will maximize GHG reductions from the
transportation sector through combinations of strategies – rather
than single purpose investments.  This integrated approach achieves
the most cost-effective results and support a range of community
benefits – including public health, resource protection, affordable
housing, equity, air quality, and safe routes to schools and other
community services.   It also would serve as a leverage to
investments in rail modernization, interregional plans, and other
funding mechanisms to encourage more sustainable growth and
transportation infrastructure. 
   
Unique among most proposals for state funding programs, the
Transportation Coalition's proposal would stimulate local
innovation and flexibility to get the greatest GHG reductions and
best overall benefits for communities – while cost effectively
meeting the goals of AB 32.  

The proposal incentivizes combinations of transportation
investments, including transit service and operating costs, road
and bridge maintenance, retrofits for complete streets and urban
greening, and clean technology infrastructure – all integrated with
land use changes to achieve the maximum greenhouse gas emission
reductions from the transportation sector.

This proposal is consistent with AB 32, SB 375, and the provisions
of AB 1532 and SB 535 --- and most equitably and effectively meets
the transportation and greenhouse gas emission reduction goals of
the state and local communities.  We request that this proposal be
considered for inclusion in the Investment Plan.

Cap and trade revenue is public money resulting from the
administration of AB 32, the Global Warming Solutions Act.  It must
be spent to implement that law.  We believe the Transportation
Coalition's proposal provides the most public and local community
benefits while achieving the most cost effective implementation of
AB 32.  

For the first year Budget allocation we propose the state provide
funding through the regions for planning and project development
focused on this competitive and integrated approach to most
effectively reduce greenhouse gases, meet our local and regional
transportation needs, and revitalize our communities.  Over the
life of the program, we believe that allowance revenues related to
motor vehicle fuels should be dedicated to reducing emissions from
the transportation sector, with a major part of those funds
allocated to this sustainable community funding program.

We have commissioned research to identify how to get the best
results from such a program and have brought together the local
governments and regional agencies responsible for administering our
sustainable community programs to create a program concept that
will most equitably and effectively achieve the state's short term
and long term GHG reduction and sustainable community goals.  

We want to work with CARB and the Administration to craft an
effective strategy to achieve maximum GHG reductions and long term
co-benefits under AB 32 by investing a major portion of revenues
related to fuels in integrated transportation and land use
strategies consistent with the SB 375, the California Regional
Blueprint plans and other regional planning processes. We request
that the following concepts be considered for inclusion in the
Investment Plan:

1. Auction revenue from fuels should implement the AB 32 regulatory
program to reduce GHG emissions from transportation

2. Favor cost-effective and integrated transportation and land use
strategies

3. Project funding determinations should be done primarily at
regional level under statewide criteria for evaluating GHG impacts.
Criteria for project selection should be uniform statewide and
developed by the State of California. Regions shall administer
competitive funding processes and select projects based on these
criteria. 

4. Allow flexibility at the regional and local level to develop
most cost effective projects.
 
5. Assist local governments in meeting regional GHG reduction
goals

6. Create performance-based approach to maximize regional
flexibility with improved modeling and verification systems to
ensure effective results

7. Promote innovation, collaboration, economic development and
rural sustainability 

8. Support co-benefits: air quality, public health, resource
protection, equity, affordable housing, agriculture, and safety 
We hope you will give us the opportunity to work with you to refine
these concepts and take advantage of this opportunity to make AB 32
a key component of California’s transportation investment program.
 
Sincerely,


TRANSPORTATION COALITION FOR LIVABLE COMMUNITIES
• California Transit Association  
• Natural Resources Defense Council
• California State Association of Counties  
• League of California Cities 
• Self-Help Counties Coalition  
• California Association of Councils of Governments  
• Sacramento Area Council of Governments  
• Southern California Association of Governments  
• Metropolitan Transportation Commission  
• San Diego Association of Governments
• San Joaquin Valley Regional Policy Council  
• Transportation California 
• California Alliance for Jobs  
• Sacramento Metropolitan Air Quality Management District 

Attachment: www.arb.ca.gov/lists/com-attach/264-2013investmentpln-ws-VTYAZwNwAzJXDlUm.pdf

Original File Name: CARB SUBMISSION_Transportation Coalition for Livable Communities Cover Letter and Proposal_03_08_13.pdf

Date and Time Comment Was Submitted: 2013-03-08 15:04:09



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