Comment Log Display

On behalf of California ReLeaf – a statewide non-profit that
supports a network of ninety community groups engaged in
on-the-ground urban forestry throughout California – we are writing
to commend CAL-EPA for a thoughtful and transparent process in
identifying what constitutes a disadvantaged community.  This is an
essential element that must be defined for the purposes of awarding
cap-and-trade auction revenues for projects that meet the goals and
objectives of AB 32, AB 1532, and SB 535.  The August 2014
discussion draft issued by CAL-EPA and OEHHA does a good job
tracing the history of the CalEnviroScreen Process, and providing
stakeholders with options to evaluate in how CalEnviroScreen
indicators are used to maximize opportunities for DACs now and in
the years to come.

The basic questions posed by this document revolve around the
appropriate cutpoint for identifying what constitutes a DAC and
which of the five “methods” presented by CAL-EPA and OEHHA best
reflect the goals and objectives of SB 535 and CalEnviroScreen. 
For California ReLeaf, these questions have fairly straightforward
answers.

1.	 Cutpoint.  California ReLeaf supports 25% as the cutpoint for
what constitutes a DAC for the purposes of awarding cap-and-trade
auction revenues for projects that are located within, or provide
benefit to, a disadvantaged community.  We agree with the argument
put forward in the discussion draft that asserts “SB 535 requires
the allocation of at least 25 percent of the available proceeds to
projects that provide benefits to disadvantaged communities.
Therefore, we present cutpoints up to 25% to ensure disadvantaged
communities receive at least a proportionate share of funds when
compared to the rest of the state.”

Furthermore, the 25% cutpoint broadens the scope of opportunity
across California, while still adhering to the goals and objectives
of SB 535.  Counties such as San Francisco, Butte, Imperial, Santa
Cruz and Tehama would be excluded from this process if a lower mark
of 15% or less was selected.  In short, an additional 15% of the
State’s counties are afforded an opportunity to compete for funding
from cap-and-trade auction revenues by integrating
disproportionately burdened communities such as San Francisco, Palo
Alto, Oroville, Watsonville and Daly City into the fold.  All of
these communities, and many more that rank lower on
CalEnviroScreen, would benefit from increased canopy cover that can
improve air quality and help mitigate urban heat island effect.

2.	Preferred Methods.  California ReLeaf does not support one
specific method identified by CAL-EPA and OEHHA in this discussion
draft.  Most reflect the spirit and statutory intent of
CalEnviroScreen and SB 535, respectively; and nearly all stay
within the heavily concentrated areas of the Central Valley,
Southern California, and portions of the East Bay and Sacramento
Valley.  As a statewide organization representing community groups
throughout California, we are not inclined to “pick favorites”, but
rather offer some brief observations on some of the proposed
methods.

Methods 2 and 3 do not take into account all 19 indicators, and
therefore interpret state statute to assume “either or” is
appropriate in regards to how pollution burden and population
characteristics are integrated into the final CalEnviroScreen
model.  While this may or may not be a correct interpretation of SB
535 (CAL-EPA and OEHHA seem split on this issue), it certainly
raises enough questions that could potentially slow the
distribution of auction revenues for projects, which was already
delayed by a year due to outcomes in the 2013-14 State Budget. 
Neither model seems particularly transformative in relation to the
other methods (though Method 3 is certainly more inclusive of
Northern California and the lower Inland Empire), and could spark
controversy, further delaying the process.

Method 5 is intriguing as it is the only model that integrates the
percentage cutpoints into the methodology.  While Method 5 still
represents a 25% cutpoint for projects, it does so in a way that
“levels the playing field” for projects that are either high
pollution-medium population or medium pollution-high population. 
This approach lends itself to a more competitive process for these
auction revenues, as only projects that are both high
pollution-high population would rank higher.  In this sense,
pollution and population are equally weighted.

Finally, “Method 6” – an alternative to the models developed by
OEHHA which has been introduced by the Bay Area Air Quality
Management District – is not without merit.  This straightforward
approach of multiplying each of the 19 indicators (and weighting
each equally) still follows the framework set forth by SB 535, but
does produce some interesting results.  While the mapping of this
methodology still recognizes the disproportionate burden of
pollution and population placed on Los Angeles and the Central
Valley, it also recognizes other underserved communities by
expanding the field of opportunity in portions of San Francisco,
East Bay, San Diego and the Central Coast.  Consequently, this
method would provide additional opportunities for Network partners
in the Bay Area and the South Coast to build upon the tremendous
urban forestry efforts that have helped improve the quality of life
in these highly populated areas of the state.  

Currently, CAL FIRE is requiring 100% of urban forestry
cap-and-trade auction revenues to be utilized for meeting the goals
and objectives of SB 535.  While this will be a subject of comments
addressed to CARB regarding its discussion draft on what
investments benefit DACs, it is pertinent here for one simple
reason.  The natural inclination for many organizations confined to
a specific geography would be to ensure their field of operation is
included in that geography, or that the area is as large as
possible.  For California ReLeaf and many of its Network members,
we would rather see the spirit and statutory requirements of SB 535
persevere, and work though other channels to ensure cap-and-trade
investments in urban forestry can benefit all California
communities in the coming years.  Consequently, we believe Methods
1, 4, 5 and 6 all meet the intent of SB 535. 

We appreciate the opportunity to provide comments.