Comment Log Display

June 12, 2012


Mary Nichols, Board Chairman 
California Air Resources Board
P.O. Box 2815 
Sacramento, CA 95812

RE:Public consultation on investment of cap and trade auction
proceeds

Dear Ms. Nichols:

The Sonoma County Transportation Authority (SCTA) and Regional
Climate Protection Authority (RCPA) appreciate the opportunity to
comment on the proceedings related to use of cap and trade auction
proceeds.

The SCTA serves as the countywide transportation planning and
funding agency in Sonoma County. In that capacity the SCTA has been
actively engaged in numerous efforts to reduce GHG emissions from
the transportation sector. The RCPA is a legislatively created,
countywide body of local government officials charged with
coordinating and implementing climate change activities throughout
Sonoma County and to advocate on issues relevant to the role of
government and the reduction of GHG emissions. The SCTA and RCPA
share a Board of Directors made up of local elected officials from
each of the 10 jurisdictions in Sonoma County.

In response to the May 24, 2012, public consultation meeting held
in Sacramento, the SCTA/RCPA would like to offer comments from both
a transportation and local government perspective on the two
questions posed.

How can California effectively invest the auction funds to meet the
goals of Assembly Bill 32 (AB 32) including support of long-term,
transformative efforts to improve public health and develop a clean
energy economy?

The SCTA/RCPA recommends the following principles when considering
expenditure of the auction funds:

1.The Air Resources Board should, working in conjunction with other
State and local government agencies, develop a multi-year
expenditure plan to outline the priorities for the use of
cap-and-trade revenue. The expenditure plan should include
objectives and performance measures that link the expenditure of
funds to reduction in greenhouse gas emissions based on certain
criteria.

2.The expenditure plan should seek to enhance or maximize other
benefits to California, including improved mobility, livability,
public health, economic vitality and social equity.

3.Transportation Sector: 
  a.Given the importance of reducing emissions in the    
transportation sector, a significant amount of anticipated revenue
should be directed towards projects that reduce
transportation-related emissions. 
  b.This objective would enhance the implementation of Senate Bill
375 (SB375) and encourage the linkages between transportation, land
use, housing and healthy communities as well as connectivity
between modes of transportation. 
  c.The expenditure plan should provide direct investment into
transportation infrastructure, operations and maintenance with an
eye toward integrating those investments into a true user-friendly
system that is not just automobile-reliant.

4.Energy Sector: 
  a.Energy efficiency, renewable energy and the water/energy nexus
represent the key areas where emission reductions can be derived
from the energy sector and the built environment. 
  b.The objective of minimizing emissions from the built
environment will encourage comprehensive long term planning as well
as lead to innovations in land use planning, zoning ordinances and
building codes.  In addition, retrofitting our existing buildings
and systems can be done more immediately to provide emission
reductions. 
  c.The expenditure plan should continue and expand upon existing
efforts such as Energy Upgrade California, zero carbon water, Build
it Green, property assessed clean energy programs and other
incentive and financing tools that target retrofitting buildings
and systems and planning for the future built environment. 
 
5.Conservation Sector: 
  a.Protecting the natural environment and critical resources while
preparing to adapt to climate change impacts are the flip side of
addressing the built environment. 
  b.The objective of addressing conservation and adaption needs
should include open space protection, investment in working
forests, river parkway development, wetland protection and
development, bio-char options to address vegetative waste and a
number of other nature-based investments that lead to significant
GHG benefits.
  c.The expenditure plan should engage and fund local governments
to develop and implement conservation efforts that help protect our
critical resources and address adaptation issues. 

6.The expenditure plan should build upon the many diverse efforts
currently underway to implement emission reduction projects and
programs. There are excellent examples from all of the sectors and
at all levels of government.

7.The expenditure plan should direct funds to local government to
serve as implementers on behalf of the State. 
What criteria should be prioritized in the development of an
investment plan for auction funds and why?

The SCTA/RCPA recommends the following criteria be considered in
the development of an investment or expenditure plan:
1.Deliverability – can a project, program or policy be implemented
quickly and provide benefits both immediately and over the long
term?

2.Measurable benefits – does a proposed project, program or policy
demonstrate quantifiable reductions in emissions?
 
3.Geographic equity – will rural, suburban and urban areas see
equitable benefit from the expenditure plan? 

4.Diversity – are needs and values of different communities
addressed when it comes to prioritizing projects, programs and
policies?

5.Balance – how will a project, program or policy balance economic
value with environmental benefit to maximize mobility, livability,
public health, economic vitality and social equity?
Thank you for your consideration and we look forward to working
with you throughout this process.

Sincerely,


Valerie Brown
Chair, SCTA/RCPA

CC:Sonoma County Legislative Delegation
   SCTA/RCPA Board of Directors