Comment Log Display

November 12, 2015

Mary Nichols, Chair 
California Air Resources Board 
1001 I Street 
Sacramento, CA 95814 

Re: Comments on Cap-and-Trade Auction Proceeds Second Investment
Plan draft

Dear Chair Nichols and Air Resources Board Members:

We submit the following comments relating to the second Three-Year
Investment Plan which will guide Greenhouse Gas Reduction Fund
investment strategies from FY2016/17 through FY2018/19. We
appreciate the significant efforts which ARB, the Department of
Finance and member organizations of the Climate Action Team have
put into creating such a comprehensive and thoughtful document and
hope that our suggestions may further contribute to the plan’s
ability to meet the goals set forth in AB 32. 

It is the responsibility of GGRF investment strategies  to not only
advance effective GHG-mitigation measures, but to also produce the
greatest possible range of co-benefits and ensure the protection of
California’s most vulnerable populations from any unintended harms
of funded development. Effectively prioritizing funding for
projects most in the interests of DACs has been problematic. While
individual program guidelines continue to include more language
supporting robust co-benefits, authentic community engagement and
proactive anti-displacement strategies, SB 535 funding has so far
been allocated for investments that fail to emphasize equitable
investments to the extent that community advocates hope to see.1

If this trend continues, billions of dollars may be invested in
DACs that ultimately may not be in the best interests of low-income
residents and local businesses. Investments must emphasize
carbon-reduction strategies that address critical issues of
economic resilience, non-GHG pollutants and public health. We are
of the opinion that the integrated projects approach first proposed
by the California Senate Budget Committee and subsequently outlined
in the Cap-and-Trade Auction Proceeds Second Investment Plan draft
has great potential to promote more comprehensive strategies with
the power to transform DACs and ensure that the primary
beneficiaries of all GGRF investments are the most vulnerable
members of our society.

An integrated projects approach could address three issues that
have greatly contributed to suboptimal DAC investments. First,
there is a predominantly “siloed” approach to California Climate
Investments that could be remedied by more flexible investment
strategies. Programs by-and-large are focused either on energy
efficiency, urban forestry, rail operations, waste diversion,
freight infrastructure or other single issue objectives. The
solutions needed to address the historic harms in environmental
justice communities are unlikely to be found using such a
fragmented approach. 

The second issue impacting effective investments is the lack of
accessibility of programs to local community-based organizations.
The Strategic Growth Council’s Affordable Housing and Sustainable
Communities program and CAL FIRE’s Urban and Community Forestry
grants are the only two programs with widespread applicability in
which nonprofit organizations may be primary applicants. However,
the capital requirements of affordable housing development are
beyond the capacity of most local nonprofits and the urban forestry
program, which is the most oversubscribed grant due to its
accessibility, is currently suspended pending the reconvening of
the State legislature which may award the forestry program to
another agency entirely. 

Further confounding the meaningful participation of community-based
organizations is the third issue of transparency. Funding for high
speed rail, low carbon freight and the transit operations and rail
capital programs is only available to public agencies, many of
which operate with little inclusion of public opinion. Ensuring
community members and local organizations are informed and engaged
in determining these agencies priorities should be a primary
concern of the GGRF.

For these reasons, we strongly suggest that an integrated
investment strategy is not only implemented, but that it is
structured in such a way that local organizations may directly
apply in a streamlined manner that will not strain the resources of
many groups. While as the draft states, “local governments with
jurisdictions in these disadvantaged communities may be well
positioned to identify projects that reduce GHG emissions to meet
local needs and support community-wide transformation,” it is often
those in the nonprofit sector who are in the best position to
convene and develop the most appropriate investment strategies in
DACs. 

California is home to a strong and diverse network of community and
environmental justice advocacy groups which also includes many
statewide and regional alliances, such as the California
Environmental Justice Alliance, Asian-Pacific Environmental
Network, Central California Environmental Justice Network, Bay Area
Environmental Health Collaborative, and many others. To be most
successful addressing the needs of DACs, California Climate
Investments should leverage the exceptional skills and local
knowledge across this network by ensuring that these organizations
and broader alliances are also able to directly apply for
integrated projects. 

There are a multitude of shovel-ready projects that have innovative
cross-cutting strategies to address GHG-reduction and many
co-benefits. Additionally, these projects have been designed in
collaboration with local residents and businesses possessing the
necessary knowledge of what their communities need most.
Participatory processes employed include design charrettes,
groundtruthing, community self-assessments and leadership
development.2

There are also broader neighborhood scale sustainability plans
proposed across the state which focus on the reduction of existing
impacts and the prevention of the toxic exposure faced by
California’s most vulnerable communities. Many of these plans not
only address carbon-reduction strategies systemically, but also
revitalize local economic opportunities, provide incentives for the
adoption of greener business practices by industrial operations and
reinvest in infrastructure that supports the local community.3

We thank you for the opportunity to comment and would look forward
to a more in-depth discussion with CARB and other agency staff
regarding these ideas.

Sincerely,


Alfred Carrillo, Pastor
Apostolic Faith Center

Dean S. Toji, Co-Chair
Asian Pacific Planning and Policy Council (A3PCON) Environmental
Justice Committee

Amy Vanderwarker, Co-Director
California Environmental Justice Alliance

Drew Wood, Executive Director
California Kids IAQ

Jesse N. Marquez, Executive Director
Coalition for A Safe Environment

Bahram Fazeli, Director of Research & Policy
Communities for a Better Environment

Ricardo Pulido, Executive Director
Community Dreams

Gisele Fong, PhD, Executive Director
EndOil / Communities for Clean Ports

Stella Ursua, President
Green Education Inc.

Ben Russak, Policy Analyst
Liberty Hill Foundation

Veronica Padilla-Campos, Executive Director
Pacoima Beautiful

Cynthia Strathmann, Executive Director
Strategic Actions for a Just Economy (SAJE)

Laura Muraida, Research Director
Strategic Concepts in Organizing and Policy Education (SCOPE-LA)

Mary Creasman, Director of Government Affairs
Trust for Public Land

Sandra McNeill, Executive Director
T.R.U.S.T. South LA


1  Advantaging Communities: Co-Benefits and Community Engagement in
the Greenhouse Gas Reduction Fund, a report co-sponsored by the
Liberty Hill Foundation, the UCLA Institute on Research for Labor
and Employment and the UCLA Labor Center, provides a detailed
community perspective of how the GGRF may better address the needs
of DACs. Available online at
http://www.libertyhill.org/news/reports/advantaging-communities-co-benefits-and-community-engagement-greenhouse-gas-reduction


2 Two examples of such projects would be Pacoima Beautiful’s
Pacoima Wash Vision Plan, which focuses on active transportation,
urban greening and the capture and treatment of stormwater; and
East Yard Communities for Environmental Justice’s  I-710 Freight
Corridor Project, which incorporates the same elements as the
Pacoima Wash plan along with expanded public transit and a
zero-emissions freight corridor. More information on these programs
may be found at
http://www.pacoimabeautiful.org/what-we-do/community-planning and
http://eycej.org/campaigns/i-710/

3 The Green Zone Initiative, led by the California Environmental
Justice Alliance (CEJA), brings together several urban and rural
pilot programs across California. Their report, Green Zones Across
California: Transforming Toxic Hotspots into Healthy Hoods, is
available at http://caleja.org/what-we-do/greenzones/