Comment Log Display

September 21, 2015

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

Re: Comments on Draft Funding Guidelines for Agencies that
Administer California Climate Investments

Dear Chair Nichols and Air Resources Board Members:

The Liberty Hill Foundation appreciates this opportunity to submit
the attached report for comment on the Draft Funding Guidelines for
Agencies that Administer California Climate Investments and the
subsequently released supplemental text. The report, Advantaging
Communities: Co-Benefits and Community Engagement in the Greenhouse
Gas Reduction Fund—co-sponsored by the UCLA Institute for Research
on Labor and Employment, the UCLA Labor Center, and Liberty Hill
Foundation—contains a set of policy recommendations informed by
collaborative engagement with grassroots environmental justice
organizations over the past year.

While co-benefits are ultimately subordinate to carbon reduction in
GGRF programs, they are not optional. California legislation
clearly mandates maximizing economic, environmental and public
health co-benefits in all climate investment strategies, with a
particular focus on directing those benefits to DACs. Advantaging
Communities provides policy recommendations to more effectively
prioritize these benefits in DACs to the maximum extent feasible
while maintaining a primary focus on GHG reduction. 

The recommendations focus on how to best guarantee GGRF investments
create significant and lasting benefits in DACs:

•	Maximize economic, environmental and public health benefits (in
addition to GHG reduction) through investments that further improve
the lives of low-income populations with an emphasis on the
generation of quality employment opportunities

•	Increase community resilience by incentivizing anti-displacement
methods and leveraging local inclusionary housing ordinances

•	Ensure authentic community engagement by prioritizing investments
made in collaboration with grassroots community-based organizations
(CBOs) or others involved in a participatory development process

This report is offered in full support of the SB 535 Coalition’s
four primary suggestions outlined in their comment letter,
submitted August 19, 2015: (1) require all SB 535 investments to
address high priority disadvantaged community needs as an
eligibility requirement (2) concretely require agencies to
prioritize the SB 535 investments that provide the most significant
benefits to DACs (3) ensure more benefits are targeted to the
neediest end-users, and (4) provide clear prohibitions on direct
displacement and strategies for avoiding economic displacement.

Recommendations include setting a baseline scoring criteria for
co-benefits, community engagement and anti-displacement measures
for competitive SB 535 funds; leveraging high-road labor ordinances
and inclusionary housing policies currently existing in local
jurisdictions; and to identify and incentivize community engagement
methods specifically applicable to GGRF programs.

While it is likely too late to consider many of the recommendations
contained in Advantaging Communities for inclusion in the Funding
Guidelines set to be finalized on September 24, 2015, hopefully the
submission of this report can begin a conversation about how to
proactively initiate important strategies to protect vulnerable
populations from the direct displacement of projects receiving SB
535 funding and build economic and social resiliency in DACs to
stabilize low-income households from increased costs of living
associated with the economic displacement.

Sincerely,

Ben Russak
Policy Analyst
Liberty Hill Foundation