Comment Log Display

Cap-and-Trade Auction Proceeds September 4 Revised Funding
Guidelines for Agencies that Administer California Climate
Investments

The Trust for Public Land (TPL) would like to thank you for
creating the opportunity for public comment on the revised funding
guidelines for agencies that administer California climate
investments. We would like to provide brief comments on this
document. Our mission is to create a healthy and climate-smart
California with access to nature for all. 

Overall we commend the ARB on compiling such comprehensive and
detailed guidance for agencies that administer GGRF programs. We
support the ARB in creating transparent program development and
reporting requirements, and in holding public agency partners
accountable to the ARB and to the public. 

Greenhouse Gas Quantification
We strongly support your revisions to ‘quantification methods’
(p.1-16-1-19). We agree that quantification methods are evolving
and dynamic. We are pleased to note your preparation of a ‘draft
quantification work plan’ and that you are involving the public
input for refinements. We also support the use of external
contractors to leverage academic and external expertise and that
they will be standardizing templates and providing project specific
GHG quantification tools and calculators. 
For example, we recommend that agencies be required by ARB to
provide technical assistance to applicants on GHG quantification; a
higher bar should be set for required technical assistance beyond
emailing with ARB (Vol. 1 p. 18). We recommend that technical
assistance be offered through person-to-person contact as well. We
feel that many applicants may have cultural or language barriers
that would be difficult to address through email. This will also
support the ARB’s guiding principle of transparency in GHG
quantification (p. 25).
We also support ARB’s proposed creation of co-benefit GHG
quantification methods to promote the inclusion of multi-benefit
projects that meet statewide climate, sustainable development, and
resource protection priorities. Moreover, quantification of
co-benefits should be included in project scoring for all programs.
While we very much appreciate that ARB staff is aware of the
importance of encouraging projects with multi-benefits, evaluating
co-benefits at a qualitative level (p1-19) leaves too much for
‘interpretation’ and will ultimately not incent a multi-benefit
approach as much as a ‘quantitative approach’ would. We very much
appreciate that ARB notes this in the Guidelines, but providing
scoring and calculation for critical co-benefits like human health,
environmental and recreation will result in bigger bang for the
buck. 
Support for Disadvantaged Communities 
We applaud that ARB encourage granting agencies to incentivize
applicants to directly engage members of the community within a
potential project area in project selection, design, and
prioritization, to ensure projects in disadvantaged communities are
designed in collaboration with the communities they will serve. (p.
2-11 V.B. 2) We encourage requiring agencies institute
anti-displacement policies (p. 1-35) To that end, we recommend the
addition of a bullet to Volume 2, p.15 (Recommendations for
Administering Agencies to Maximize Funding to Benefit Disadvantaged
Communities), requiring grant applicants with projects located
within or benefiting a DAC to engage that DAC in project design and
implementation. We strongly agree that the bullets in 2-2 p. 2-15
‘Examples of Maximizing Benefits’ but to have them be
recommendations and not requirements is a missed opportunity to
award applications that address community needs and are required to
provide benefits and that outreach to community members happens.
We still ask you remove additional barriers for DAC in applying to
GGRF programs, we request that ARB require from agencies a minimum
of 60 days between the notice of funding and proposal deadline. We
also suggest that ARB include in the guidelines a recommendation
that matching funds should be waived for projects located within
DAC. For example there were 2-week turn-arounds in some application
processes.
We would like ARB to ensure distribution of GGRF funds to a diverse
group of nonprofits, agencies, municipalities and small business
can be eligible applicants.
We recommend that ARB require agencies to create set-asides within
GGRF programs for planning and the creation of decision-making
tools that will ultimately lead to projects that reduce GHGs. This
will greatly assist communities to assess and prioritize needs, as
well as develop innovative strategies for future GHG reduction and
participation in GGRF programs.
Please contact me if you would like to discuss any of the above in
greater detail. I can be reached at (916) 557-1673
Sincerely,

Rico Mastrodonato
Senior Manager Government Affairs
The Trust for Public Land