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Comment 53 for Comments on the RTAC (sb375-rtac-ws) - 1st Workshop.


First Name: Keith
Last Name: Roberts
Email Address: keitheroberts@aol.com
Affiliation:

Subject: local government incentives/compensation
Comment:
1.	Is there a framework available of what a good Sustainable
Communities Strategy (SCS) would look like?

2.	Is there any information available about how an SCS will be
“graded”, who will “grade” the SCS, and how the “grading” will
translate into: (1) transportation funding incentive and (2) CEQA
streamlining?

3.	Local governments can help the State implement approximately
half of the 73 identified scoping plan measures.  See attached
document (Appendix B) under separate cover for a partial compendium
of over 300 projects and programs that local jurisdictions might
choose to undertake to meet their voluntary target.  RTAC is
addressing scoping plan item #47, yet this measure comprises ¼ to
1/3 of what a local jurisdiction might consider implementing in an
SCS to meet its voluntary target.  Will non-SB375 compliant
programs that are part of an SCS be rewarded under the
transportation incentives mechanism of SB375?  Playing devil’s
advocate, why would the following SB375 non-compliant programs be
implemented by a local government:
·	Why would a local government care to improve the energy
efficiency of new or existing building stock within its city
limits? 
·	Why would a local government care to try and achieve zero
waste?
·	Why would a local government care about distributed generation
or increasing the use of renewable power within its boundaries? 
·	Why would a local government care to improve awareness of its
businesses, citizens and staff?

4.	Can CARB identify the proposed incentive/compensation measures
that are being considered to help local governments achieve their
voluntary targets.  Measures that I’ve seen mentioned over the last
year or so are:
·	Transportation funding incentives and CEQA streamlining under
SB375
·	Proposed public goods charge (PGC) on water (scoping plan item
#32)
·	A year or so ago Build It Green had a proposal before the CPUC
to use electric/gas PGC’s to reward local governments for energy
efficient new construction and for residential/ commercial energy
conservation ordinances (RECO/CECO) development and implementation.
 I think the proposal died, but could be a good local jurisdiction
incentive
·	ARRA grants might be able to help start a program, but won’t
keep it operational over time… long-term incentive/compensation
structure is needed.
·	Something that might come out of cap-and-trade

5.	I’d like to recommend that CARB put together a working group on
local government incentives.  Local jurisdictions operate under
such thin margins that they need to be compensated for the work
that they do to assist in meeting their voluntary targets.  Other
reasons for having a local government incentives group might
include:
·	Regulation is good to identify a “floor” that a local government
needs to achieve (e.g. AB939’s 50% landfill diversion); but
incentives/compensation need to be provided for local jurisdictions
that want to reach for the “ceiling” of what is achievable (e.g.
zero waste). 
·	CARB should consider addressing local government sustainability
improvement in a holistic fashion; the above are measures that
address several aspects with piecemeal incentives, which are
admittedly the best short-term solution.  Appendix B does provide a
revenue-neutral concept for addressing the above in a more holistic
fashion (see rows 190 to 238 for 2 brainstorming options- one
related to distribution of sales tax, the other related to
distribution of property taxes).

6.	CARB should consider being part of the development process for
the ICLEI/USGBC Stars Community Index.  This is known as LEED for
Cities by some.  The co-development of indicators by CARB/ICLEI
might benefit both organizations.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-09-09 22:38:03



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