Comment Log Display

On behalf of California ReLeaf – a statewide non-profit that
supports ninety community groups that are committed to greening our
golden state through urban forestry --  we are writing to provide
comments on CARB’s discussion draft of Investments to Benefit
Disadvantaged Communities, published August 22, 2014.
The interim guidance provided in this document will set the stage
for one of the most important governing tools CARB will ever
produce related to AB 32 implementation:  a methodology for
unequivocally demonstrating how cap-and-trade auction revenue
investments will meet and exceed the goals of AB 32, and related
statutes that include AB 1532 and SB 535.  Consequently, California
ReLeaf believes every effort should be made to get as much of this
interim guidance right from the very start.

With respect to how this document addresses the role of urban
forestry in the overall process of GHG reductions and benefits to
disadvantaged communities, there is much to applaud in this
discussion draft.  CARB’s acknowledgement on page 11 that all
projects come with administrative costs takes a reality-based
approach to what is required to make the overall program
successful.  CARB’s suggestion on page 16 that “agencies could work
together to combine transit improvement projects with other
projects” represents progressive thinking that is critically needed
if California is to truly embrace the goals of SB 375 and adopt
meaningful Sustainable Communities Strategies.   And CARB’s
direction throughout the first half of the document regarding early
engagement and outreach is an absolute must if these projects are
to succeed and sustain.

There are other meritorious directives through the document, but
California ReLeaf would like to focus on three particular items
related specifically to urban forestry.

1.	 Estimated GGRF Appropriation for 2014-15 Expected to Benefit
DACs.

Table 2 on page 12 suggests CAL FIRE should direct 55% of its total
cap-and-trade auction revenues allocated for urban forestry to
projects that benefit disadvantaged communities, and 55% to
projects located within them.  Item 1 exceeds the SB 535
requirement by more than 100%, while item 2 exceeds 535
requirements by 550%.

California ReLeaf strongly supports both recommendations.   In
fact, California ReLeaf, in its capacity as a lead advocate for
these funds throughout the state budget process in 2013 and 2014,
has maintained that closer to 66% of these funds should be directed
to projects that benefit DACs, which we still support.  In either
case, CARB recognizes that a small portion of the urban forest
funds should remain competitive for all communities and thereby
reflect CARB’s assertion on page 3 that notes “agencies can use
their GGRF appropriations to fund projects that otherwise meet the
statutory requirements for investments, but do not meet the
criteria in this guidance."  Given that neither SB 862 (chaptered
in 2014) or the 2014-15 State Budget bill signed by Governor Brown
place any statutory restrictions on how much of these urban
forestry funds be directed to DACs, this language and CARB’s
recommendation in Table 2 are both appropriate and comply with
state law.

This point warrants further discussion, however, given CAL FIRE’s
announcement on August 28th that 100% of CAL FIRE’s urban forestry
funding be used to benefit DACs – without any public process or
debate.  For urban forestry stakeholders operating in
disproportionately burdened areas (who have utilized now-exhausted
bonds) to support projects that don’t fall within the top
CalEnviroScreen percentiles, this was a shocking revelation that is
in direct conflict with messages communicated by the Legislature
and Administration – most specifically CARB’s discussion draft
publicly released six days prior (and still available on its
website).  Even if CAL FIRE were to utilize its Urban and Community
Forestry Program as the sole element within the suite of CAL FIRE
programs funded with $42 million in cap-and –trade auction
revenues, the minimum requirement would be $10.5 million. As a
member of the 535 coalition, California ReLeaf supports up to $12.5
million for these purposes, and encourages efforts to ensure 535
targets represent the floor, not the ceiling, for DAC investments. 


But 100% goes too far. It eliminates the opportunity to address
drought by keeping water in terrestrial systems that don’t neatly
fall within CalEnviroScreen.  It excludes many underserved areas in
East Bay, San Francisco, and even San Diego from even competing for
funds.  And it removes the opportunity for CAL FIRE to judge all
applications on their merit and their ability to promote the best
ecological decisions for all communities.  A letter signed by 30
urban forestry leaders scattered throughout California was sent to
CAL FIRE on this matter, and forwarded to Ms. Cynthia Marvin and
Ms. Shelby Livingston at CARB (see attached).

As the control agency on this matter, and the administrator of GGRF
dollars, we encourage CARB to work with the Administration and
Resources Agency to ensure the majority – not the entirety – of
urban forestry funds be directed to projects that benefit, or are
located within , disadvantaged communities, as reflected in the
discussion draft.  

2.	Scope of eligible urban forestry projects

California ReLeaf strongly supports the list of urban forestry
projects identified in Appendix 1-7 deemed by CARB as eligible
activities “that will achieve GHG reductions though net increases
in carbon sequestration…”  We would encourage CARB to consider
adding tree inventories and management plans to that list, as both
are critical tools in identifying means to support a healthy,
thriving urban forest, and determining the net GHG reduction
benefit in aggregate for California communities.
More specifically, we want to thank CARB for its recognition of
“tree maintenance” as an eligible use of these funds.  

California’s current urban forest sequesters approximate 4.5
million metric tons of carbon dioxide each year, with another 1.8
million metric tons avoided through energy conservation and
mitigation for urban heat island effect.  These impressive figures
are based on sustaining our existing mature trees in urban areas
throughout the state, which are at risk from disease, neglect,
drought, and land use development.

For example, many cities have looked to their parks and public
works departments to deliver cost-savings through natural resources
budget cuts. Consequently, as cities continue grappling with a
challenging economy, they are requiring property owners to care for
trees growing along city streets.  In San Francisco, a seven-year
process is currently in place to turn over responsibility for
23,700 street trees to its residents due to budgetary constraints. 
Therefore, tree maintenance must be a component of this effort if
California ifs to sustain the immense GHG reductions provided by
our urban forest.

3.	Draft Criteria to Evaluate Urban Forestry Projects.

California ReLeaf supports many components of these criteria as
presented in Appendix 1-7, including CARB’s assertion that trees
planted in DACs inherently provide benefits to that DAC, and
therefore meet both elements of the 535 requirement.  However, we
would argue that all urban forestry projects located in a DAC (i.e.
maintenance, inventory) provide benefit to that DAC, which would
extend well beyond tree planting.  For this reason, we would
encourage CARB to amend Item A in Step 1 to reflect the eligible
scope of urban forestry projects, and to remain consistent with
CARB assertions made on page 15 and page 19 of the document.

In addition, we would encourage CARB to replace the ½ mile
proximity model reflected in Item A in Step 2 with a more
meaningful metric that specifically addresses the benefits urban
forestry can provide to adjacent and nearby disadvantaged
communities that reflect priorities set forth in AB 32 and AB
1532.

As an example, Item B in Step 2 of Appendix 1-6 (relating to Land
Preservation or Restoration) notes that a project here “Provides
Benefit To” a DAC if the “Project significantly reduces flood risk
to one or more adjacent DACs.”  Verbatim, this language is
completely appropriate for Step 2 of Appendix 1-7.  Trees intercept
rainfall in their canopy, reducing the amount of rain that reaches
the ground. A portion of this captured rainwater evaporates from
tree surfaces.  In addition, trees take up water from the soil
through their roots, which increases soil water storage potential
and lengthens the amount of time before rainfall becomes runoff. 
By incorporating stormwater best management practices (BMPs) such
as swales, retention grading, cisterns, infiltrators and
strategically-planted trees in building and landscaping designs, a
multitude of benefits can be realized for communities located near
the urban forestry project.  This includes improved water quality,
a decreased risk of flooding, a reduced need for water importation,
heat-island effect mitigation, an augmented supply of local
groundwater and, of course, a reduction in contributions to global
climate change.

An additional consideration should be whether or not the facility
at which the urban forestry project occurs is servicing a
disadvantaged community.  In and around disadvantaged communities
in many of California’s most urbanized areas, it’s not uncommon for
a public school servicing primarily students from a DAC to be
located just outside that DAC.  Does an urban forestry project that
is increasing shade for kids to play in, or create a healthier,
cooler playground environment through urban heat island mitigation
“Provide Benefit To” a DAC.  We believe the answer is yes, and
should be included in Step 2.

Concluding Comments  

In total, California ReLeaf supports CARB’s vision of how urban
forestry integrates into the larger mosaic of how all auction
proceeds will benefit disadvantaged communities. With some
important modifications, as suggested in these comments, we believe
the scope of eligible projects, and how they integrate into the 535
model, is on track and much appreciated.  CARB’s commitment to
ensure the majority, rather than the entirety, of CAL FIRE’s urban
forestry funds be directed to DACs is essential to building
stakeholder trust and engagement in a meaningful way that results
in truly transformative investments.