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Comment 110 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Eileen
Last Name: Tutt
Email Address: eileen@caletc.com
Affiliation: CalETC

Subject: Interim Guidance for Auction Proceeds
Comment:
From: California Electric Transportation Coalition
To: Cal/EPA and CARB
Comments on Interim Guidance for Auction Proceeds

The California Electric Transportation Coalition (CalETC)
appreciates the opportunity to comment on the Interim Guidance
being developed by the California Environmental Protection Agency
and California Air Resources Board. CalETC is a non-profit
association with a board of directors that includes: Los Angeles
Department of Water and Power, Pacific Gas & Electric, Sacramento
Municipal Utility District, San Diego Gas & Electric and Southern
California Edison.
CalETC strongly supports a portion of the auction revenue being
utilized to fight pollution and help the state’s disadvantaged
communities enjoy the benefits of zero and near-zero emission
transportation. We worked closely with the Administration,
Legislature and other stakeholders in support of the 2013/14 budget
which allocated auction revenue to disadvantaged communities, in
excess of the SB 535 (De Leon) requirements.
We submit the following comments specific to the Cap-and-Trade
Auction Proceeds, Investments to Benefit Disadvantaged Communities,
2014 Public Workshops, held in Fresno, Los Angeles and Oakland in
August and early September 2014, and to CARB as they consider the
item September 18:
Transformational Low-Carbon Transportation Technologies
For the interim guidance period, fiscal year 2014/15, CalETC
recommends that zero- and near-zero emission vehicle technologies
purchased with Greenhouse Gas Reduction Funds, including plug-in
electric vehicles (cars, trucks and buses), count towards the SB
535 requirement as benefitting disadvantaged communities because
the vehicle will lower pollution in the whole region. The market
penetration of plug-in electric vehicle technologies is currently
below one percent. To address the substantial air quality, toxic
pollution and economic challenges in California, by 2030, almost
every vehicle sold must be zero- or near-zero emission. 
Vehicles, cars, trucks and buses, are mobile. It is almost certain
that zero- and near-zero emission vehicles will travel through and
near disadvantaged communities, and will reduce transported air and
toxic pollutants in disadvantaged communities. Further, it is often
the case that residents of disadvantaged communities purchase used
vehicles. The market for used vehicles cannot grow without
substantial sales of new vehicles. Therefore, acceleration in the
new vehicle fleet in these very early market stages is essential to
ensuring zero- and near-zero emission vehicles enter the used
vehicle market as quickly as possible.
Beyond fiscal year 2014/15 CalETC would like to continue to work
with community representatives through the Charge Ahead effort and
with CalEPA and CARB to best define the benefits low-carbon
transportation to disadvantaged communities.
Defining Disadvantaged Communities
CalETC applauds Cal/EPA’s efforts to identify disadvantaged
communities. The thorough and thoughtful development and use of the
CalEnviroScreen 2.0 tool has helped communities and stakeholders in
California better understand the plethora of socioeconomic and
environmental challenges facing our state. 
CalETC is concerned that the methods being considered by Cal/EPA
may unintentionally exclude some communities that are heavily
impacted by toxic and/or air pollutants and/or communities that
suffer under extreme socioeconomic burdens. CalETC believes the
intent of SB 535 (De Leon) was to ensure that disadvantaged
communities receive greenhouse gas reduction funds. For this
interim guidance, we suggest a methodology that recognizes
previously identified disadvantaged communities, particularly those
that have very high levels of toxic pollution and/or poverty.
Further refinement can and should be explored for 2015/16 and
beyond.


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Date and Time Comment Was Submitted: 2014-09-15 16:56:03



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