Comment Log Display

Thank you for the opportunity to provide comment to the Concept
Paper and Funding Guidelines.   This set of comments provides
written record of the verbal comments I provided at the 8/3/15
workshop in Sacramento on behalf of the California Green Business
Program, and also lists the specific citations within the two
documents we offer considerations for but did not have time to
present in the three minutes alloted.

Ecology Action is the administrator for the California Green
Business Program. The Program has provided technical assistance to
over 10,000 small and medium businesses since 1996, helping them
implement comprehensive green practices.   Our onsite assistance,
audits and certification leads to verified outcomes that are not
currently captured in the GGRF program and creates a green economy
where consumers can vote with their dollars by frequenting green
businesses. The program is funded and implemented by 24 cities and
counties around the state and serves over 50% of California’s
population. 17% of our currently certified businesses are located
in disadvantaged communities as identified by the CalEnviroscreen
2.0 tool.  The Program was authorized by the legislature as the
official California Green Business Certification program model in
2011 (AB 913, Feuer). The program received some fiscal support from
DTSC before the budget crisis and the legislation but due to fiscal
challenges no financial support was tied to the bill or has come
from agencies since.

Today we are here to strongly support the inclusion of a small
businesses category in the Auction Proceeds Investment Plan. The
3.4 million small to medium businesses in California account for
99% of the state’s employers, employ 52% of the workforce and
represent 45% of the commercial energy use in our state.  As such
this sector provides a significant, if distributed, opportunity to
reduce greenhouse gasses, strengthen local economies and through
engaging employees, generate a commitment to climate protecting
practices that can spread from business to customer, and from work
to home.

As one example of what’s possible with investment from the GGRF
into small business programs, the California Green Business Program
has a strategic plan to scale to serve 40,000 businesses by 2040,
so that we can mainstream green in California’s small business
economy.  Doing so would provide verified voluntary emission
reductions of at least 900 thousand metric tons of greenhouse
gasses annually and reduce 125 million gallons of water use each
year. These, among the other environmental co-benefits of the
program would save small businesses $30 million annually in utility
bills and rebates.   Beyond these outcomes, which are based on our
current program model, we estimate that as much as a doubling of
energy efficiency outcomes would occur if we could offer funding
for project implementation for the business, which the program is
unable to provide now.  Our 3,000 currently certified businesses
are also keenly interested in solar, and we are currently
estimating the uptake potential and clean energy outcomes we could
realize if funding were available to support financing and/or
installation as part of our Green Business Certification process.

Based on these compelling facts, we respectfully request that the
Investment Plan:
•	Retains the priority of funding small business programs (Section
H. Rural Comm./SBs, Page 7.)
•	Includes more detailed information about the potential of small
businesses (such as the number of small businesses in California
and their energy and water use, etc) so that this category can
generate and sustain broad support through the review process
(Section H. Rural Comm./SBs, Page 7)
•	We request that the plan considers small businesses as well as
residents when referencing Disadvantaged Communities, since
businesses can both contribute to outcomes and benefit from
investments, such as referenced in the Disadvantaged community
Section in the Clean Energy and Energy Efficiency chapter (Section
4. DACs, P. 16)
•	We request that the plan also include nonprofits as potential
recipients under the Energy Efficiency and Clean Energy category,
as noted in Figure 5. Page 17.
•	We request that small businesses are considered and listed as
beneficiaries and potential programs under all applicable sections
such as Water and Energy, Energy Efficiency and Clean Energy, and
Sustainable Communities
•	We additionally strongly support the themes other than the small
business priority, (III. Overarching Themes ,Pages 4-6) including:
o	Item A: Beyond 2020. While this is clearly important for the plan
overall, it also can be realized with programs like the CAGBP that
implements lasting retrofits and cultural changes in the
businesses, which is reinforced by mandatory recertification audits
every 3 years to ensure the business has sustained its practices.
o	Item B. Extends Benefits to all Californians.  While the CAGBP
has a strong history of service to DACS (17% of our businesses are
located in DACs), the numbers of businesses we serve are not
representative of the population percentage of those communities in
the state (25%) and additional resources are required to ensure
services are provided with parity, using culturally appropriate
methods.  The CAGBP has a component of its strategic plan
specifically addressing this issue. 
o	Item D. An integrated Systems Approach to funding projects.  The
California Green Business Program’s strength is that it offers a
comprehensive one-stop-shop systems approach for businesses, but
due to that has had a challenges securing funding to support
program operations from siloed agencies who prioritize only one
environmental media area in their funding programs.
o	Item E. Integrated Projects in Disadvantaged Communities to
Support Local Climate Action. While the CAGBP is not an
infrastructure project it foes offer an integrated systems
approach, and is frequently a pillar of local Climate Action Plans
due to its verified carbon reduction outcomes.
o	Item F. Efficient Financing.  Whether we can deliver cost
coverage, cost share or financing for projects, it will help
businesses commit to energy efficiency, water efficiency, waste
reduction and renewables retrofits that, while identified in our
process now, are not financially within reach even with utility
rebates and programs. 
o	


We additionally have comments specific to the Funding Guidelines,
which include:
•	Adding requirements for Program Agencies to include scoring
preferences and selection criteria that consider the environmental
co-benefits, job creation and economic benefits of projects in
competitive solicitations, and 
•	That Agencies select projects that provide verified outcomes in
these areas to realize the full breadth of AB 32 goals.
(Solicitation Materials, 3. Quantification Methods, and 4.
Selection Criteria P. 39-40)

The comments I have provided in person represent many other voices.
 Over 54 small businesses and 5 local certified green business
program implementation agencies have already submitted comments
online supporting a small business category in the Investment Plan.
On their behalf, I thank you for your time and consideration of the
potential for small businesses to make a big difference in growing
California’s green economy.