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Comment 68 for Public Input on Cap-and-Trade Auction Proceeds Second Investment Plan (investplan2-ws) - 1st Workshop.


First Name: Kerri
Last Name: Timmer
Email Address: dmadson@sierrabusiness.org
Affiliation: Sierra Business Council

Subject: Sierra Business Council Comment on Draft C&T Auction Proceeds Second Investment Plan
Comment:
November 13, 2015

Chairwoman Mary Nichols
California Air Resources Board
1001 I Street
Sacramento, CA 95814

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

Dear Chairwoman Nichols, Board Members, and Staff:

Sierra Business Council (SBC) – a non-profit network of more than
4,000 business, local government and community partners working to
foster vibrant, livable communities in the Sierra Nevada – is
pleased to provide comments on the Draft Cap-and-Trade Auction
Proceeds Second Investment Plan.

We appreciate the Draft’s inclusion of the following:
  
1)	Focus on increased rural participation, especially in the
forestry, waste diversion and sustainable communities sectors,
including the proposal for a dedicated funding stream for rural
areas in the Affordable Housing Sustainable Communities (AHSC)
program. Investments in rural resource areas recognizes the
contributions made by such areas to the rest of the state and helps
to address the Governor’s goals, such as increasing investment in
land stewardship, building resilience in our natural systems,
appropriately valuing the services provided by our ecosystems, and
increasing the use of biomass as a local, alternative energy
sources.

2)	Emphasis on forest management, both as a complement to
protection from conversion to more carbon-intensive uses and a
means of reducing wildfire emissions, increasing carbon storage,
and achieving additional co-benefits, such as: reducing other
harmful pollutants, improving public health, providing jobs that
support local economic development, and improving the
sustainability of our energy and water systems for all users.

3)	Recognition of the need to start now to reduce risks to the
landscape, decrease emissions and increase carbon storage to meet
medium- and longer-term greenhouse gas (GHG) reduction goals. While
forest restoration, waste diversion and fire risk reduction
activities may temporarily increase emissions, those activities are
necessary to set the stage for long-term carbon storage and
emission reductions beyond 2020.

4)	Offering the ability to use Greenhouse Gas Reduction Fund (GGRF)
funds on federal lands.

5)	Additional outreach and technical assistance to disadvantaged
communities, including rural disadvantaged areas.

6)	Urban greening to increase carbon storage and moderate heat
effects in the built environment.

7)	Use of conservation easements on working lands (agricultural and
forest) to protect existing carbon and reduce conversion to
higher-emitting uses.


We offer the following suggestions for the Draft Cap-and-Trade
Auction Proceeds Second Investment Plan:

1)	Increase the Affordable Housing Sustainable Communities’ (AHSC)
rural program from 10% to 20% to bring it in line with the TCAC
program upon which the definition of “rural” is modeled, and in
recognition of the tremendous need for protection and management of
our natural resources – particularly in the headwaters of the
state’s primary water system.

2)	At a minimum, double Greenhouse Gas Reduction Fund (GGRF)
investment in the Natural and Working Lands sector, including a
concomitant increase in the non-urban forestry portion of that
sector, in recognition of the priority the Governor and his
Administration have placed on forest carbon capture and
sequestration, reduction of forest-related short-lived climate
pollutants, and organic waste diversion to create bioenergy and
other products.  

3)	Use GGRF funds to establish landscape-level demonstrations where

individual projects within the demonstration footprint are designed
to begin developing a regionwide GHG/carbon inventory, set of
baseline assumptions, GHG/carbon quantification methodologies, and
a common approach to GHG/carbon accounting that considers
project-specific co-benefits, lifecycle accounting, and integrated
benefits across sectors (e.g. waste diversion, renewable energy,
SCS, transportation, climate action plans).

4)	Find a different tool or overlay additional criteria for
identifying disadvantaged communities in rural areas of the state.
While we understand the obvious need to focus resources on the
state’s most disadvantaged communities, we continue to be concerned
about the use of Cal Enviroscreen as the sole mechanism for
identifying those communities. The Enviroscreen criteria focus
primarily on urban metropolitan areas due to the emphasis on
pollutants or other criteria that either are not measured in or do
not affect rural communities, especially those located in the
Sierra. Yet many of our communities are disadvantaged based on
below-average household incomes and health impacts from water
contamination and air pollution from wildfire and other “non-urban”
sources. 

Specifically, we suggest incorporating the criteria defining
Economically Distressed Areas as defined in the 2014 water bond
(Prop. 1), which includes “a municipality with a population of
20,000 persons or less, a rural county, or a reasonably isolated
and divisible segment of a larger municipality where the segment of
the population is 20,000 persons or less, with an annual median
household income that is less than 85 percent of the statewide
median household income, and with one or more of the following
conditions as determined by the department [Department of Water
Resources]: (1) Financial hardship, (2) Unemployment rate at least
2% higher than the statewide average, (3) Low population density.”

5)	Identify supplementary delivery mechanism for GGRF funding in
addition to Metropolitan Planning Organizations (MPOs). We support
the Sustainable Communities Strategy efforts, but the rural areas
of the state largely lack MPOs, or if they do have them, they are
typically county-wide and do not focus on the rural portions of the
county where GHG reduction gains can be made by employing similar
compact growth, transportation-related and natural and working
lands improvements in rural areas. In fact, studies such as the
2015 Boston University “Cities, traffic, and CO2: A multidecadal
assessment of trends, drivers, and scaling relationships” [Conor K.
Gately, Lucy R. Hutyra, and Ian Sue Wing], indicate that rural
investment in transportation yields even more benefit than urban
given the long distances rural residents typically travel to access
basic services and destinations.  

We recommend development of a companion rural mechanism to achieve
vehicle miles traveled (VMT) reduction goals and co-benefits in
rural communities. More than 4 million people live in rural areas
of the state that are not covered by MPOs and, therefore, are not
required to develop Sustainable Communities Strategies for
transportation and housing. This investment plan needs to create
better options for more transportation-efficient rural communities
across the state, including those not located within MPO areas. 


SBC appreciates the Air Resources Board’s recognition, in advance,
of many of these issues, as presented at the workshops earlier this
month. We would like to work with you, especially related to
addressing rural issues, and look forward to participating in the
continuing discussion about how to ensure the second Cap-and-Trade
Auction Proceeds Investment Plan is meaningful to all Californians
and achieves the state’s post- 2020 climate goals.

All best,
 
Kerri Timmer
Government Affairs Director

Attachment: www.arb.ca.gov/lists/com-attach/73-investplan2-ws-UiFWMgdlWVUFYARr.pdf

Original File Name: SBC Comment on CARB Draft Second Investment Plan_2015_11_13.pdf

Date and Time Comment Was Submitted: 2015-11-13 14:59:32



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