Comment Log Display

November 11, 2015

Chair Mary Nichols and Board Members
California Air Resources Board 
1001 I Street
Sacramento, CA 95814


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

Dear Chair Nichols and Board Members:

On behalf of Strategic Concepts in Organizing and Policy Education
(SCOPE), I would like to thank the Air Resources Board (ARB) for
providing the opportunity to give feedback on the Draft
Cap-and-Trade Auction Proceeds Second Investment Plan: Fiscal Years
2016-17 through 2018-19. We greatly appreciate the ARB’s ongoing
efforts to incorporate the public’s recommendations into the Plan’s
priorities.

SCOPE is a 22-year-old community organization based in South Los
Angeles that has worked over the past 10 years to create replicable
models for targeted training and career-path job opportunities for
disadvantaged workers in the climate and green jobs sector. We are
currently working with other South Los Angeles-based organizations
through the Los Angeles Equity Alliance to ensure equitable
investment and full integration of low-income communities in
climate resilience efforts and high-road green job creation. 

As the agency tasked with identifying priorities to help achieve
greenhouse gas (GHG) emission reduction goals, maximize benefits to
disadvantaged communities, and yield valuable co-benefits, we
believe that the ARB’s recommendations would be strengthened by
providing more emphasis on job growth and workforce development
benefits—a key post-2020 implementation strategy identified by
State agencies. Our comments focus on specific areas in which the
ARB can incorporate the issue of job creation and workforce
development—in relation to disadvantaged workers in particular—in
the overarching strategies to transition to a low-carbon economy. 

Recommendations:

1.	Include job creation & workforce development in the assessment
of gaps and needs
Including a better gap and needs assessment related to job creation
and workforce development can help ensure that future programs
maximize economic benefits, foster job creation, and direct
investment toward the most disadvantaged communities in the state.
Reaching the State’s long-term goals will require significant
policy, development and industry shifts, and understanding the
workforce and training needs of the new clean energy economy is
imperative. Such an assessment should also explicitly look at
potential job creation and economic co-benefits to disadvantaged
workers.   

2.	Intentional investment in job creation and training programs
Under each investment concept, the ARB should discuss potential job
creation and training opportunities. Given the strong policy
mandate to maximize job creation, particularly among the state’s
disadvantaged workers, the ARB should provide additional context on
job creation for decision-makers. Where possible, the Plan should
highlight industries where successful and scalable training models
and career-pipelines exist.

3.	Research, development and deployment of innovative workforce and
targeted training strategies related to Cap-and-Trade funded
programs and projects
The Plan should prioritize investment in innovative program models
that develop successful job placement and training opportunities
using concrete workforce indicators and metrics in conjunction with
GHG emission reduction benefits.  Research and development support
are needed to ensure targeted-hiring, training, and new
career-track job development models go hand-in-hand with GHG
reductions. Training investments will not only lead to a higher
skilled workforce, but have been proven to produce more effective
greenhouse gas reduction outcomes. Additionally, thoughtful
investment in successful job and targeting models will help
low-skilled, incumbent, and disadvantaged workers access jobs in
the growing clean energy economy, ensuring it is inclusive and
accessible to all California’s workers. 

4.	Integrating complementary jobs and workforce recommendations in
future program guideline development 
These recommendations require better coordination between the ARB,
which develops investment priorities and funding guidelines, and
the agencies administering program funds, so that investments in
training and project performance goals can be tracked and evaluated
and concrete job and training goals can be set. Integrating these
recommendations into the Second Investment Plan will ensure that
additional workforce-related recommendations at the program
guideline-level are more effective. 


We appreciate the opportunity to share our comments and we thank
you for all the work your agency has done to implement these
important programs. I am available to discuss our workforce models
and our recommendations more in depth. Please feel free to reach
out with any questions or if you would like more information. We
look forward to working with you to ensure that our state’s most
disadvantaged workers and their families are able to benefit from
these investments.


Sincerely,

Laura Muraida
Research Director
Strategic Concepts in Organizing & Policy Education (SCOPE)