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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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