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To The California Air Resources Board:
The following are REV's comments to CARB's draft Funding Guidelines
Supplement for FY 2016-17 Funds (Supplement) document.

To the extent that the guidelines advance both increasing rigor and
flexibility for agencies to determine what are acceptable GHG
reduction methods for GGRF programs, thank you. 

We do however want to raise a concern that may not be recognized
and accounted for in the existing guidelines and should be.  It
appears that the guidance focuses only on specific subject matter
GHG reducing "projects" and does not address measurement
requirements for broader organizational GHG reducing efforts should
an agency wish to set up a program to encourage organization-wide
GHG reducing outcomes.  

For example, since organization-wide peer cohort trainings were
recognized as a promising energy efficiency tactic in the
California Energy Commission's 10 year Existing Buildings Energy
Efficiency Action Plan, should the Transformative Climate Community
GGRF program wish to fund organizational peer cohort trainings to
help organizations reduce GHGs organization-wide, are the existing
guidelines sufficient to help them consider and deal with that
scenario?  To be sure, an organization-wide GHG reduction effort
will be composed of specific projects, but measuring GHG reductions
from each of those projects may require different and consolidated
measuring guidelines.  

Further and more broadly, we believe that unless CARB provides
guidance for agencies to utilize peer cohort trainings in their
GGRF programs, then utilizing this promising tactic will be less
likely to occur.

Thank you in advance for addressing these comments and providing
guidance to agencies about how they can set up and administer GGRF
programs that use peer cohort trainings to achieve
organization-wide GHG reductions.  If we can help provide any
information in this area to improve the guidelines, please let us
know. 

Matt Bogoshian
Chief Strategy Officer and General Counsel
REV