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Comment 56 for Auction Proceeds Funding Guidelines (ggrf-guidelines-ws) - 1st Workshop.
First Name: Eva
Last Name: Kuczynski
Email Address: eva.kuczynski@tpl.org
Affiliation: The Trust for Public Land
Subject: The Trust for Public Land's comments on the GGRF Guidelines
Comment:
Thank you for creating the opportunity for public comment on the funding guidelines for agencies that administer California climate investments. The Trust for Public Land would like to provide brief comments on this guiding document. Our mission is to create a healthy and climate-smart California with access to nature for all. Overall we commend the ARB on compiling such comprehensive and detailed guidance for agencies that administer GGRF programs. We support the ARB in creating transparent program development and reporting requirements, and in holding public agency partners accountable to the ARB and to the public. Greenhouse Gas Quantification We look forward to reviewing the draft GHG quantification work plan that is under development (Vol. 1, p. 17) where ARB will lay out their process for development for new and updated GHG quantification methods. We applaud ARB’s dedication to developing GHG quantification methods that are both scientifically defensible and accessible; this will surely help the state meet its climate goals while making these funds available to disadvantaged communities, or applicants with less capacity for GHG modeling. We encourage ARB to continue working on developing user-friendly quantification methods and exploring the use of automated, web-based tools (p. 19). Such accessible tools are essential – both for enabling fair access to GGRF funds by diverse groups, and to ensure consistent, defendable data collection by the state. To further this goal, we recommend that agencies be required by ARB to provide technical assistance to applicants on GHG quantification; a higher bar should be set for required technical assistance beyond emailing with ARB (Vol. 1 p. 18). This will also support the ARB’s guiding principle of transparency in GHG quantification (p. 23). We also support ARB’s proposed creation of co-benefit GHG quantification methods to promote the inclusion of multi-benefit projects that meet statewide climate, sustainable development, and resource protection priorities. Moreover, quantification of co-benefits should be included in project scoring for all programs. For example, in the Strategic Growth Council’s Affordable Housing and Sustainable Communities program, scoring should include GHGs reduced by trees planted in the project area, or through stormwater captured through infiltration by green infrastructure. These co-benefits include, among others, urban forestry, green infrastructure, decreased energy usage, and transportation mode-shift (increased walking or bicycling instead of driving). Support for Disadvantaged Communities We recommend that ARB encourage granting agencies to incentivize applicants to directly engage members of the community within a potential project area in project selection, design, and prioritization, to ensure projects in disadvantaged communities are designed in collaboration with the communities they will serve, and that they will not displace current residents (p. 32). To that end, we recommend the addition of a bullet to Volume 2, p. 14 (Recommendations for Administering Agencies to Maximize Funding to Benefit Disadvantaged Communities), requiring grant applicants with projects located within or benefiting a DAC to engage that DAC in project design and implementation. To remove additional barriers for DAC in applying to GGRF programs, we request that ARB require from agencies a minimum of 60 days between the notice of funding and proposal deadline. We also suggest that ARB include in the guidelines a recommendation that matching funds should be waived for projects located within DAC. We would like ARB to ensure access to and equitable distribution of GGRF funds so a diverse group of nonprofits, agencies, municipalities and small business can be eligible applicants. We recommend that ARB require agencies to create set-asides within GGRF programs for planning and the creation of decision-making tools that will ultimately lead to projects that reduce GHGs. This will greatly assist communities to assess and prioritize needs, as well as develop innovative strategies for future GHG reduction and participation in GGRF programs. Likewise, we would like ARB to require agencies to create set-asides for projects in rural communities – although there is a great need for GGRF investments in our urban communities, there are many high-need rural areas of the state encompassed within CalEnviroScreen prioritized areas, that would not be triggered by grant program density requirements that are also worthy of investments. Please contact me if you would like to discuss any of the above in greater detail. I can be reached at 415-495-4014. Sincerely, Mary Creasman Director of Government Affairs The Trust for Public Land
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Date and Time Comment Was Submitted: 2015-08-13 17:08:21
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