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Comment 34 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Keith
Last Name: McAleer
Email Address: keith@treedavis.org
Affiliation: Tree Davis, Executive Director
Subject: CalEPA and CARB Guidance on Cap-and-Trade Implementation and SB 535
Comment:
Dear Dr. Alexeeff and Ms. Livingston, I writing to you on behalf of Tree Davis, a small non-profit organization based in Davis, California. We are very excited about the upcoming opportunity for urban forestry made possible by cap-and-trade auctions. We look forward to seeing this significant investment come to fruition in California communities. We also look forward to better air and water quality, energy savings, reduced pollution, and ultimately happier, healthier Californians! Thank you for all of your work to make this happen. While Davis is not a disadvantaged community, we strongly support the effort to focus 55% to 70% of cap and trade funds for urban forestry into communities defined as disadvantaged through methods such as CalEnviroScreen. The CalEnviroScreen 2.0 tool is a very thorough method of analyzing which communities are being confronted with both environmental and poverty challenges (which unfortunately tend to go hand in hand). While the CalEnviroScreen tool and other methods of determining what communities are disadvantaged are very impressive, we do not believe that it is possible for any of them to be completely valid. For this reason, we believe there should be some flexibility concerning what percentage of cap-and-trade funds go to communities defined as disadvantaged. Recently, we heard that 100% of the funds would be directed to communities defined as disadvantaged and that disadvantaged may be defined as the top 15% or 20% of CalEnviroScreen scores. To be clear, we do believe that all of the funds should go to disadvantaged communities, but we think there is no perfect method of determining which communities are disadvantaged, so there should be some flexibility when it comes to CalEnviroScreen scores. This is why we support the lower threshold of 55% to 70% of the funds being directed to communities that have the highest 20% of CalEnviroScreen scores (or whichever method ends up being the one which defines disadvantaged). For example, we want to help Yolo County Housing plant trees on ten of their sites around Yolo County. These sites are not all in one place, but scattered within different census tracts. The CalEnviroScreen scores for these sites range from 40%-70%, but we believe this is misleading. The average household income for residents at these sites is around $20,000 and there are a significant number of elderly and disabled people. While the communities that surround them are not in the top 20% of scores, they are still moderate to very high. It was great that the 2.0 CalEnviroScreen tool focused on census tracts to analyze smaller units of analysis, but there are also large disparities even within census tracts. So, we propose a strategy where 55%-70% of monies are directed to the top 15 or 20% of CalEnviroScreen scores, with the rest being more flexible to give urban foresters an opportunity to help residents who may have been missed such as those who live in Yolo County Housing. Thank you! Sincerely, Keith McAleer Executive Director Tree Davis keith@treedavis.org (530)758-7337
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Date and Time Comment Was Submitted: 2014-09-12 16:00:17
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