Comment Log Display

The Gateway Cities COG staff submits the following comments
regarding the Draft 2017 Scoping Plan Update:

1) Ensure Local GHG Reduction Goals are Voluntary and Applicable
Regionally

The proposed local government GHG (CO2e) goals of 6 MT per capita
by 2030 and 2 MT per capita are useful as benchmarks for local
jurisdictions engaged in climate planning.  The final 2017 Scoping
Plan should make it clear that these goals are not enforceable
mandates, and that no mitigations or remedies will be required of
any jurisdiction that should fail to meet them.

The Gateway Cities are 27 diverse cities in Southeast Los Angeles
County - diverse in size, population, capacity, and economic base. 
Based on a preliminary 2010 community GHG inventory conducted by
Los Angeles County, some of our cities already are below 6 MT per
capita; others, with a large industrial base and a small
residential population, are well above this goal, and are likely to
remain so.  The recommended 2030 goal of 6 MT per capita may be a
useful starting point as a regional target, but it is highly
unlikely that each of our cities could meet the goal individually. 
The ability of any of our cities to reach 2 MT per capita by 2050
is unknown.  

2) Restore Focus on Reducing GHG, not VMT

The current 2017 Scoping Plan draft appears to be shifting state
policy towards an explicit goal of reducing vehicle miles traveled
(VMT) rather than GHG.  This would be an unfortunate and
short-sighted shift in focus (although there is certainly value in
encouraging people to avoid using cars when it makes sense).

As vehicle emissions drop over time with the adoption of cleaner
fuels and fleets, VMT reduction will have less and less impact in
reducing emissions.  Moreover, VMT represent economic activity, so
schemes to limit them could have a significant downside that should
be evaluated for policy makers' consideration.  And the state
separately is evaluating VMT fees (mileage charges) as a way to
bolster state transportation finance as gas tax revenue drops.  The
state cannot simultaneously reduce VMT while also hoping to use it
to raise revenue.

3) Take Needed Steps to Ensure CA Climate Investments Reach
Disadvantaged Communities

The Gateway Cities of Southeast Los Angeles County are home to one
of the greatest concentrations of disadvantaged communities in the
state.  Three-quarters of our two million residents live in census
tracts designated as "disadvantaged" according to CalEnviroScreen
2.0.  Despite this need, and a robust, participatory planning
process over the past 20 years, very little of the cap and trade
funding has been awarded to our communities.  This is part of a
larger pattern where more funding finds its way to the Bay Area
than to Southern California.

As of this writing, despite several grant applications under
various programs, close involvement with staff of the various state
programs, and providing focused workshops for our city staff, the
Gateway Cities have received one $15 million grant under the
Affordable Housing & Sustainable Communities program. 
Additionally, we will benefit (eventually) from deployment of
clean-fuel heavy duty vehicles under a portion of the $23.5 million
CARB grant to the South Coast Air Quality Management District. 
Apart from these awards, 1.5 million disadvantaged residents of the
Gateway Cities, and their neighbors, have received no direct
investment of cap and trade revenues since the inception of the
program.

It is our hope that the state will closely re-evaluate its
processes for awarding these funds to ensure that our communities
are among those who will benefit going forward.  The net effect of
continued investment only in the areas that are at the leading edge
is to exacerbate inequality, not to reduce it.  Surely this cannot
be the goal of the state's policies regarding disadvantaged
communities.