Comment Log Display

Thank you for the opportunity to comment on the recent
Environmental Justice Advisory Committee community meetings.  

The Climate Change Policy Coalition [CCPC -- formerly AB 32
Implementation Group] is a diverse group representing California’s
large and small employers, cap-and-trade regulated entities,
taxpayer groups, agriculture interests and building and planning
experts.  We advocate for policies to reach AB 32 greenhouse gas
[GHG] emission reduction goals in a cost-effective and
technologically feasible manner to protect jobs and the economy.

We have been participating in the AB 32 implementation process
since its inception. As part of that participation, we have
attended most of the Environmental Justice Advisory Committee
[EJAC] Community Workshops throughout the state during July and
August. We want to thank ARB for holding these meetings - we
resolutely support the idea of gathering as much information as
possible from communities around the state. Our goal in attending
these meetings was to learn more from the community about what they
consider to be the most pressing issues. 

We believe ARB staff worked diligently to help provide a structure
for community input to be provided. However, we have deep concerns
about the overall integrity of this information gathering process.
More specifically, we’re concerned that the end result will not
truly represent the communities but instead will reflect a
predetermined narrative and agenda that the EJAC was endeavoring to
justify.  

We believe it’s important for us to share with you our overarching
concern regarding the community meeting process. Multiple times we
witnessed scenarios where a member of the public would offer a
comment, and the meeting facilitator would reshape that comment to
fit a predetermined EJAC recommendation. Reshaping community
feedback to validate a narrative is not what this information
gathering process should be about. Rather, it should be geared
toward really understanding what communities want and need.  

One of the goals of successful AB 32 implementation should be
assuring local California communities that our climate change
policies are and will continue to reduce GHG emissions while
maintaining local jobs, keeping energy prices low, and providing
affordable food and housing.  

This process has unfortunately come across as a contentious event
where there is an ‘us versus them’ mentality.  It doesn’t have to
be that way.  The truth of the matter is that a number of the
‘programs and requests’ of the EJAC to ‘ benefit’ EJAC
recommendations would be funded by cap-and-trade funds, yet
cap-and-trade and its necessary program design mechanisms -- such
as off-sets and allowances -- are at the heart of EJAC’s
recommendations to eliminate in its 2030 Scoping Plan
recommendations. Invariably, state consumers will pay the costs of
increased regulation.  Consumers from economically disadvantaged
communities are affected disproportionately by these assessments.

A state with lofty environmental co-benefit goals but without jobs,
higher energy costs, and increasing food costs will be a state that
is doing a disservice to all residents…and especially those in
disadvantaged communities. We should all do a better job to work
together rather than against each other. 

Thank you.