Comment Log Display

 


August 31, 2015

Mary D. Nichols, Chair
California Air Resources Board
1001 "I" Street 
Sacramento, CA 95814

Re: Cap-and-Trade Auction Proceeds Second Investment Plan Draft
Concept

Dear Ms. Nichols,

Thank you for the opportunity to comment on the Cap-and-Trade
Auction Proceeds Second Investment Plan Draft Concept Proposal
(Investment Plan). The Sierra Cascade Land Trust Council is a
network of land trusts that provides a collective voice for this
diverse region by fostering collaboration to protect the natural,
historic and agricultural resources for present and future
generations. 

We would like to provide comments on several areas of the
Investment Plan, particularly spanning the Transportation and
Sustainable Communities and Natural Resources and Waste Diversion
concepts. Specifically, we propose a new program to fill a gap we
perceive in current GGRF investments and we also recommend that ARB
direct more support for several existing programs with great
greenhouse gas reduction potential. Note that below references to
current levels of investment are from 2014/15. 

	Building Sustainable Communities - the Case for
Carbon-Smart Green Infrastructure
The Strategic Growth Council’s Affordable Housing and Sustainable
Communities program supports housing or transit-oriented
development to reduce greenhouse gases but does not lead to the
development of complete carbon-smart communities. A multi-benefit
green infrastructure approach to community development is missing
in the current GGRF expenditure plan, and it is not incentivized
under existing programs. These strategies are critical to the
long-term sustainability of our state - they will help us meet our
2030 and 2050 climate goals, while tackling other critical
statewide issues like the drought.
We propose the development of a new Carbon-Smart Green
Infrastructure program as an essential strategy to greening our
cities, and incentivizing innovative, carbon-smart development. We
need to make our communities more climate resilient through a
connect, cool, absorb, and protect approach to green alleys, school
yards, parks, riverways and greenways - greenhouse gas reduction
strategies that are well documented by research (see Attachment A
for background and details of proposed program). Through innovative
development and restoration, these projects reduce greenhouse gases
in our communities by providing multiple benefits – enhancing the
tree canopy, lowering VMTs, reducing energy usage from water
conveyance and treatment, and decreasing the urban heat island
effect. The Investment Plan stresses a need for integrated projects
that support energy and transportation solutions, smart growth, and
urban forestry within communities (Investment Plan, III.E, p. 5) –
a green infrastructure program would cut across GGRF investment
areas while catalyzing much needed integration at a local level,
incentivizing local jurisdictions to coordinate across agencies for
investment decisions and planning. Investments can be targeted
toward our disadvantaged communities, where they are needed most. 


The 2012 Urban Greening for Sustainable Communities Program,
overseen by SGC and administered by Natural Resources Agency is a
great example of a multi-benefit approach to building sustainable,
resilient, low-carbon communities. With the foundation and
infrastructure for the program already established, the state is
well on its way to adding this missing piece to the puzzle.
Revamping the 2012 Urban Greening Program will create a
crosscutting program to complement current investments in forestry,
wetlands, and other natural resources. We recommend this program be
funded through the GGRF, based on evidence showing the potential
these strategies have to play in statewide carbon reduction. We
recommend that ARB consider adapting the Urban Greening program to
become a vital and complementary tool for meeting and exceeding
GGRF goals. 

Recommendation – Create a 4-5% allocated new program for
Carbon-Smart Green Infrastructure by revamping the 2012 Urban
Greening for Sustainable Communities program through the Strategic
Growth Council and California Natural Resources Agency. 

Recommendations for Enhancing Existing Investments

➢	Increase funding to CALFIRE for urban and rural forest
conservation to 7-8%

•	The largest vehicle for greenhouse gas reduction through
large-scale carbon storage is the protection and management of
large tracts of intact forest. The world’s forests are estimated to
sequester up to 30% of annual global anthropogenic carbon
emissions.  
•	In California, approximately 113,000 acres of forest were
converted to other uses between 1969 and 1998. 
•	Protection of forests with conservation easements, with
management to maximize carbon storage, is essential to meeting our
greenhouse gas reduction goals.
•	Urban forestry in California sequesters 4.5 MMT of carbon
annually.  In San Francisco, it is estimated that the city's trees
sequester nearly 200,000 tons of carbon and filter 260 tons of
atmospheric pollutants each year.  
•	There is currently a $4.2 million allocation to CALFIRE’s Forest
Legacy program for forestland threatened by conversion. The initial
3-year investment plan does not represent the critical role forest
conservation plays in achieving our long-term greenhouse gas
reduction goals, and should be increased. The current $15.7 million
investment through CALFIRE in urban forestry projects should also
be increased. 

➢	Increase funding for agricultural conservation easements
and management incentives to 2%

•	Agricultural conservation easements are an essential tool to
store carbon, help cities combat sprawl and maintain working lands
close to where people live. With careful management, rangelands and
cropland sequester carbon in soils – through the growth of
vegetation and accumulation of organic matter.  Appropriate
incentives can help landowners achieve these results.
•	Agricultural lands provide a myriad of climate and public
benefits – food security, jobs, long-term carbon storage in soils,
and decrease of greenhouse gas production from long distance
commutes and food transportation.
•	In California, approximately 40,000 acres of working lands are
lost to development and other uses each year , particularly when
close to urban areas with rapid population growth and increasing
land value. Moreover, conversions of agricultural land to urban
development in California results in a 57 times increase in
greenhouse gas emissions per acre of land converted.  
•	The Strategic Growth Council’s Sustainable Agricultural Lands
Conservation Program is insufficiently funded at $4.75 million
annually, and should be increased. 

➢	Increase and broaden funding for wetland and watershed
protection and restoration to 3%

•	The ecological and economic benefits of wetlands are well
understood. Notably, wetlands have the ability to sequester and
store large amounts of carbon over long time periods. 
•	California has lost 91% of wetlands since the 1780s (compared to
53% for the lower 48 states). 
•	Protection of wetlands on private land, in combination with
restoration, is essential to ensure durability of restoration
efforts and to realize the greenhouse gas benefits of wetland
conservation. The Department of Fish and Wildlife‘s Wetlands
Restoration for Greenhouse Gas Reduction program funds restoration,
but does not enable the permanent protection of wetlands. Funding
for this program should be increased and expanded to include
conservation easement or fee title acquisition of key watershed and
wetland areas for durability.

➢	Remove barriers to funding for disadvantaged communities

Currently many GGRF programs are not set up to be user-friendly for
communities with fewer resources, less capacity, or experience in
applying for highly competitive public funds. The Investment Plan
stresses that disadvantaged communities should be able to compete
themselves for GGRF funds (III.B, p.4). To be accessible by
communities hit first and worst by climate impacts, we recommend
the following:

Technical assistance should be provided early in the process in
order to assist applicants in making their projects more
competitive. This includes technical support for the required
greenhouse gas calculations to ensure broad participation in the
program. This will also assist ARB and agencies implementing GGRF
programs to ensure consistency with greenhouse gas quantification
as well as in gathering defensible, and comparable data across the
state.
•	Bonus points should be awarded for applications that demonstrate
a multiple-benefits strategy;
•	Prioritization of qualitative processes to support the success of
applicants who need additional direction, information, and
technical assistance;
•	Incentives for grant applicants to directly engage members of
disadvantaged communities in project selection, design, and
prioritization.
•	The timeline between the NOFA and the concept proposal deadline
should be increased to 60 days to provide more lead time to
applicants.
•	Funding, through set-asides within GGRF programs, for planning,
decision-making tools, and community engagement, with the intent
that the planning would lead to projects resulting in greenhouse
gas reduction.
•	Set-asides in GGRF programs for rural disadvantaged communities.

•	Matching funds requirements should be waived for projects located
within disadvantaged communities.
•	Nonprofits should be eligible applicants for these funds – in
order to increase the variety of projects that are brought forward
and to encourage a greater diversity of partnerships.


Sincerely,
 
Ellie Routt
President, Sierra Cascade Land Trust Council


Attachment A: The Creation of a Carbon-Smart Green Infrastructure
Program

Here we provide relevant research to support the development of a
Carbon-Smart Green Infrastructure Program as well as
recommendations for the revision of the 2012 Urban Greening for
Sustainable Communities Program.

A carbon-smart green infrastructure approach increases mobility
options in communities to ensure transportation mode shifts,
capture and cleanse our water, reduces energy usage connected with
urban heat island effect, and sequesters greenhouse gases through
natural infrastructure. These strategies provide important
co-benefits for our communities by cleaning the air, promoting
active transportation, and reducing heat related illness and death,
providing outdoor recreation opportunities, and increasing
community connection. Applicants will be asked to carefully project
the effectiveness and cost-benefits of their approach for carbon
reduction and measure actual performance post-implementation. This
will increase the impact of funding through this program by helping
to advance knowledge within the field of carbon-smart green
infrastructure while also helping to promote replication.  

A Carbon-Smart Green Infrastructure Program seeks proposals that
utilize a multiple-benefit approach to maximize carbon gains and
other co-benefits from green infrastructure. To help guide
applicants, this program has five base layers of carbon-related
green infrastructure benefit for applicants to consider. The
scientific framework is as follows:

Connect:  In 2012, transportation emissions represented 37% of
California’s total emissions, with more than 90% attributable to
on-road vehicles.  Personal passenger vehicles account for 78% of
emissions from this sector.  For many suburban and exurban
communities, transportation is responsible for an even higher
percentage of emissions.  California communities have many
opportunities to reduce on-road vehicle use by leveraging green
infrastructure investment to help fill gaps in active transit
networks. While California communities are leading in bicycle
commuting, such as Davis at a nationally leading 24.5% of its
population, many communities have room for active transit growth. 
Los Angeles is second nationally for the raw number of daily
cyclists on its streets, but this number represents only 1.5% of
the city’s population.  Other major cities, including San
Francisco, are over 3% bicycle commuting.  One study found that
achieving a 50% mode shift to active transit for short trips (less
than 1.5 miles) and medium trips (1.5 to 5 miles) in Bay Area
communities from the 2000 baseline would reduce carbon emissions by
14.5% while also producing a 14% reduction in cardiovascular
disease and diabetes.  Green infrastructure proposals under this
program should demonstrate how the proposed activities will promote
active transit by increasing user accessibility and decreasing
safety concerns. Proposals should use a research-based methodology
such as The Trust for Public Land/ICF International carbon benefits
quantification model to calculate the specific carbon benefits and
air quality that are projected from the green infrastructure being
proposed. Other data should also be used to demonstrate the
co-benefits of the project, such as spatial data showing the
demographic, social, and health-related risk factors for adjacent
populations (affordable housing developments, etc.) to the new
active transit connections being created. These data should be used
to show the impact of the project on transit equity, economic
benefits of enhanced transit alternatives, and health benefits. The
Connect strategy supports the State’s goal of reducing petroleum
use in cars  

Cool:  Energy use for cooling buildings is a major segment of
carbon emissions in communities during warm weather months. Energy
use is elevated 5-10% during peak summer periods due to the urban
heat island effect.  Shade trees and other heat island reduction
measures can reduce building emissions by 5-20%.  An analysis by
the University of California at Berkeley’s Heat Island Group
developed in response to the passage of A.B. 32 estimated that full
implementation of a “cool communities” strategy using green
infrastructure and closely related approaches could reduce
California emissions by 4 million metric tons of carbon dioxide
equivalent per year.  This is equivalent to 5% of the 80 million
tons in annual reductions required for the State of California to
meet is 2020 target under A.B. 32. Additional carbon gains can be
found in direct sequestration by urban trees and other vegetation
used to reduce urban heat islands. Urban forests account for
approximately 8% of forest-based sequestration in the U.S.
annually. Green infrastructure proposals under this program should
demonstrate how the proposed activities will advance heat island
reduction, including how siting and design of the proposed green
infrastructure will maximize cooling of buildings within the
proposal area for reduced carbon emissions. Other carbon benefits
through direct sequestration should also be quantified. Proposals
should use a research-based tool such as the U.S. Forest Service
I-Tree model to calculate the specific heat island benefits of
proposed green infrastructure. Other data can be used to
demonstrate the impact of the project, such as spatial data showing
the magnitude of the urban heat island being addressed and
information on demographic, social, and health-related risk factors
for adjacent populations. The Cool strategy support the State’s
goal of reducing energy use in homes and businesses.  

Absorb:  Energy use for imported water supplies and wastewater
treatment represent an important segment of California’s carbon
emissions. The State Water Project is the single largest energy
user in the state, and 20% of electric use in the state is
attributable to water.  Deploying green infrastructure to manage
stormwater on-site through an integrated water management approach
increases potential for communities to use local water supplies
through aquifer recharge. Green infrastructure that promotes
infiltration also lessens the water load for treatment, and thereby
reduces associated energy use and carbon emissions. The City of Los
Angeles and Los Angeles County, among other actors in California,
have assessed the potential water and energy savings of an
integrated water management approach.  One recent analysis
concluded that the City of Los Angeles has potential to meet 30-45%
of its water supply needs by implementing a full green
infrastructure plan, such as the activities envisioned as part of
the Los Angeles Department of Water and Power’s Stormwater Master
Plan.  The City of Los Angeles has set a goal in its Sustainability
Plan to reduce imported water purchases from the State Water
Project and Metropolitan Water District of Southern California 50%
by 2025. ICF International analysis found that the carbon footprint
of the Metropolitan Water District imports to Los Angeles during
one year (2007) was 548,000 metric tons of carbon dioxide
equivalents. If LID techniques were applied in southern California
and the San Francisco Bay area, between 40,400 MG and 72,700 MG per
year in additional water supplies would become available by 2020.
The creation of these local water supplies would result in
electricity savings of up to 637 million kWh per year and annual
carbon emissions reductions would amount to approximately 202,000
metric tons by offsetting the need for inter-basin transfers and
desalinated seawater.  Statewide, for instance, water-related
energy use in 2001 was estimated at 48 million MWh (or 48 thousand
GWh) of electricity, plus 4.3 billion Therms of natural gas and 88
million gallons of diesel fuel. This energy use results in
approximately 38.8 million metric tons of carbon dioxide emissions
annually.  The carbon emissions embedded in California’s water as a
result of these energy demands is equivalent to the carbon
emissions of 7.1 million passenger vehicles, and would require
approximately 9 million acres of pine forest to offset California’s
water-related carbon footprint.  Green infrastructure proposals
under this program should demonstrate how the proposed activities
will advance energy savings through integrated water management,
including specific description of the volume of water impacted by
the proposal and how the water management achieved will impact
existing water management activities and the energy impact of those
activities.  Proposals should utilize a research-based model such
as the Local Government Commission’s tool to demonstrate the
aggregate energy impacts and related carbon savings from the
integrated water management benefits that will be achieved through
the proposal. The Absorb strategy supports the State’s goals to
capture and save water. 

Protect:  Consistent with California’s Climate Action Plan,
proposals should integrate explicit climate resilience
considerations into green infrastructure design and development.
California-relevant considerations include vulnerability of key
populations to extreme heat events, repetitive loss flooding from
increasingly intense rainfall patterns, seismic threats, and
increased risk of coastal and riverine inundation. Additional
credit will be given to applications that reflect consideration and
pursuit of these adaptation co-benefits as part of carbon-oriented
green infrastructure. Applicants will be asked to use diverse data
sources to demonstrate the risk being addressed and the related
resilience benefits of the green infrastructure proposal.  

Disadvantaged Communities:  Further, the consideration of
California’s most impacted communities should be integrated into
the design considerations for each plan. Which populations will
most greatly benefit from the economic benefits of energy savings
and increased access to active transit? Which populations are most
at risk from pollution, extreme heat, and natural disasters?
Low-income populations are disproportionately impacted by energy
costs as a percentage of household income, and will uniquely
benefit from the potential for economic savings generated by
reduced energy use. Further, these communities will uniquely
benefit from reduced vulnerability to climate risks like extreme
heat and household flooding given their reduced resources for
dealing with these challenges, and the presence of elevating risk
factors such as health conditions that exacerbate heat related
illness. Applicants must detail the specific communities served,
connect to affordable housing residents where appropriate, and show
the direct and indirect climate benefits to these communities from
the proposal.  



Carbon-Smart Green Infrastructure: Revising the 2012 Urban Greening
Program
This funding is intended to engage the capabilities of experts from
across California and the nation to advance greater carbon
efficiency through green infrastructure in California communities,
with a particular emphasis on supporting strategies that are
implemented at larger scales, such as a neighborhood or watershed,
and that can be replicated across that community or even the state.
These replicable “super projects” represent green infrastructure
typologies such as green alleys that combine multiple benefits and
have potential application within a variety of different California
communities and geographic contexts across the state, and are able
to leverage a diversity of local, state, and federal funding
through the multiple benefits approach. As such the program has a
planning and development component to invest in carbon-smart
innovation and incentivize research and decision-making tools to
inform investments that provide the greatest multiple-benefit
return.  

The 2012 Urban Greening Project and Planning Grant Program defined
urban greening as a community-based effort to plan, plant, care,
and manage flora, structures and spaces, which lead to increased
forest canopy, reduced stormwater runoff, improved air and water
quality, energy conservation, open space and ultimately, more
sustainable communities. The program was administered through the
Natural Resources Agency in consultation with the Strategic Growth
Council, to ensure optimal integration of sustainable community
strategies including transportation, affordable housing and
low-income transit-oriented development projects. Guidelines were
developed through a cross-functional effort between Public Health,
DWR, CALFIRE, DFW, Caltrans, the Strategic Growth Council, and
regional boards, and the Strategic Growth Council was the final
decision-maker on grant applications. 

The 2012 Urban Greening Program description: because of the
built-out nature of California's urban areas, the Urban Greening
for Sustainable Communities Program provides funds to preserve,
enhance, increase or establish community green areas such as urban
forests, open spaces, wetlands and community spaces (e.g.,
community gardens). The goal is for these greening projects to
incrementally create more viable and sustainable communities
throughout the State.

The 2012 Urban Greening Project and Planning Grant Program eligible
projects: 
•	Use natural systems, or systems that mimic natural systems, or
create, enhance, or expand community green spaces.

•	Provide multiple benefits including, but not limited to
o	Decrease in air and water pollution
o	Reduction in the consumption of natural resources and energy
o	Increase in the reliability of local water supplies
o	Increased adaptability to climate change

•	Be consistent with the State's planning policies specific to the
following statewide priorities 
o	Promote infill development and invest in existing communities
o	Protect, preserve and enhance environmental, agricultural and
recreational resources
o	Encourage location and resource efficient new development
 
•	Reduce; on as permanent a basis that is feasible, greenhouse gas
emissions consistent with the California Global Warming Solutions
Act of 2006.