Comment Log Display

April 24, 2013


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

Re: City of Long Beach Comments – Cap and Trade Investment Plan 

Dear Chairman Nichols:

On behalf of the City of Long Beach, I write in support of the
progress that has been made by the California Air Resources Board
(CARB) to implement the State’s Cap and Trade Program.  Long Beach
supports the three investment priorities described in this draft
plan, but urges the Board to consider one additional greenhouse gas
reduction strategy within these three priorities.  The City is
requesting waste-to-energy be included as a potential area for
investment in the Energy Efficiency and Clean Energy portion of
this investment plan.  Long Beach is interested in future
discussions with CalRecycle on how these facilities can play a role
in increasing diversion from landfills.

Sustainable Communities and Clean Transportation appears to be the
focus for investing cap and trade revenues.  Long Beach supports
this is as appropriate area for investment.  The City has worked
closely with other local governments in the region through the
Gateway Council of Governments (Gateway COG) and SCAG to develop a
Sustainable Communities Strategy (SCS) per SB 375 to identify areas
for greenhouse gas reduction in the region.  This plan is region
specific, and the City supports the implementation strategy that
has been identified.  

Long Beach also supports the proposal to invest in zero-emissions
freight movement technology.  In particular, zero-emission projects
are of significant interest to Long Beach given the volume of goods
movement originating from the Ports of Long Beach and Los Angeles. 
As documented by the CalEnviroScreen, communities along the I-710
freeway are disproportionally impacted by greenhouse gas emissions.
 Cap and trade investment into zero-emission infrastructure along
this major goods movement corridor is important to Long Beach.

The Draft Cap and Trade Investment Plan identifies Energy
Efficiency and Clean Energy as a second investment priority. 
Though the City of Long Beach agrees clean energy, and energy
efficiency programs will reduce greenhouse gas emissions, Long
Beach urges CARB to consider including waste-to-energy in this
section of the investment plan.  The State Department of Resources
Recycling and Recovery (CalRecycle) recently published a report
that shows California’s three existing waste-to-energy facilities
help reduce greenhouse gas emissions.  Published July 3, 2012,
CalRecycle Review of Waste-to-Energy and Avoided Landfill Methane
Emissions, concludes, “The three existing California WtE facilities
provide net avoided methane emissions over waste otherwise disposed
in a California landfill.”  The City is also encouraged to see the
inclusion of energy efficiency retrofits in the Draft Investment
Plan.  On this issue, Long Beach requests that local government
buildings be included in the list of eligible projects. 

The City is particularly interested in the implementation of the
final investment priority, which is described as Natural Resources
and Waste Diversion.  Long Beach is encouraged that this investment
area will provide competitive grants to local agencies to expand
and improve waste diversion and recycling.  The City is committed
to strategically implementing these goals, and is interested in
future discussions with CalRecycle and the California Energy
Commission regarding valuable greenhouse gas and clean energy
benefits that may be achieved through emerging technologies.

The Draft Investment Plan notes that it does not include dedicated
funding levels for each investment priority area due the
uncertainty of funds available each year, as cap and trade auctions
occur quarterly.  However, the Draft Investment Plan also does not
set forth a percentage of funding for each investment priority
categories.  Long Beach strongly prefers that funding continue to
focus on Sustainable Communities and Clean Transportation, as this
is the area that the City believes will have the most impact on
reducing greenhouse gas emissions.

Thank you for the opportunity to comment.  Should you have
questions, please contact Tom Modica, Director of Government
Affairs and Strategic Initiatives at 562-570-5091 or
Tom.Modica@longbeach.gov.

Sincerely,



Patrick H. West
CITY MANAGER