Comment Log Display

Re: Auction Proceeds Funding Guidelines

Chairman Mary D. Nichols and Executive Officer Richard Corey
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Dear Chairman Mary D. Nichols and Executive Officer Richard Corey,


Thank you for the hard work that ARB staff has done to make the
Auction Proceeds Funding Guidelines possible. We are writing as a
coalition of groups serving the Sacramento Region to recommend
changes to this draft of the Guidelines. As a region, we have
formed a coalition of public agencies and organizations working
together to support and advance applications for key Greenhouse Gas
Reduction Fund grants, and have complimented that effort with a
robust engagement process in disadvantaged communities. The lack of
common application processes and metrics between state agencies
with funding programs and the lack of a common tracking website has
made this task very difficult. Our comments are directly informed
by those efforts.

Inclusive Development of Funding Guidelines

The Auction Proceeds Funding Guidelines are critical to the
administration of the Greenhouse Gas Reduction Fund (GGRF). Release
of the Draft Guidelines occurred on June 16th with only one
workshop scheduled less than a week later. We understand ARB’s
desire to give guidance to the agencies funded by the GGRF.
However, the potential for the Funding Guidelines to shape how
agencies engage communities and implement effective programs cannot
be overstated. 

The timeline for developing and refining these guidelines must be
extended to allow for meaningful participation from all interested
stakeholders in all areas of the state.

Clarity and Transparency in Application Process

Funding agencies each have their own process for allocating GGRF
grants. Project evaluation criteria and application processes are
obscured from applicants and community members by the separate
criteria and decentralized coordination. Further, the inability to
access active applications to all agencies hampers the community’s
ability to influence their project parameters and impedes
collaboration between agencies. 

All twelve agencies administering grants should post the criteria
used to rank applications and post applications received to a
centralized and public website to increase transparency and enable
community engagement and agency collaboration.

Meaningful Accountability for Co-Benefits

While the primary goal of the GGRF is to reduce greenhouse gas
emissions, co-benefits are a natural outgrowth of those efforts.
With some intentionality behind defining and evaluating
co-benefits, California can leverage auction proceeds to
significantly improve the health of our state’s disadvantaged
communities while also improving air quality. 

Agencies should require applicants to develop metrics for
co-benefits and to reference those metrics in their applications
and reports to enhance the effects of these investments. 

Reports on the metrics should be used to inform each agency’s
future rounds of funding. 

Organizations receiving funding will have a substantial monitoring
and auditing requirement for both co-benefits and GHG reductions.
The guidelines should recognize this requirement and provide for
the use of some funding for administrating this process. 

Agencies must give priority to applications that identify more than
one co-benefit.

Robust Community Engagement Processes

Assembly Bill 32 requires that public and private investment be
directed toward the most disadvantaged communities in California to
provide an opportunity for community institutions to “participate
in and benefit from statewide efforts to reduce greenhouse gas
emissions.”   SB 535 requires that “funding guidelines developed
for administering agencies… shall include guidelines for how
administering agencies should maximize benefits for disadvantaged
communities.” To abide by these legislative mandates, agencies and
applicants should do everything possible to ensure that GGRF
investments are funding those efforts that provide substantial GHG
reductions while responding to real community needs and are
bolstered by robust community input. It is these projects that are
likely to also provide substantial co-benefits (public health,
transit equity). 

All agencies administering GGRF should provide technical assistance
to community based organizations to promote the engagement of
disadvantaged communities. When necessary, ARB should exercise its
authority to distribute cap and trade revenues to fund grants that
will help agencies adhere to AB 32’s “participation” requirement
via agency- or board-level technical assistance.  

Applicants should receive priority if they can provide the contact
information (in accordance with privacy considerations) for
residents within the census tract their project targets to
illustrate community support for the application, in addition to
outlining their community engagement process in the development of
the application. 

Finally, agencies should consider pre-allocating funds to
metropolitan planning organizations or local governments based on
population and CalEnviroScreen scores to remove competition between
different regions that may exacerbate or perpetuate inequity in our
state. Pre-allocation would also better allow for holistic planning
at the community level.

Refinement of CalEnviroScreen 2.0

Observation of socially and environmentally disadvantaged
communities on census tract level does not always correspond with
the disadvantaged communities identified by CalEnviroScreen 2.0.
Observed outcomes from CalEPA’s CalEnviroScreen 2.0 model do not
accurately identify disadvantaged communities.

CalEPA should continue to refine CalEnviroScreen to be more
accurate and useful for the purposes of targeting GGRF to
communities with the highest level of need.


Thank you for your consideration of these comments. We look forward
to working with you to ensure the success of this important
program.

Sincerely,

Marti Brown, Executive Director
North Franklin Business District Association

Mat Ehrhardt, Executive Director/ APCO
Yolo Solano Air Quality Management District

Larry Greene, Executive Director/ APCO
Sacramento Metropolitan Air Quality Management District

Richard Guerrero, President
Environmental Council of Sacramento

Randy Knott, Director of Government Affairs
City of Sacramento

Bill Mueller, Chief Executive
Valley Vision

Matt Read, Director of Government Relations
Breathe California

Linda Roberson, Park Planner and Urban Designer
Cordova Recreation and Park District

Mike Wiley, General Manager/CEO
Sacramento Regional Transit

Submitted electronically at
http://www.arb.ca.gov/lispub/comm2/bcsubform.php?listname=ggrf-guidelines-ws&comm_period=1