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Comment 171 for Auction Proceeds Investment Plan Public Process (investplan2015-ws) - 1st Workshop.


First Name: Jessica
Last Name: Goodheart
Email Address: jgoodheart@laane.org
Affiliation: LAANE

Subject: Investment Plan 2015
Comment:
September 1, 2015

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

Dear Ms. Nichols:

Re: Comments on the Draft Second Investment Plan Concept Paper for
California Climate Investments

Thank you for the opportunity to submit comments on the Draft
Second Investment Plan Concept Paper. The Los Angeles Alliance for
a New Economy is a non-profit organization that for more than two
decades has successfully advocated for policies and projects that
promote thriving communities, environmental benefits and good jobs.
We have worked in coalition for policies and programs to raise
living standards, create career opportunities, improve communities
and reduce Greenhouse Gas emissions and toxic pollution. This
includes our work to clean up the trucks at the Ports of Los
Angeles and Long Beach, to expand investment in energy efficiency
and solar programs at the Los Angeles Department of Water and
Power, and to increase recycling in the City of Los Angeles. We
believe that our state’s transition to a clean energy economy can
and should be tied to the creation of good, middle class jobs that
can support families and build strong communities. 

We are interested in the Energy Efficiency and Renewable Energy
components of the Draft Second Investment Plan. This is due to our
long-standing partnership with the Los Angeles Department of Water
and Power and IBEW Local 18 to develop programs that provide the
triple benefit of reducing Greenhouse Gas emissions, benefiting low
income communities through lower utility bills and providing high
quality training and employment opportunities to disadvantaged
communities. 








We are particularly proud of our work with the Utility Pre-Craft
Trainee program. Trainees are paid $16 per hour while they gain the
experience to access careers in the utility industry. Very few
training programs offer this earn-as-you-learn approach that is
essential to maximizing benefits for disadvantaged communities.
This program’s trainee workforce reflects LA’s ethnic diversity,
has a large percentage of women and a majority of participants
report a barrier to employment such as a criminal conviction,
long-term unemployment or being a single parent. We feel that this
incredibly successful program has a role to play in ensuring monies
invested from the GHGRF maximize benefits to disadvantaged
communities. 

Given this experience, we respectfully offer some suggestions for
changes to the Draft Second Investment Plan:


•	The section that addresses disadvantaged communities under Energy
Efficiency and Renewable Energy (pg. 16), mentions “household clean
energy generation”, but does not include renewable energy
generation projects that are community based and not household
based. It is essential that this definition be expanded to include
community based energy generation projects as they have the
potential to reach residents who do not meet requirements for
household based systems. Household clean energy generation is
important, but it makes sense to define projects as widely as
possible in the Investment Plan. This will ensure that all
innovative projects that provide the highest reduction in GHG
emissions and the best benefits to disadvantaged communities are
eligible.

An example of this exciting opportunity is the 40MW Community Solar
Program currently being developed by the Los Angeles Department of
Water and Power. Developed on public land, these projects have the
potential to bring solar power and reduced energy bills to
households locked out of the current residential solar model like
some renters and those whose homes do not qualify. This is
especially important because many residents in disadvantaged
communities do not own their home. A coalition of more than 30
community, labor and environmental organizations, including LAANE,
IBEW Local 18, SCOPE, Communities for a Better Environment and
Sierra Club, supports such a program and is working to ensure that
it truly serves disadvantaged communities. 

•	Similarly, Figure 5, which describes “Draft Investment Concepts”
under Energy Efficiency and Renewable Energy (pg. 17), also focuses
on residential projects. Again, this excludes the exciting
potential to create community renewable energy projects. Many of
these community renewable energy projects can be located in
disadvantages communities, employ the residents of these
communities in projects that are visible to them and benefit the
neighbors of the project with reduced energy bills. 

•	Another recommendation involves the reference to “clean energy
manufacturing and service jobs” in section 5, “Co-Benefits” (pg.
16). Rather than simply referring to “jobs” as a co-benefit, we
would like to recommend using language that prioritizes
high-quality jobs. In addition, we recommend language that supports
providing access to these high-quality jobs to residents of
disadvantaged communities. 

•	The money allocated for energy efficiency and solar in municipal,
university, school and hospital buildings offers one of the best
opportunities to provide high quality job opportunities for
disadvantaged communities while reducing energy use and greenhouse
gas emissions. For this reason, we feel the current funding for
energy efficiency for public buildings, set at only $20 million per
year, should be increased and be made available for all types of
public buildings, not just state-owned buildings. 


We appreciate your consideration of these comments. We look forward
to working together in the future to develop exciting and
innovative approaches to a clean energy future that benefits all
Californians. 


Sincerely, 



Roxana Tynan
Executive Director 
Los Angeles Alliance for a New Economy



Jessica Goodheart
Director of the RePower LA Project
Los Angeles Alliance for a New Economy





Attachment: www.arb.ca.gov/lists/com-attach/256-investplan2015-ws-V2ZTYFRlVjxQZgMy.pdf

Original File Name: 150901LAANE Comments to CARB re Investment Plan.pdf

Date and Time Comment Was Submitted: 2015-09-01 16:02:39



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