Comment Log Display

The Center for Climate Change and Health welcomes the opportunity
to comment on the DRAFT Funding Guidelines for Agencies that
Administer California Climate Investments.  The Center dedicated to
tackling the challenge of climate change while creating more
vibrant, healthy and equitable communities. Our comments reflect
general concerns about the use of GGRF dollars.

We appreciate the thoughtful approach taken in the DRAFT funding
guidelines., most notably the attention to the concept of
resiliency, and the support for coordination, integration, and
leveraging of funds across agencies. However, we are concerned that
the application process, and the administration of other funds
across multiple agencies, must also be better coordinated and
integrated. Without state-level integration, it may be particularly
challenging for poorly resourced communities to navigate multiple
complex state programs and application processes. Additional TA for
these communities would also address this issue. 

The guidelines appropriately recognize the importance of
co-benefits. We understand that CARB will be developing further
direction on the quantitative assessment of co-benefits, and
request that you seek substantive input from public health experts
on a range of strategies to assess the full range of health
co-benefits and potential adverse health consequences (e.g. those
associated active transportation, agriculture, and urban greening).


The definition of GHGE reduction should include language consistent
with AB32 - that the reductions are real, permanent, quantifiable,
and verifiable. Quantification of emissions reductions should be
required to use methods that assess full life cycle emissions. 

It is essential that climate projections be taken into account in
the determination of suitability of proposed funding. Projects that
propose building infrastructure or housing in areas likely to be
adversely impacted by sea level rise and storm surge should not be
prioritzed for receipt of public funds. 

GGRF investments have the potential to play an important role in
community economic development, and in increasing the availability
of living-wage jobs for community residents in disadvantaged
communities. We suggest that proposals that address local hiring
and job training, and decent wages and benefits be preferentially
funded. 

We request that the scope of “urban forestry” be expanded to
include a broad range of projects such as community gardens, green
infrastructure, and tree maintenance. We support other comments
regarding the inclusion of tree maintenance and vegetation at Title
1 Schools as eligible for urban forestry funding. We also believe
that green infrastructure projects that will reduce the risk of
flooding in disadvantaged communities - even if the project itself
is located outside of a DAC - should be eligible.

The definition and criteria by which “benefit” for DAC and low
income residents requires more specificity, particularly for
projects located outside of a DAC. For example, without appropriate
safeguards, a transit-oriented development near a BART station in a
DAC may hurt current residents. We support a scoring method that
clearly delineates different types of co-benefits, such as health,
economic, or climate resilience. One important strategy for
assessing the “benefits” or potential harms of proposed projects is
to require community engagement and public participation in the
development of proposals for GGRF funding. 

While we strongly support land use that promotes reduced VMT, it is
very important that infill/density projects are healthy infill.
Anti-displacement measures to assure that TOD/infill projects
include adequate attention to prevention of displacement of current
residents. Measures to reduce potential adverse health impacts of
poor outdoor air quality should be incorporated into GGRF-funded
projects; other health concerns (e.g. noise-reduction, traffic
safety, access to essential services) should also be considered.
Adequate access to parks and green space is a critical component of
health, and we are concerned that it has been poorly addressed in
many neighborhoods currently undergoing “densification”.
 
Many DAC, subject to disinvestment over decades, lack access to
resources for health and to economic opportunity. We suggest that
GGRF funding also go toward building of affordable housing outside
of currently designated DAC, to increase the availability of
affordable housing in neighborhoods with high opportunity where
housing prices make them out of reach for low income people. 
We believe that the health co-benefits of active transportation are
potentially the most impactful on population health. Piecemeal
active transportation projects (e.g. a one-city bicycle plan,
disconnected bicycle lanes) will not get us to the VMT reductions
that are possible with visionary planning and implementation of
active transportation infrastructure. We would like planning and
cross-jurisdictional coordination required for truly regional
active transportation infrastructure, connected to transit, to be
more clearly eligible.

Finally, there are a variety of types of programs that are not
explicitly identified in the guidelines, but which could provide
significant GGHE reductions and health co-benefits. For example,
food waste contributes to landfill methane and to food insecurity,
and food waste reduction programs (such as that of Orange County)
can have a significant impact. We request that the guidelines offer
opportunities for innovation in areas not explicitly addressed, if
the GGHE and co-benefits can be appropriately quantified and
demonstrated.

Thank you again for the opportunity to comment.