Comment Log Display

The County of Santa Cruz Planning Department regularly engages the
needs of disadvantaged communities in the course of our work. We
are concerned that the proposed method for identifying
disadvantaged communities will fail to capture disadvantaged
populations in Santa Cruz County that should be identified if the
program is to reach those communities that are intended to be
served by Cap and Trade resources.  The technique of using a
weighted average of characteristics to identify communities may
obscure  communities that are strongly  disadvantaged in some
important categories but not broadly in all categories.
For example, disadvantaged populations in coastal areas are not as
likely to be located near identified polluted areas. However, in
other important measures of social equity, such as housing costs
and the economic and social cost of long commutes to jobs, the
disadvantage is extreme.  Santa Cruz County has the second most
expensive cost of housing in the nation, when housing cost is
compared to income. 
Thank you for considering amending the proposal to consider all
relevant measures of social equity, to consider that disadvantages
vary among the different regions of California,  and to consider
accepting applications from communities that may not meet the
CalEPA definition of disadvantaged community as  it is currently
conceived.
Please contact me if additional information is needed.
Sincerely,
Paia Levine
Planning Department
County of Santa Cruz