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On behalf of the City of Benicia, we respectfully support investing
Cap-and-Trade Auction revenue in local governments.  We appreciate
that the Draft Cap-and-Trade Auction Proceeds Investment Plan
(Investment Plan) lists local governments as eligible recipients
for several of the potential funding categories; however, the City
strongly supports a more clearly defined role for local governments
because they are best suited to identify and implement projects to
reflect local needs, leverage other funding, and achieve the
greatest reductions in greenhouse gas (GHG) emissions. 

The Investment Plan should create a Local Emission Reduction
Program for municipalities to access a portion of the funds
generated from the Cap-and-Trade Auction.  In addition to providing
local governments grants for implementation of GHG reducing
projects, the City of Benicia also requests that the Investment
Plan include a mechanism to direct a majority of proceeds from
covered entities within a local jurisdiction back to the
municipality.  We believe that the addition of a local
government-directed return-to-source component of the Investment
Plan will promote statewide sustainability by giving communities
most affected by pollution opportunities to implement GHG reducing
and energy efficiency projects that will create jobs and improve
the economy.  

The City of Benicia respectfully requests that you consider this
recommendation when finalizing the Investment Plan so that local
governments can continue helping California meet AB 32 goals.