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Dear Chairman Nichols and Members of the Board:

The Transbay Joint Powers Authority (TJPA) appreciates the
opportunity to comment on the Draft General Guidance for Agencies
that Administer California Climate Investments (Draft General
Guidance). The TJPA remains excited by the transformative effect
that cap-and-trade auction proceeds can have throughout the State,
especially in California’s Disadvantage Communities. As the TJPA
has previously stated, the Transbay Program is a model for transit
oriented development in California that will significantly reduce
greenhouse gas emissions and improve public health and quality of
life throughout the Bay Area.
Last fall, the TJPA submitted comments on CARB’s Draft Interim
Guidance to Agencies Administering Greenhouse Gas Reduction Fund
Monies. The TJPA appreciates CARB’s consideration of those
comments, and notes that the Draft General Guidance incorporates
the TJPA’s suggestion that the eligibility criteria in CARB’s
guidance documents include projects that are within ½ mile of a
Disadvantaged Community and that also provide transit benefits and
other amenities.
After reviewing the Draft General Guidance, the TJPA also
recognizes that many of its previously suggested amendments remain
applicable to this current guidance proposal. At the time that it
suggested those amendments, the TJPA was concerned that the CARB’s
proposed project evaluation criteria would not credit large
projects that will contribute substantial benefits to Disadvantaged
Communities. In effect, the guidance would unfairly penalize such
large projects. The TJPA continues to have similar concerns
regarding the project evaluation criteria included in the Draft
General Guidance. Thus, the TJPA is enclosing its previous comments
for CARB to consider including in the final General Guidance
document. The TJPA further notes that the amendments that it
previously proposed to the evaluation criteria for investments in
transit projects are equally applicable to the criteria for
investments in affordable housing projects.
The TJPA therefore respectfully requests that CARB amend the Draft
General Guidance to better reflect the substantial benefits that
large projects, such as projects within the Transbay Program,
provide to Disadvantaged Communities. Please do not hesitate to
contact the TJPA if we can be of any assistance as you continue to
develop CARB’s Draft General Guidance documents.