Dear
Members of the California Air Resources Board:
We are
writing to you as members of the Building Energy, Equity and Power
(BEEP) Coalition to submit formal comments to the draft Scoping
Plan. The BEEP Coalition currently includes representatives from
Self-Help Enterprises; PODER; the Center on Race, Poverty & the
Environment; the Central Valley Air Quality Coalition; Leadership
Counsel for Justice & Accountability; Local Clean Energy
Alliance; and Physicians for Social Responsibility-Los Angeles. The
Coalition has been engaging with the AB 32 Environmental Justice
Advisory Committee and CARB staff on this topic throughout the
Scoping Plan development process to-date and we appreciate the
opportunity to memorialize those conversations and related
recommendations in this letter.
The BEEP
Coalition represents environmental justice communities in various
parts of the state. We formed for a simple reason: low-income
communities and communities of color are being left behind in
conversations about building decarbonization. We have previously
sent you our Preliminary Report, “Community
Priorities for Equitable Building
Decarbonization,” as a call to action to invest in the real, equitable,
community-driven solutions we know will work to ensure rapid
decarbonization and increased resiliency in the communities who
need to see those benefits the most. The recommendations included
in the Preliminary Report are developed directly from community
input heard in regional listening lessons in the San Joaquin
Valley, Los Angeles County, San Francisco Bay Area, and East
Coachella Valley. These communities are already bearing the brunt
of the effects of climate change and they deserve real solutions
that meet their unique needs.
The BEEP
Coalition recommends that CARB form an interagency working group to
work with communities to identify and address barriers to equitable
building decarbonization prior to adoption and implementation of any
appliance, indoor air quality, or building standards. We recognize and
appreciate the sense of urgency to move forward on standard-setting
now, and in general, we recognize the health, climate, and
environmental benefits that equitable building decarbonization can
provide. However, we also know from our direct work in frontline
communities that the barriers and risks of moving forward on those
standards, before appropriate funding and policy solutions are in
place, are significant and cannot be ignored - particularly for
low-income communities and communities of color already
overburdened by economic and environmental challenges with no
capacity for any cost increases or displacement
risk.
The
Preliminary Report highlights concerns across program design and
access, costs, and affordability, among other cross-sector issues.
For example, requirements for home ownership documentation and
other legal documents (only available in English) are existing
barriers to program participation. Additionally, residents without
existing appliances to replace (like air conditioning units) or
without access to natural gas are ineligible for many programs to
access cleaner, efficient appliances. Further, many low- and
middle-income households are considered ineligible to access
current financial assistance programs and program income thresholds
don't always cover families struggling to make ends meet. For many
communities across California, these conditions are reflective of
historical and ongoing lack of engagement and investment in their
communities, which means that these communities will need specific,
tailored solutions to help meet the state's decarbonization
goals.
The working
group would work collaboratively to identify funding and policy
solutions to critical issues that, if addressed, would allow BEEP
and other environmental justice stakeholders to engage fully in
discussions around equitable building electrification, appliance
standards, and upgrades that benefit the health and safety of
community members.
This
working group should, at a minimum, include members of the BEEP
Coalition and representatives from CARB, the California Energy
Commission, the California Public Utilities Commission, the
California Department of Community Services & Development, and
the California Business, Consumer Services and Housing
Agency.
The
following issues should be prioritized in such a working group, as
outlined in our Preliminary Report and based on feedback from
hundreds of stakeholders from across California:
-
Stronger tenant protections to ensure that
loopholes in state and local law are closed. Tenants should be able
to access programs without fear of untenable rent increases or
being permanently displaced for these improvements. The state also
needs to identify a robust enforcement mechanism that includes
trusted community-based organizations for upholding these
protections.
-
Equitable funding mechanisms that include
direct community grants, equipment and installation incentives,
rate reform, debt relief, and bill protection to enable no-cost
improvements for low-income households. These mechanisms would
include aligning existing incentives and cross-sector retrofit
funding to enable holistic building upgrades to happen
simultaneously. This also includes aligning affordable housing
funding and technical assistance so nonprofit developers can
implement decarbonization for new and existing
buildings.
-
Partnerships with local groups to facilitate
planning, outreach, and education efforts, similar to the model
used in the San Joaquin Valley Affordable Energy Pilots. Engaging
with local groups is critical to ensuring that trusted advisors are
responsible for enrolling, educating, and supporting community
members as they decarbonize. Regional approaches will be needed as
there is no blanket solution that can meet the diverse needs of
California's communities and local groups have the expertise and
relationships necessary to ensure that all communities across the
state are decarbonizing.
-
Regulatory and policy alignment to ensure
ratepayers are not negatively impacted by these improvements or
policies over time, and to address potential hurdles like
“obligation to serve” and other hurdles that may hamper
statewide decarbonization efforts.
-
Workforce alignment to ensure
frontline communities can access and benefit from new job
opportunities. This includes exploring community workforce
agreements, as well as public coordination of projects to ensure
high-road job standards are upheld.
-
Supply chain issues related to the
recycling and clean-up of natural gas infrastructure, as well as
the potential impacts of lithium extraction. Communities in the
Eastern Coachella Valley have expressed their interest in research
about the short- and long-term impacts of lithium extraction at the
Salton Sea, and how to build in protections that will ensure
frontline communities benefit from that activity.
The BEEP
Coalition further recommends that CARB reserve funding for
community engagement and CBO-led research in this work. We initiated
the process behind our Preliminary Report to help respond to the
Scoping Plan process, but were only offered $5,000 by CARB to help
offset our expenses. That level of funding was completely
insufficient to compensate for the time of frontline community
organizations and residents, so we pursued private funding to
enable us to complete the listening sessions and corresponding
report. Recently, we became aware of a $450,000
research solicitation from CARB, using our Preliminary Report as the foundation for that project -
with absolutely no requirements that any funded entity partner with
or compensate us for the role we would need to play in that
project. To set aside $450,000 for academics to do the work that we
were only offered $5,000 to complete is an insult to environmental
justice principles and the essential experience, community relationships,
and expertise the BEEP Coalition partners offer to this process.
CARB should reallocate the $450,000 for the project to enable BEEP
to continue our research and engagement, or identify an additional
$450,000 from another budget.
If you have
any questions about our position, please do not hesitate to reach
out to us. Thank you for your time and consideration of these
comments.
Sincerely:
Abigail
Solis
Self-Help
Enterprises
abigails@selfhelpenterprises.org
Antonio
Díaz
Chris
Selig
PODER
adiaz@podersf.org
Caroline
Farrell
Center on
Race, Poverty & the Environment
cfarrell@crpe-ej.org
Catherine
Garoupa White
Jasmine
Martinez
Central
Valley Air Quality Coalition (CVAQ)
catherine@calcleanair.org
Jamie
Katz
Leadership
Counsel for Justice & Accountability
jbkatz@leadershipcounsel.org
Jessica
Tovar
Barbara
Stebbins
Local Clean
Energy Alliance
jessica@localcleanenergy.org
Martha Dina
Argüello
Alex
Jasset
Edgar
Barraza
Physicians
for Social Responsibility-Los Angeles
marguello@psr-la.org
Cc:
Richard Corey,
Executive Officer
Edie Chang,
Deputy Executive Officer - Planning, Freight &
Toxics
Chanell Fletcher,
Deputy Executive Officer - Environmental Justice
Rajinder Sahota,
Deputy Executive Officer - Climate Change &
Research
Craig Segall, Deputy Executive Officer - Mobile
Sources & Incentives
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