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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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