Comment Log Display

Attached and pasted is Valley CAN's comments on LCTP

June 20, 2016


Mary D. Nichols
Chair, California Air Resources Board
1001 “I” Street
Sacramento, CA 95814

RE:	Low Carbon Transportation Fund Investments and Air Quality
Improvement Plan (AQIP), focusing on Light Duty Pilot Projects to
Benefit Disadvantaged Communities and Lower-Income Consumers

Dear Chair Nichols:

Thank you for your ongoing leadership with implementing carbon
reduction and air quality programs at CARB.  Your team has been
doing good work with facilitating the ongoing planning process to
encourage input and collaboration. 

Valley Clean Air Now (Valley CAN) greatly appreciates the
opportunities that CARB has created for transportation equity
projects in the San Joaquin Valley, and we want to take this
opportunity to offer some broad comments about program planning, as
well as specific comments on some of the details.

Overall, we encourage a focus on how to use existing GGRF-funded
programs such as the Enhanced Fleet Modernization Program Plus-Up
to identify and engage eligible households to create an expanding
sales pipeline in San Joaquin Valley disadvantaged communities. 
These customers will likely qualify for multiple environmental
programs and are likely very motivated by cost savings to enter and
complete programs.  Combining multiple GGRF programs at the
household and community level is a cost-effective way to both
deepen and broaden the impact of California Climate Investments
(CCI) investments by creating economies of scale.  To effectively
manage this process, an online customer relations system is needed
to manage qualification and data reporting.  To build and retain
community support, additional flexibility and consumer protections
are needed to help customers qualify for and succeed with these
programs.

CCI guidelines should be visible across all agencies
CCI programs are currently managed by 11 state agencies, each with
a separate set of guidelines that do not always precisely align.  
Encouraging program interconnections would be facilitated by
creating and updating a matrix that compares the basic program
qualification criteria across all CCI programs.  This matrix can be
organized by grouping programs by category (transportation,
housing, infrastructure, etc) and further by types of criteria
(income, household vs. business, etc).  This work product would be
very valuable in creating an inclusive yet rigorous
cross-qualification process for all disadvantaged community
households.


Effective strategies are needed to enable “cross-cutting”
“Cross-cutting” to create linkages between GGRF-funded programs to
focus benefits in disadvantaged community households is a goal that
has been cited repeatedly in Carbon Investment Program documents
including the recent Investment Plan as well as the proposed
Transformative Climate Communities program in the Governor’s
2016-17 budget proposal.  

Combining existing programs to focus benefits into low-income
households in the most severely disadvantaged communities should be
a faster path to quantifiable GHG reductions in these areas, as
programs could potentially need only additional flexibility and
some creativity to create points of connection for
cross-qualification.

Valley CAN has already been coordinating with the other GGRF-funded
program providers in the San Joaquin Valley to deliver multiple
programs to qualified households: 
•	EFMP Plus Up customers who purchase battery electric vehicles
(BEV) who also qualify for Department of Community Services and
Development’s low-income rooftop solar PV program managed by Fresno
Economic Opportunity Commission can receive a rooftop solar system
that includes the pre-wiring necessary for Electric Vehicle Service
Equipment.  
•	Another consumer-facing GGRF-funded project in the San Joaquin
Valley is the CalVans agricultural vanpool program.  We offer
CalVans riders the opportunity to qualify for EFMP Plus-Up, as
their vehicles are often pre-1996 high-emitting vehicles that are
top targets.

Cross-cutting can be handled most easily at the point of
implementation
We recognize how challenging it is to align multiple programs
across eleven state agencies, all of which have existing processes.
 Based on our experience with encouraging program coordination to
date, we believe that the easiest path to this cross-program
alignment is to incentivize collaboration among program
administrators to cross-qualify eligible low-income households for
multiple GGRF programs.  

Program administrators can compare how program guidelines align or
conflict, and can find ways to help to qualify their customers for
other programs in ways that are labor- and cost-effective.  These
administrators are already responsible for verifying eligibility,
and they can find points of connection between various program
guidelines that improve low-income accessibility while maintaining
program integrity. 

We encourage staff to consider specific strategies to start
creating these interconnections by including enabling language
within program guidelines to prioritize cross-program collaboration
to find effective ways to maximize related co-benefits.  The Light
Duty Pilots would be an ideal testing ground on how to interconnect
climate equity programs.




A process is needed to consider new additions to the Light Duty
Pilot Projects
The Light Duty Pilot Projects have been a good space to test
potential approaches for GHG reductions in disadvantaged
communities.  It would send a positive signal if CARB would
establish a process by which new projects could be considered for
inclusion in future years.

Web-based systems are needed to manage within and between CCI
programs
Customer Relationship Management systems powered by a relational
database are typically used to managing large-scale sales or field
operations.  A well-designed software system could expedite all
aspects of GGRF-funded programs, from outreach to customer intake
and qualification to project management to reporting and
accounting.

By adding program eligibility criteria into project management
software and constructing a logic tree for how these rules
interrelate, the management system can accurately assess customer
eligibility and ensure a rigorous but inclusive verification
system.  We request that CARB start a 
work stream to consider how to best implement a unified program
management system that can link programs and align program metrics
and reporting.

Low-income customers often require additional program flexibility
Qualifying low-income households in disadvantaged communities
requires a more inclusive administrative approach than for other
customers.  For example, many lower income customers do not file
IRS tax returns, so verifying household income with IRS Form 4506-T
is problematic.  In addition to 
the concept of cross-qualifying customers that are already in a
state or utility low-income program, another potential solution
would be to use the income reported on credit reports.  Other
perceived 
barriers for low-income households include concerns about family
members who are undocumented residents, or have legal issues where
applying for a government program may seem like a risk.  

Acknowledging the challenges in these households and avoiding
creating perceived barriers is key to maximizing participation in
disadvantaged communities.  We recommend that CARB consider how to
best maintain low-income accessibility in the qualification
process, and how to avoid conflicting and confusion qualification
criteria that could create barriers to access.

Supply of used PEVs is a limiting factor for EFMP Plus-Up
Used PEVs are an opportunity to encourage greater overall demand
for plug-in vehicles.
The EFMP Plus-Up program in the San Joaquin Valley has found that
the most popular choices for replacement vehicles are plug-in
hybrids and battery electric vehicles.  The only limiting 
factor in selling these vehicles is the supply of used PEVs. 
Valley CAN is making every effort to increase the availability of
plug-in vehicles to satisfy customer demand.  It is not much of a
stretch to say that if there was sufficient availability of plug-in
vehicles, EFMP Plus-Up results would be close to 100% PEVs. 
Longer-term success of the EFMP Plus-Up program is interdependent
on the continued success of CVRP 


in selling new plug-in electric vehicles which are available for
resale to EFMP Plus-Up customers 3-5 years later.

PEVs can be leveraged to extend the benefits of solar PV
PEVs are a connection point between transportation and household
GHG reduction programs.  By combining BEVs with GGRF-funded solar
PV, we have seen the value multiply for these households.  There
are some potential experiments on how to further link PEVs and
homes:
•	We suggest a pilot project within the Light Duty Pilot Projects,
linked to the CVRP and EFMP Plus-Up programs, to consider options
for BEVs as home batteries and re-use of PEV batteries at the
household and community level
o	BEVs have been used as storage devices for homes in Japan, where
they have been shown to power an average-sized home for up to two
days.  Using a PEV as a battery for a home would be a game-changer
in disadvantaged communities in the San Joaquin Valley, especially
those that are not connected to the grid.
o	When PEV customers replace their batteries, the used battery can
potentially be repurposed as storage for rooftop solar PV systems,
further extending the flexibility and value of the system.

Thank you for your consideration.  If you need any additional
details, please feel free to contact Tom Knox, at (916) 288-2209 or
tom.knox@valleycan.org