Comment Log Display

September 1, 2015

Chairman Mary D. Nichols and Executive Officer Richard Corey
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Dear Chairman Nichols and Executive Officer Corey:

The Alliance of Regional Collaboratives for Climate Adaptation
(ARCCA) welcomes the opportunity to provide comments on the
Cap-and-Trade Auction Proceeds Second Investment Plan Draft
Concepts.

About ARCCA

ARCCA is a network comprised of existing regional collaboratives
from across California. ARCCA’s members represent leading regional
collaboratives that are already coordinating and supporting climate
adaptation efforts in their own regions in order to enhance public
health, protect natural systems, build economies, and improve
quality of life. Through ARCCA, member regional collaboratives have
come together to amplify and solidify their individual efforts, as
well as to give a stronger voice to regionalism at the state and
federal levels. ARRCA members share information among regions on
best practices and lessons learned; identify each region’s most
innovative and successful strategies; and then determine how these
strategies could be adapted to another region’s particular needs.
As a result, ARRCA bolsters the efforts of member regional
collaboratives and empowers those interested in forging new
regional partnerships. 

Current State of Affairs

California has been tremendously successful in developing and
executing mitigation strategies to respond to the challenge of
climate change. In recent months, the urgency and opportunity of
addressing climate change through accelerated mitigation and
adaptation activities have become even more clear, as Governor
Brown outlined in his recent Executive Order (B-30-15). We are
grateful to see the administration’s key principles and concepts
reflected in the current draft, especially those related to climate
impacts and resiliency. We are also very appreciative that the
guidelines recognize the importance of coordination with local
governments and rural communities. It is clear to us that ARB is
listening closely, learning from the experience of the first year
of GGRF funding and working to provide guidance that helps the
state and local participants realize the full intent of the
program. 

As you are aware, even the most effective reductions in emissions
would not be able to prevent further climate change impacts in the
state, given that global changes have already been set in motion.
Thus, undertaking climate adaptation strategies will be unavoidable
to reduce our risk and increase our capacity to respond to build
resilient societies and to foster sustainable development.
Additionally, an unprecedented degree of collaborative action
throughout California is critical to respond to climate change
quickly, effectively, and equitably. Climate change adaptation and
mitigation conversations must occur at scales above city and county
footprints to be relevant and most effective as an integrated,
landscape-scale approach; engage key stakeholders from all sectors
- urban and rural, public and private, from decision-makers to
implementers; and bridge the divide between California’s regions to
fully capture the critical role that rural communities play in
advancing climate adaptation and mitigation efforts. 

Recommendations

To realize success, we want to see the GGRF program, within the
limits allowed, empower local communities and regional entities in
all parts of the state - urban and rural -  and across sectors to
implement investments that strengthen the state’s overall economic,
environmental, and social resilience. Within this context, we offer
a few broad comments that might strengthen the ability of local
governments to participate in the program and meet our shared
goals. We encourage the ARB to:

1.	Prioritize adaptation and resilience at the state, regional, and
local levels to accurately convey the imperativeness of pursuing
adaptation and resilience strategies in conjunction with mitigation
strategies. Climate change is having, and will have, more
widespread impacts on California’s people, economy, and
environment, and steps must be taken to protect against climate
impacts that are already occurring. Because uncertainty is a strong
factor and climate change adaptation requires an iterative process
that needs to be informed on an ongoing basis, it is critical for
the state to escalate the importance of adaptation and resilience
by providing necessary support and resources. We recommend that the
ARB allocate funds for adaptation planning, as well as for
initiatives that aim to build resilience at all levels and across
all sectors.

2.	Adopt an inter-regional approach and framework for climate
change adaptation and mitigation that prioritizes collaboration and
cross-sectoral partnerships, especially with sectors that are not
as engaged but play a critical role in achieving state goals and
building California’s resiliency, such as the business sector.
Climate impacts will vary in severity and nature between regions,
as will each region’s ability to cope and approach to adapting,
making regional efforts more likely to have shared priorities,
common goals, and a more holistic impact that addresses the
region’s specific needs. Communities are already bound together at
a landscape-level scale by shared geography and mutual reliance on
resources that span across jurisdictions, such as watersheds,
forests, agricultural lands, rangelands, and grasslands. We
recommend that the ARB prioritize investment in projects that focus
on working within regions and across regions that also engage key
stakeholders from all sectors.

3.	Prioritize investments to support rural and underserved
communities to enable a wider population of communities to
participate in this program, especially for regions that steward
important resources that the state relies upon. The well-being of
all Californians is inextricably tied to the goods and services,
such as clean water, clean air, carbon storage, and recreation,
that are provided by resource-rich, rural areas; thus protecting
California’s rural areas, particularly the upper watershed, is
equally important to urban adaptation strategy and meeting
long-term urban sustainability goals. We recommend that the ARB
make greater efforts to acknowledge and leverage the value of rural
areas in achieving the state’s climate goals, and in engaging rural
and underserved communities more effectively and regularly to
empower action. We encourage the ARB to consider more substantive
guidance on technical assistance processes, such as by providing
more details on outreach approaches that provide more direct
support for participants to develop suitable projects.

4.	Expedite the development of methodologies for quantifying
co-benefits, since such co-benefits will enable the state to
achieve multiple goals with these programmatic dollars.  Climate
impacts on some projects could directly impact long-term GHG
reductions, but may not be strictly considered a co-benefit. In
light of this, we recommend that the ARB explore quantification
methods for climate impacts where they might directly affect GHG
reductions distinctly from quantifications of climate impacts as
general co-benefits, such as social and economic co-benefits. Such
an approach would represent risk management strategy for ensuring
funded reductions are realized and that different types of
co-benefits were assessed to ensure consistency of this statewide
program with the Governor’s direction as outlined in his Executive
Order.

We hope these comments are helpful to your efforts, and welcome the
opportunity to provide additional clarification or support
development of specific language as desired. 

Sincerely,

Krista Kline
ARCCA Chair
The Los Angeles Regional Collaborative for Climate Action &
Sustainability
 
Larry Greene
ARCCA Vice-Chair
Capital Region Climate Readiness Collaborative
 
Cody Hooven
The San Diego Regional Climate Collaborative
 
Allison Brooks
Bay Area Regional Collaborative and the Alliance for Climate
Resilience
 
Kerri Timmer
Sierra Climate Adaptation & Mitigation Partnership