Comment Log Display

Dear Ms. Nichols and Board members:

On behalf of the under-signed organizations and individuals, Green
Schools Initiative welcomes the opportunity to submit comments on
the Second Draft Cap-and Trade Auction Proceeds Second Investment
Plan: Fiscal Years 2016-17 through 2018-19.  Collectively, our
organizations represent more than 1.6 million parents, students,
facility directors, school board members, school district
administrators, environmental educators, and health and
environmental organizations, and nearly all 1,000 school districts
and county offices of education in California. We advocate for K-12
public schools in California and are dedicated to ensuring that
schools are community models of sustainability that contribute to
achieving greenhouse gas reduction goals and that provide healthy,
safe learning environments for all California students. Climate
change is a children’s issue: children are more vulnerable to
heat-related illnesses, air pollution and asthma, and lack of
access to safe outdoor spaces to play and learn. The California
State PTA and the American Academy of Pediatrics both issued
resolutions and policy statements this year recognizing children’s
special vulnerabilities to climate change and called for action.  

Given that children are required to attend school, and that 1 in 5
Californians spend their day in a K-12 school – including 6.2
million school-aged children – we urge the California Air Resources
Board to prioritize investments in greenhouse gas reduction
projects at K-12 schools in its Investment Plan to protect children
and capture significant emission reductions. Our recommendation is
aligned with the “California Blueprint for Environmental Literacy,”
recently published by the California State Superintendent’s
Environmental Literacy Task Force and the Californians Dedicated to
Education Foundation, which recommends that the California Air
Resources Board explore possibilities for allocating a portion of
the Greenhouse Gas Reduction Fund for developing green schools and
schoolyards. 

Healthy, sustainable, and green schools will contribute to each of
the three over-arching priorities established in the draft
Investment Plan for Transportation & Sustainable Communities, Clean
Energy & Energy Efficiency, and Natural Resources & Waste
Diversion. Alternatively, California will not achieve the goals of
reducing greenhouse gas emissions by 40% below 1990 levels by 2030
if K-12 schools are not included given their sizable footprints. We
submitted similar comments on the first draft of the Investment
Plan on September 1, 2015, but the second draft does not reflect
these comments and we remain concerned about this significant gap
in capturing substantial co-benefits from school-based projects for
urban forestry, water conservation, active transportation, and
waste reduction, among others.  This letter builds on our earlier
comments and provides additional recommendations for why and how to
integrate schools into ARB’s priority investments.

The word “schools” appears only once on page 32 of the second draft
Investment Plan (in the first draft it was page 11 – same sentence)
in a passing reference to active transportation.  There is one
existing program under ARB’s Hybrid and Zero Emission Truck and Bus
Voucher Incentive Project (HVIP) that includes grants for rural
school districts to invest in lower-emission school buses, and
should be continued. Proposition 39 provides funding for energy
conservation and renewables at K-12 schools and is having a
positive measurable impact on reducing schools’ energy use.
However, Prop 39 does not cover other greenhouse gas reduction
projects like transit, composting, tree planting, asphalt removal,
or water conservation. Currently, K-12 school districts are either
excluded completely and are not eligible to apply for grants or the
barriers to pursue greenhouse gas reduction funds are too high,
requiring separate complex applications and reporting to different
agencies, and managing separate partnerships in order to be
eligible.

We urge ARB to include “Sustainable Schools” as an investment
element relevant to investment concepts and “cross-cutting
approaches” (pp. 28-29) in its Second Draft Three Year Investment
Plan 2016-2019 and to ensure that K-12 public school districts –
especially those in disadvantaged communities designated by CalEPA
– are eligible to receive GGRF funds via existing or new grant
programs. Sustainable, healthy schools are critical to achieving
the State’s greenhouse gas reduction goals and to protecting the
health and well-being of vulnerable children from the impacts of
climate change at school, while engaging students by modeling
sustainability at school.

We recommend (attached letter has citations and footnotes):  

1. Investments in Integrated Projects in Disadvantaged Communities
for Local Climate Action (pp. 28-29) – We support priority
investments for disadvantaged communities, as required by SB535,
and recommend that K-12 schools in disadvantaged communities be
included in your framework for “community greening” projects. There
are an estimated 125,000 acres of school grounds  (admittedly
conservative estimate) and 36,000 school buildings that are perfect
candidates for integrated approaches, including green
infrastructure, tree planting, asphalt removal, cool/green roofs,
active transportation, clean school buses, water conservation,
water/energy nexus and more. School districts and Local Educational
Agencies (LEAs) should be included in the “menu of potential
projects” (p. 29) and should be included as potential recipients of
grants, technical assistance, and other forms of support. To date,
schools and LEAs “have been virtually left out of California’s
state policy framework on sustainable communities planning,”
including both SB375 and the Strategic Growth Council as well as
AB32 – a glaring state disconnect considering that school
facilities funding has been about 2/3 of all state general
obligation bonds since the 1970s. 

2. Include Schools as an Urgent Priority for Urban Forestry Grants
(p. 43 and Figure 16): A recent study by UCLA estimated the average
number of days with temperatures hotter than 95o F will increase
from 58/year in 1980-2000 to 98/year in 2041-2060 in Riverside
(~70% increase and even more when projected to 2100), 6/yr to 22/yr
to 54/yr in Los Angeles, and 111/yr to 134/yr to 154/yr in
Bakersfield, among other parts of southern California.  Paved
school grounds can be 20-40 degrees hotter than vegetated areas,
worsening heat exposure. Investments at schools for urban forestry,
asphalt removal and more permeable surfaces, cool roofs, and other
green infrastructure projects can help reduce and mitigate these
heat island effects, capture stormwater, sequester carbon in the
soil, and save money, as well as create living schoolyards and
outdoor classrooms that enhance children’s learning. However, a
study by Claremont Graduate University and Council for Watershed
Health showed that 20% of the 509 elementary schools surveyed in
Los Angeles Unified School District had 0% tree canopy and 100%
paving – and that the schools with the fewest trees and most paving
were primarily in low-income schools and communities.   We know
that children’s health and ability to learn are worsened by heat
extremes. Yet, K-12 schools are not eligible for CalFire urban
forestry grants; in some regions (but not all) non-profits may
apply with schools as a partner but schools, districts, and LEAs
cannot apply directly. Given the greater impact of heat on children
and the disparity in tree cover at schools in disadvantaged
communities, ARB should ensure that K-12 schools in disadvantaged
communities are eligible to apply directly for urban forestry
grants, together with other integrated “school greening” projects
with multiple co-benefits. In Figure 16 (p. 45), school districts
and LEAs should be included as potential recipients.

3. Include Schools in Reducing Short-lived Climate Pollutants (p.
44 and Figure 16) – We support the Investment Plan’s priority to
reduce short-lived climate pollutants, such as methane, via waste
reduction and composting; however, we urge you to ensure that K-12
schools are eligible for funding via CalRecycle. The state will not
be able to meet its 75% diversion goal by 2020 if K-12 schools are
not participating, given that school districts are often the
largest single generator of waste in many communities – upwards of
5% of municipal waste – and generate more than 764,000 tons per
year.  AB1826 requires commercial-scale composting, including
schools. In April 2016, the law requires that schools that generate
more than 8 cubic yards of organic waste per week must arrange for
composting (and regulations tighten the targets in subsequent years
to achieve 75% diversion by 2020). Yet, current and proposed grant
programs for waste reduction and composting of organics through
CalRecycle exclude K-12 schools. Investing in recycling and
composting at K-12 schools is leveraged because children bring
these habits home and teach and motivate their parents and
community members to do so, as well. Schools cannot comply with
AB1826 and AB32 diversion requirements if they cannot access
funding; and community diversion requirements cannot be met unless
school districts participate. The “Waste as a Resource” section on
p. 44 should include source reduction strategies, in addition to
the resource recovery infrastructure strategies and not only
anaerobic digestion projects. Figure 16 “Reduce Methane Release
from Organic Waste” should include a bullet point under “Organic
Waste” to “Support infrastructure needed for source reduction and
organics recycling/composting” and should also include school
districts and LEAs in the list of “Potential Recipients.”

4. Include Schools in Low-Carbon Water System and Water
Conservation (p. 34-36 and Figure 14) – Schools have a lot of
acreage and grass and can be large water-users. If schools and LEAs
are not participating in water conservation efforts, it will be
difficult to achieve the target to lower urban water usage 20%
below 2005 levels by 2020 (Figure 13, p. 35). Improving water
conservation and increasing permeable surfaces on school grounds
can contribute to recharging groundwater, reducing stormwater
runoff, and saving water and energy through decreased water demand.
The State Water Board’s Drought Response Outreach Program for
Schools (DROPS) was highly successful and over-subscribed.  The
DROPS program should be renewed, perhaps via GGRF allocations; it
was previously funded via Propositions 13, 40, and 50; there are
not plans currently to renew the DROPS program. Figure 14 (p. 39)
should include under “Low Carbon Water System” a bullet point:
“Support urban water conservation and increased stormwater capture”
and include school districts and LEAs in the list of “Potential
Recipients.”

5. Include Schools in Transportation and Sustainable Communities
(pp. 32-34 and Figure 12) – From Safe Routes to School: “Within the
span of one generation, the percentage of children walking or
bicycling to school has dropped precipitously, from approximately
50% in 1969 to just 13% in 2009. In 2009, American families drove
30 billion miles and made 6.5 billion vehicle trips to take their
children to and from schools, representing 10-14 percent of traffic
on the road during the morning commute. Returning to 1969 levels of
walking and bicycling to school would save 3.2 billion vehicle
miles, 1.5 million tons of carbon dioxide and 89,000 tons of other
pollutants—equal to keeping more than 250,000 cars off the road for
a year.”  Given the heavy traffic moving children to school each
day, we recommend that greater priority be made for clean school
buses under “Advanced Vehicle Technology” in Figure 12 (p. 33) and
that school districts and LEAs be included as “Potential
Recipients.” Also, we recommend that “sustainable school
strategies” and “transit-oriented schools” be included under
“Sustainable Communities and Transportation Infrastructure” in
Figure 12 and that school districts and LEAs be included as
“Potential Recipients.”

6. Include Schools in Sustainable Communities, “Neighborhood
Scale,” Community Centers, and other frameworks for integrated
approaches to implementing climate action plans – Many public
comments on the Investment Plan have recommended including
strategies and mechanisms to reduce the barriers for integrated and
comprehensive projects. This is particularly relevant for K-12
schools, where integrated projects with maximum benefits could
include active transportation, cool roofs, water/energy nexus,
green infrastructure, waste reduction, tree planting, and asphalt
removal/permeable surfaces. However, needing to apply to multiple
agencies for separate grants creates silos and tremendous barriers
that limit these projects. Furthermore, K-12 school districts and
LEAs are not considered eligible to apply to many of the existing
grant programs funded via AB32. We recommend that ARB develop
coordinated mechanisms to streamline applications for integrated
projects and include K-12 school districts as eligible applicants.
This could include establishment of a “Healthy & Sustainable
Schools” integrated grant program for school-based climate action
projects that would align with the California Department of
Education’s existing Green Ribbon Schools award and recognition
program (http://www.cde.ca.gov/ls/fa/sf/greenribbonprog.asp). This
recognition program application includes metrics for energy and
water use, waste generation and diversion, carbon footprint,
outdoor landscaping and other relevant items. California Green
Ribbon School awardees are exemplary models of integrated
sustainability programs and are diverting upwards of 50% of their
waste, reducing their carbon footprints 10-30%, promoting transit
and Safe Routes to Schools, creating green schoolyards and green
infrastructure, saving water and energy, and engaging students in
hands-on sustainability education and behaviors that ripple
throughout the community. Our September 1, 2015 letter provided
specific examples of the tangible and multiple benefits that
sustainable, green schools are generating, such as the 2015 Green
Ribbon awardees, several of which are schools serving disadvantaged
communities. California has 1,000 school districts and 10,300
public schools with huge potential to save millions of tons of
greenhouse gases per year.

Other options for streamlining the application process for
integrated projects could include establishing an inter-agency
coordination mechanism and ensuring that K-12 school districts are
eligible. We also support efficient and innovative financing
mechanisms, including revolving loan funds and state green
development banks, to extend the utility of GGRF proceeds, as
outlined in the Investment Plan (p. 29).

The 25 organizations and individuals signing this letter,
representing nearly all 1,000 school districts in California,
support reducing the carbon footprint and improving the
sustainability of K-12 school buildings, grounds, and operations;
promoting healthy, resilient communities; and teaching
environmental and outdoor education and climate literacy. We
believe that sustainable schools and environmental literacy are
fundamental to California’s health, prosperity, and security.
Investing in greenhouse gas reduction projects at schools will help
solve the growing climate problems we face now, while also
preparing our children to be the environmental leaders and engaged
community members of tomorrow. Thank you for your consideration of
our comments to include schools as part of California’s solution
for mitigating climate change.

Sincerely,


 
Deborah Moore, Executive Director 
Green Schools Initiative
Berkeley, CA
deborah@greenschools.net

 
On behalf of:

Nancy Chaires Espinoza, Legislative Representative
California School Boards Association
Sacramento, CA
nchaires@csba.org 

Shayne Silva
California State PTA
Sacramento, CA
legislation@capta.org

Ian Padilla, Legislative Advocate
Coalition for Adequate School Housing (C.A.S.H.)
Sacramento, CA
ipadilla@m-h-w.com

Bill Orr, Executive Director
Collaborative for High Performance Schools (CHPS)
Sacramento, CA
borr@chps.net

Craig Cheslog, Co-Director, VP, California Policy
Common Sense Kids Action
San Francisco, CA
ccheslog@commonsense.org

Anna Ferrera, Executive Director
School Energy Coalition
Sacramento, CA
aferrera@m-h-w.com

Christos Chrysiliou, Director of Architectural & Engineering
Services, Facilities Services Division
Los Angeles Unified School District
Los Angeles, CA
christos.chrysiliou@lausd.net

Nik Kaestner, Sustainability Director
San Francisco Unified School District – A California Green Ribbon
School District-Silver
San Francisco, CA
KaestnerN@sfusd.edu

Anthony W. Knight, Superintendent
Oak Park Unified School District – A National Green Ribbon School
District
Oak Park, CA  
TKnight@oakparkusd.org

Jeff Vincent, Deputy Director
Center for Cities and Schools
University of California-Berkeley
Berkeley, CA
jvincent@berkeley.edu

Pauline Souza, Partner, Sustainability Director
WRNS Studio, Architect
National Green Schools Committee Chair – USGBC/Center for Green
Schools
San Francisco, CA
psouza@wrnsstudio.com

 

Paul Chapman, Executive Director
Inverness Associates
Berkeley, CA
pchapman5@gmail.com

Arden Bucklin-Sporer, Executive Director
Education Outside
San Francisco, CA
arden@educationoutside.org

Anne Kelsey Lamb, Director
Regional Asthma Management & Prevention (RAMP)
Oakland, CA
anne@rampasthma.org

Zenobia Barlow, Co-Founder & Executive Director
Center for Ecoliteracy
Berkeley, CA
zenobia@ecoliteracy.org

Candice Dickens-Russell, Director
Environmental Education
TreePeople
Beverly Hills, CA 
crussell@treepeople.org
 
Sharon Danks, CEO
Green Schoolyards America
Berkeley, CA
sharon@greenschoolyardsamerica.org


Will Parish, Founder & President
Ten Strands
San Francisco, CA
wparish@tenstrands.org

Leslie Tamminen, Director
Seventh Generation Advisors
Los Angeles, CA
leslie.tamminen@gmail.com
 
Mary Kimball, Executive Director
Center for Land-Based Learning
Winters, CA
mary@landbasedlearning.org

Adrian Almquist, Garden Programs Manager
Community Grows
San Francisco, CA
Adrian@communitygrows.org

Casey Poldino, Zero Waste Specialist
County of Marin
San Rafael, CA
CPoldino@marincounty.org

Susan Silber, Program Director
Nature’s Voices Project
Berkeley, CA
naturesvoices@gmail.com

Christiane Parry, Public Education Manager
California Coastal Commission*
San Francisco, CA
Chris.Parry@coastal.ca.gov


* Affiliation for identification purposes only