Comment Log Display

Attached and pasted below are Valley Clean Air Now's comments on
the Cap-and-Trade Auction Proceeds Second Investment Plan

Tom Knox
tom.knox@valleycan.org
916-715-6310


Valley Clean Air Now Comments on
Cap-and-Trade Auction Proceeds Second Investment Plan

Thank you for the opportunity to comment on the Draft Second
Investment Plan. We are heartened to see the Air Resources Board’s
commitment to creating meaningful change in disadvantaged
communities through reinvestment of Cap and Trade funds and offer
the following comments and suggestions:

Support for Cross Cutting Approaches. Section VI, Current Strategy
Gaps and Draft Investment Concepts is an excellent approach to
continue to evolve the planning process in order to achieve
effective carbon reduction investments and economic returns.

Specifically, the idea of using “cross-cutting approaches” to
streamline program delivery can create momentum toward maximum
environmental, economic, and public health benefits in
disadvantaged communities.  By preferentially funding projects with
achieve multiple benefits, a suggestion that has been made by the
independent Legislative Analyst’s Office as well as by many
stakeholders, the state can make the most use of the funds it has
been tasked with reinvesting. In addition, we believe that it is
possible, and highly advantageous, to stack multiple GGRF-funded
programs within disadvantaged community households, creating
transformative change in these communities. For instance, Valley
Clean Air Now coordinates with Fresno EOC to make solar
installations available for low-income residents who qualify for
incentives for a battery electric vehicle.

Enable Program Coordination Through Unified Applicant Management &
Program Analytics.  Attempting to align programs at the agency
level may be difficult due to relatively small differences in
quantification methodologies, approach, and guideline requirements,
which is amplified by the number and breadth of agencies involved. 
As a potential solution we recommend including a third section
under Section VI. A. Potential Cross Cutting Approaches for Program
Design and Structure.  Based on our experience with operating EFMP
Plus-Up in the San Joaquin Valley, we believe there is an
opportunity to coordinate at the program level using a universal
customer application and reporting system as the basis for
cross-program coordination that can streamline the intake and
eligibility verification process and ensure that consistent
reporting metrics are used.  This avoids the need to alter existing
statutes and program guidelines and allows for coordination at the
grassroots level where it is most needed.  Cross-program
coordination can include most aspects of program design:
•	Outreach
•	Education and activation
•	Program delivery
•	Accounting
•	Reporting

The key element of this approach is that is would allow agencies to
stack GGRF programs for a single customer or community, creating
ease of access and utilization for the general public. The
universal application and reporting system can be to developed as a
common application usable by most, if not all, GGRF programs.  This
common application could collect basic information broad enough to
cover all programs, with modules specific to the needs of each
issue area based on a constituent’s interest or qualifications. 
This way the same application could work for all program types,
with each program able to use the core application plus the modules
that meet their specific needs.

It would be a relatively straightforward process to assess each
GGRF program for opportunities to coordinate with other programs,
and map these potential interconnections.  This coordination can
cross between similar program types, such as various clean
transportation and transit programs within CARB’s Clean
Transportation Funding stream which share commonalities, or between
agencies where alignment can be encouraged across housing,
transportation, clean energy, energy efficiency, natural resources
and waste diversion programs.  As new programs are developed,
agencies can offer new opportunities for program stacking and
continue to build out the universal application.

Deep Outreach in Disadvantaged Communities and Rural Areas. A
universal application and reporting system approach could also help
to alleviate the challenges with outreach in disadvantaged
communities and rural areas.  A common application system, designed
to be inclusive of the needs of disadvantaged residents, will lower
barriers to participation and make GGRF programs appear more
attractive and understandable to these residents.  Based on our
first-hand experience establishing a successful program for rural
and disadvantaged communities in the San Joaquin Valley, outreach
will not be effective in these communities unless perceived
barriers are eliminated and the application process is made as
simple as possible. Valley CAN has developed a universal screening
mechanism, similar to the universal application, which allows our
organization to guide participants through the application process
and reduce the complexity which acts as a barrier to
participation.

Given the San Joaquin Valley’s leadership and experience in
establishing integrated programs focused on disadvantaged and rural
communities, the Valley could host a pilot to test this approach
and report back to the Air Resources Board on successes and further
barriers which may need to be addressed.  Program administrators in
the Valley have already conducted early meetings and forged
agreements to begin working together on participant outreach,
screening, and reporting which would allow this pilot to begin as
early as January 2016.

Thank you for considering these comments.  Please contact Tom Knox
at tom.knox@valleycan.org or (916) 273-8886 if you need any
additional information.