Comment Log Display

Dear Chairman Mary D. Nichols and Executive Officer Richard Corey,

Thank you for the hard work that ARB staff has done to make the
Auction Proceeds Triennial Investment Plan for 2016-2019 possible.
We are writing as a coalition of groups serving the Sacramento
Region to recommend changes to the 2016-19 draft Investment Plan.
As a region, we have formed a coalition of public agencies and
organizations working together to support and advance applications
for key Greenhouse Gas Reduction Fund grants, and have complimented
that effort with a robust public engagement process in
disadvantaged communities. Our comments are directly informed by
those efforts.

Expansion of Energy and Weatherization Programs

Funds for the Energy Efficiency and Low-Income Weatherization
Program are currently limited to income eligible, single-family
households in target census tracts. Since implementation of this
program is spread across several grantees, an income-eligible
household that receives one program benefit is not automatically
enrolled to receive other program benefits from the Urban Forestry,
Low-Carbon Transportation, WET, and Water Efficiency Programs.
Further, funding does not allow grantees to make home improvements
conducive to the goals of the program, like repairing a roof so
solar panels can be installed, or in lieu of solar installing a
cool roof. Finally, the program does not include business owners or
community centers in targeted neighborhoods, even though the
sustainability of those buildings is critical for the
environmental, social, health, business resiliency and economic
benefits they can provide to those neighborhoods. 
	Programs should create project teams that can
automatically enroll income-eligible households in all program
benefits as appropriate. The project team should consult with MPOs
and local government officials to ensure maximum efficiency in
program delivery, with the opportunity to leverage other local
resources for improved co-benefits and outcomes.
	Funds should be allowed to make home improvements (such as
a roof repair or insulation replacement) related to energy
efficiency, weatherization, and tree planting. Funding should also
be able to be used for technologies like cool roofs, radiant
barriers, wind energy, and gray water systems.
	Multi-family housing units within targeted census tracts
should be eligible for all programs.
	Small businesses and community centers  in targeted census
tracts should also be eligible if they can demonstrate that the
owners, at least one of their employees, or at least 10% of their
patrons live in the surrounding neighborhood. 
	If nearby homes are not suitable for solar panels,
businesses and community centers can have them installed to
generate renewable energy to serve the facilities’ electricity
needs as well as the needs of surrounding income-eligible
households. Solar panels could also be allowed on vacant land or to
cover parking.

Inclusion of Streetscape Improvements

Many residents of disadvantaged communities will attribute poor
streetscapes as one of the primary reasons they do not walk, bike,
or take transit to their destinations. In Sacramento, as in many
regions throughout the state, our air quality is heavily impacted
by those transportation choices. There are not sufficient funds
dedicated to streetscape improvements as larger infrastructure
projects generally take priority. Streetscape projects are
low-budget and high-impact, providing great opportunities for
community involvement. 
	Funding for streetscape improvements to improve the
ability to safely walk and bike, while calming traffic, should be
allocated to metropolitan planning organizations throughout the
state. These funds can be used for land acquisition, LED lighting
installations, “Complete Street s” construction, tree planting and
drought-tolerant landscaping, road overlay (as related to slowing
traffic, adding and/or separating bike lanes, road diets and
increasing alternative transportation), bus stop infrastructure,
and bike parking facilities.

Inclusion of Urban Agriculture

Urban agriculture is growing in popularity in our state as a viable
means to increasing access to healthy food while providing people
with a source of income. The City of Sacramento, along with several
other jurisdictions, has recently passed an urban agriculture
ordinance to make growing and selling food easier for residents.
	The Urban Forestry program should be expanded and clearly
allowed to fund creation of new and maintenance/expansion of
existing urban agriculture spaces. All sources of carbon reduction
should be taken into account in project scoring criteria, not just
carbon sequestration.

Expansion of EV Charging Station Resources

Electric Vehicle Charging Stations are expensive to install in
existing communities, in particular disadvantaged communities and
multi-family complexes. While a new incentive program for
businesses was just released, the cost for infrastructure and the
chargers is very expensive and not cost-effective for most small
businesses. Cities and Counties can advance more public charging
stations in key locations if there were incentive funds, rather
than loans, to offset these costs.
	Funding for Electric Vehicle Charging Stations should be
expanded to include grants for infrastructure and charging station
equipment, particularly in disadvantaged communities and
multi-family units. New affordable multi-family developments and
business complexes should be particularly targeted for electric
vehicle charging to avoid retrofit costs in the future.
	There should be special measures taken to ensure that
access to EV fleet and charging station monies are available to
small businesses.
	Funding for electric vehicle charging stations in
multi-family housing should be an eligible element of this program,
especially in existing multi-family low-income housing projects.

Green Jobs as a Priority Co-Benefit

The source of much pollution in our state rests on the fact that
our industries are not all “green.”  To address this, California
needs to put a high priority on training people to start careers in
green industries. As awardees administer their various grant
programs, they should be required to train and employ residents
from targeted communities to ensure the maximum benefit of that
investment.
	All agencies and grant awardees must demonstrate that they
train and employ residents of targeted communities in green jobs as
much as possible. To the extent feasible, awardees should explain
how jobs for these residents will be sustained after the project is
complete. For example, if a project will build affordable housing,
the applicant should write its budget to allow for the training and
employment of residents to build that housing, and address how
residents will continue to be employed either on-site, in future
projects, or in other positions.

Ensuring Equitable Access to Funds by Creating Better
Accountability

SB 535 prioritizes funding to the most disadvantaged communities in
our state, but competition for those funds may inadvertently
prevent funding from going to communities with the most need.
Competition also discourages collaboration and transparency, which
makes it hard for community members to track and influence
applications. Assembly Bill 32 requires that public and private
investment be directed toward the most disadvantaged communities in
California to provide an opportunity for community institutions to
“participate in and benefit from statewide efforts to reduce
greenhouse gas emissions.” Measures should be taken to ease public
access to this process.
	The ARB and administering agencies should require at least
three weeks for review of new policy documents before closing
public comment or holding public meetings.
	Administering agencies should post all grant review
criterion and applications received on one, central website to
promote transparency and public engagement.
	All agencies administering GGRF should provide technical
assistance to community based organizations to promote the
engagement of disadvantaged communities. When necessary, ARB should
exercise its authority to distribute cap and trade revenues to fund
grants that will help agencies adhere to AB 32’s “participation”
requirement via agency- or board-level technical assistance.
Agencies should also make provisions to reduce or waive match
funding requirements for applicants that may not have the means to
provide that funding.
	Grant recipients should conduct data collection and report
on the realization of proposed project co-benefits. Data collection
should also be an eligible expense from grant funding. The ARB and
administering agencies should require applicants to provide the
contact information (in accordance with privacy considerations) for
residents within the census tract their project targets to
illustrate community support for the application, in addition to
outlining their community engagement process in the development of
the application. 
	The ARB and administering agencies should require
applicants to get at least one letter of support from the local
jurisdictions where the project will occur to ensure alignment with
local initiatives and planning efforts and delivery of a quality
project. 

Thank you for your time and consideration of these comments.

Sincerely,

Chris Brown, Organizer
350Sacramento

Elaine Hebert, President
Southside Park Neighborhood Association

James Shelby, President & CEO
Greater Sacramento Urban League

Jesse Reese, President
Meadowview Neighborhood Association

Linda Roberson, Park Planner and Urban Designer
Cordova Recreation and Park District

Matt Read, Director of Government Relations
Breathe California

Michael Blair, President
South Oak Park Community Association

Michelle Pariset, Organizer
Capital Region Organizing Project

Rachel Rios, Executive Director
La Familia Counseling Center

Rick Bettis, Natural Resources Director
League of Women Voters Sacramento County