Comment Log Display

November 12, 2015

The Honorable Mary D. Nichols
Chair, California Air Resources Board
1001 “I” Street
Sacramento, CA 95814

RE: Cap-and-Trade Auction Proceeds Second Investment Plan

Dear Chair Nichols:

Thank you for your leadership and service to the State of
California. Your vigilant work in advocating for our
environment and public health has helped California play an
international role in efforts to address climate change. On behalf
of the seven elected members of the East Bay Regional Park
District’s Board, we wish to officially comment on the
Cap-and-Trade Auction Proceeds Second Investment Plan.

The Park District is a steward of nearly 120,000 acres in the
eastern San Francisco Bay Area – one of the most urbanized regions
of California – and operates 200 plus miles of paved active
transportation trails. The District is well positioned to support
the State’s efforts to achieve greenhouse gas reduction
objectives.

We applaud the recent October 27th Draft Second Investment Plan. We
are pleased to see so many placeholders or “buckets” that our work
as a public natural resource management agency could support.
Importantly, we appreciate that special districts, such as our
Public Resources Code 5500 agency, are identified as potential
recipients for cap-and-trade proceeds. The grasslands, forests
rangelands, wetlands,shorelines and open spaces we manage surely
have an important role to play in protecting and growing carbon
stocks on natural and working lands.

Forest Carbon Plan:
We believe the Forest Carbon Plan designated in the October 27th
Draft Investment Plan is an extremely important step. The Park
District’s Fire Department works squarely in the middle of the
wildland-urban interface in the East Bay Hills. From 1923 to 1991,
there were 15 major wildfires in the East Bay Hills
interface. The 1991 East Bay Hills fire was nearly 25 years ago,
but it is still the most costly of any wildfire in California.
District employees were first responders when 25 people died and
3,280 residences were destroyed resulting in $1.5 billion in
damages. Since that horrific event, the Park District has
implemented a Wildfire Hazard Reduction and Resource Management
Plan. This is ongoing, costly work. The Forest Carbon Plan should
not only look at largescale forest carbon storage in rural areas,
but the important work of protecting against wholesale releases of
carbon where the wildland-urban interface places not only trees,
but homes, infrastructure, vehicles – and most importantly, people
– at risk. Historically, catastrophic carbon release due to
wildfire has occurred in the East Bay Hills nearly every four and a
half years. We are long overdue for another, but with proper costly
management, and despite extreme drought conditions, it is being
prevented. Proper funding for fuels management work in these
interface areas should be prioritized.
Implementation strategy: Develop grant guidelines within the Forest
Carbon Plan that consider or add points for wildland-urban
interface fuels management work.

Leveraging Investments:
We appreciate the sentiment that “state-federal and public-private
partnerships” will be “critical to effective
management of natural and working lands in California.” We agree
that state and federal investments in natural and working lands are
providing climate benefits, but so too are regional and local
investments. In the Bay Area, many of our public land agencies have
passed significant funding measures with 2/3rds of the vote for
natural resource protection, management and restoration. In some
cases, it is actually local agency investments that leverage state
and federal funds. Our agencies also provide significant
co-benefits including: landscape-level
protection and management of public lands, watershed protection,
shoreline resiliency, protection of rangelands and grasslands,
active transportation networks, recreational health benefits,
economic benefits,wildlife corridors and habitats, and shoreline
access. 
Implementation strategy: Provide priority to
agencies, regions, or counties that have enacted local natural
resource funding measures.

Paved Trail Active/Green Transportation Network:
We appreciate the concept of sustainable communities programs being
included in the 60% of continuous appropriations per SB 862 in
2014. We also very much appreciate the emphasis in the Draft
Investment Plan on filling in the gaps in the sustainable
communities and transportation infrastructure portfolio. In
particular,we appreciate the fact that specified special districts,
such as the East Bay Regional Park District, are included as
potential recipients. As managers of over 200 miles of paved,
non-motorized trails, which link the 33 cities
of the East Bay together in an Active/Green Transportation Network,
we wish to broaden the discussion about sustainable communities.
Most interpretations of “a sustainable community” are that it is
walkable and within a concentrated area. As interpreted by the Bay
Area’s Metropolitan Planning Organizations they are classified as
Priority Development Areas which are dense, infill housing pockets
within a subsection of a city,usually near a transit node. In order
to truly maximize GHG reduction benefits through Active
Transportation,we need to focus on connecting communities.
Completing the trail gaps between communities should be a priority
to improve and/or create a true alternative transportation network
for the non-motorized movement of people. Of our 41 trail counters,
which in fact demonstrate trail usage peaks during the morning and
evening commute hours, one located at the Pleasant Hill BART
station has counted an increase of 50,000 annual users over the
last five years. Multiply that out by 200 miles of paved trail and
we have data to demonstrate a significant reduction in vehicle
miles traveled. Regional agencies such as ours are able to complete
non-motorized paved trail networks across jurisdictions.
Prioritizing investments to regional
agencies should be considered. 
Implementation strategy: Provide priority to connecting communities
via non-motorized active transportation networks, with additional
points considered for regional agencies that cross multiple
jurisdictions.

Urban Greening:
We agree that increasing the urban tree canopy and expansion of
green infrastructure – including wetlands restoration and watershed
protection – plays an important role in sequestering carbon and
increasing energy efficiency. We offer a slight expansion to the
definition of traditional urban greening projects. The population
of the two counties served by the Park District, Alameda and Contra
Costa, is over 2.5 million. The Park
District has significant parks in highly urbanized parts of
Oakland, Richmond and Fremont. Typically, District parks are more
passive and not akin to neighborhood, pocket, or linear parks. They
are in urban areas, but because of the size of some of our parks
they don’t feel like it. To effectively realize urban greening
benefits in regional parks, the scale of these allocations need to
be significantly increased. We believe the Urban Greening for
Sustainable Communities Program, overseen by the Strategic Growth
Council and administered by the Natural Resources Agency, should be
expanded. We also support creating a 4-5% allocation for a
Carbon-Smart Green Infrastructure Program to integrate more
co-benefits into the Urban Greening for Sustainable Communities
Program. 
Implementation strategy: Develop two (or more) sets of criteria for
urban greening grants, one of which recognizes larger scale
projects in regional parklands that are within urban areas.

Wetland Creation and Coastal Resiliency:
With close to $50 billion in homes, offices and infrastructure at
jeopardy due to sea level rise in the Bay Area,we can ill afford to
not consider resiliency in any Investment Plan related to climate
change. Many of the East Bay’s most disadvantaged communities are
along the shoreline and vulnerable to sea level rise, including
Richmond, Oakland, Hayward, etc. Wetlands creation and restoration
provides known GHG reduction
benefits, and also improves watersheds and wildlife habitat.
Importantly, as is pointed out in the Draft Investment Plan, “they
are the first line of defense against sea-level rise and storm
surge, particularly in the fragile Delta region.” We believe this
should read, “particularly in the fragile San Francisco Bay-Delta
region.” The Park District has developed innovative, adaptive
strategies for Bay and Delta shorelines – such as the multi-million
dollar Breuner Marsh wetlands restoration investment in Richmond
and the $5.4 million sand
replenishment effort along Shoreline Drive in Alameda – which
provide buffer zones for homes and infrastructure while providing
multiple co-benefits to the region. Regulatory challenges, however,
restrict rapid development and future opportunities for wetland
restoration and creation along the Bay-Delta region. As the
Baylands Ecosystem Habitat Goals Science Update of 2015 points out,
at least eight state and federal agencies are likely to have a role
in the permitting process of Bay Area wetlands. In addition,
wetlands restoration
projects may need local authorization from cities or counties, and
those that cross paths with railroad tracks,pipelines, highways and
utilities need additional permission. Streamlined permitting
mechanisms for wetlands restoration and creation are necessary. In
addition, flexibility is needed for adaptive management of sites
until best practices are truly understood. Also, flood-control
channels need to be naturalized for both resiliency and water
quality. Lastly, wetland restoration and creation projects which
maximize carbon sequestration may
not fully meet other habitat objectives that other regulatory
agencies are charged with advancing.
Implementation strategy: Streamline permit processes and provide
flexibility in project management for wetland restoration and
creation efforts funded by GGRF appropriations.

Carbon Sequestration and Land Use Planning:
We agree with the Investment Plan’s assertion that protecting
natural lands from conversion to more carbon intensive
uses, such as residential and commercial development, provides a
high value to the state’s overall GHG reduction goals. Based on an
evaluation by ICF Jones & Stokes, the average amount of carbon
sequestered by the Park District’s lands is over 91,157 metric tons
– the equivalent of removing 16,317 passenger cars and
sport-utility vehicles from the road annually, saving approximately
over 10.4 million gallons of gasoline. By preserving natural land
in perpetuity, the District’s parklands represent an important
permanent carbon stock of over 2.8 million metric tons (estimates
last updated in 2011). Additionally, our properties form natural
boundaries encouraging more infill development that reduces vehicle
miles traveled,
infrastructure expansion and the associated GHG emissions. These
lands, however, need proper management to retain sequestration
value – particularly with regard to wildfire threats. We believe
public natural resource management agencies should be awarded
offset credit funds for continued stewardship. Further, we believe
property owners should be incentivized for conveying or selling
land to grow carbon stocks. Private property
owners should benefit from conveying or selling property, not just
granting easements, to natural resource agencies rather than for a
more carbon-intensive use. We believe this can be addressed in the
Gaps and Needs Assessment Natural and Working Lands comments on
page 43 of the Investment Plan by stating “targeting investments
toward private landowners with easements and/or as incentives for
outright transfer of land
ownership to natural resource agencies on forest, undeveloped and
agricultural lands that are at risk of conversion.” Implementation
strategy: Provide annual offset credit funding for effective long
term management and incentivize property transfers to natural
resource agencies.

As is stated in the Draft Investment Plan, “there is a strong
history of land conservation in California [and particularly in the
East Bay] to protect wildlife, preserve agricultural viability,
improve water supply and quality,and provide parks and open space
for residents and visitors from around the world.” The District
concurs that California’s lands “should be protected and managed
wisely to reverse carbon loss, and to preserve and grow carbon
stocks.” To reach our collective goals, there must be significant
investment from Cap-and-Trade
proceeds in managing, maintaining and restoring our natural lands –
including the parks, open space, wetlands and rangelands of the
East Bay.

Thank you again for your leadership on this issue. We look forward
to continuing to work with you. Please feel free to contact us if
you have any questions or would like additional support
documentation.

Regards,
Robert E. Doyle
General Manager
East Bay Regional Park District

cc: Governor Edmund G. Brown, Jr.
The Honorable Matthew Rodriquez, Secretary, California
Environmental Protection Agency
The Honorable John Laird, Secretary, California Natural Resources
Agency
The Honorable Michael Cohen, Finance Director, California
Department of Finance
East Bay California Legislative Delegation
EBRPD Board of Directors