Comment Log Display

GGRF DRAFT Funding Guidelines Comment: Thank you for the
opportunity to comment on the DRAFT Funding Guidelines for Agencies
that Administer California Climate Investments. Having previously
led CDPH’s climate and health policy and planning work from
2010-2014, I strongly support the state’s climate change mitigation
efforts and see critical opportunities to address healthy and
equitable and healthy communities as part of these efforts. My
comments reflect general concerns about the use of GGRF dollars. 

Having worked at the staff level at the state health department
working to support CAT and AB 32 goals, I strongly support your
attention to the concept of resiliency, and the support for strong
coordination, integration, and leveraging of funds across agencies.
 This coordination is essential to fostering the broadest and most
effective efforts across complex and interdisciplinary program and
policy domains. In fact, the application process, and the
administration of other funds across multiple agencies, must be
better coordinated and integrated to achieve the best results.
Without clear and well-communicated state-level integration, it may
be particularly challenging for those in disadvantaged communities
to navigate multiple complex state programs and application
processes. In fact, those communities need and should have access
to additional technical assistance services in order to be able to
fully participate in state climate mitigation funding programs.

I’m very supportive of the guidelines highlighting the importance
of identifying and pursing co-benefits. I understand that CARB is
developing additional quantitative methods for co-benefits. In
order to develop appropriate public health co-benefit measures, it
is very important that CARB 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. For example, projects that propose building infrastructure
or housing in areas likely to be adversely impacted by sea level
rise and storm surge should not be prioritized 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. I suggest that proposals that address
local hiring and job training,  livable wages and benefits be
preferentially funded. In addition I would suggest that the scope
of “urban forestry” be expanded to include a broad range of
projects such as community gardens, green infrastructure, and tree
maintenance. 

I 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 at CDPH and working with the CAT Climate and Land
Use cmt chaired by OPR, I frequently raised the need to support
healthy infill development and encouraged standards that would
ensure that projects not create new health risks such as urban heat
islands, or perpetuating/creating inequitable green space deficits,
while promoting infill/TOD and density projects. Adequate access to
parks and green space is a critical component of health, and am
concerned that it has been poorly addressed in many neighborhoods
currently undergoing “densification”. I encourage you to
incorporate health goals as part of infill projects.
Anti-displacement measures to assure that TOD/infill projects
include adequate attention to prevention of displacement of current
residents are urgently needed. I strongly believe that the health
co-benefits of active transportation can potentially achieve a huge
positive impact on population health. Piecemeal active
transportation projects (e.g. a one-city bicycle plan, disconnected
bicycle lanes) will not achieve the VMT reductions that are
possible with truly transformational planning and implementation of
active transportation infrastructure. I would encourage you to
consider how planning and cross-jurisdictional coordination that
truly promotes/ supports regional active transportation
infrastructure, with good transit connections, can be included as
eligible projects. 

Thank you for the opportunity to comment on these important
guidelines.