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The use of Cap-and-Trade funds for economically-disadvantage and
highly pollution-impacted communities should be able to assist
isolated refinery towns that have a dramatic bimodal income
distribution pattern. 

I speak specifically of Rodeo California or collectively, the Rodeo
and Crockett unincorporated county jurisdictions, that are both
adjacent to and inclusive of the Phillips 66 Refinery, having two
zip codes (94547, 94572) and approximately 8,700 and 3,100
residents, respectively. It is remarkable that Rodeo scores above
the 20% cut-off point, when considering both the distribution of
poverty and pollution.

I..Phillips 66 is the most polluting refinery in the state,
1,097,117 pounds of toxic releases in 2012 versus Chevron in
Richmond's 611,255 pounds, although it is less than half the size.
Much of the reason for the Rodeo refinery's high pollution levels
is that Phillips 66 has a history of and capacity for utilizing
lower-quality, higher-sulfur crude feedstocks than most other
refiners in California

Rodeo also has a major interstate highway running through it that
separates the lower income flat lands on one side of the highway
and the moderate income communities on the other side, where it is
hilly and has a higher percentage of homeowners. It is beyond
understanding that Rodeo does not qualify for use of Cap-and-Trade
funds under the CalEnviroScreen models, 1-5. To amend the problem
that leaves out thousands of low income Rodeo residents in the
vicinity of Phillips 66, Option #6 should be used to include
asthma, age, gender and poverty on the refinery side of the
highway. in other words, option #1-5 lack resolution and have
increased granularity for those factors and other reasons.

My read of the statistics are that The median income for a
household in the CDP was $60,522, and the median income for a
family was $63,151. Males had a median income of $46,077 versus
$32,452 for females, indicating that female-only led households
would be disproportionally impacted by poverty, even before the Bay
Area cost-of-living is factored into the equation. 

Both towns recently learned that their single supermarket, an old
Safeway store, that will be closing, so the at a new store will be
opened by corporate headquarters in the next town over, Hercules.
that has a much higher average household income of about $93,000.
So therefore, both Rodeo and Crockett are food deserts as well as
grossly underserved by public transportation and subjected to
Interstate 80 traffic and diesel particulate pollution. At the very
least, the qualifying score should be raised for certain
communities that the CalEnviroScreen algorithms 31-5 bias against,
statistically.

As others have noted the problem with qualification methods #1-5, I
quote: "Many Bay Area Communities with some of the highest poverty
rates and greatest health burdens (asthma rates and low birth
weight) are not identified. For example, current approaches for
scoring CalEnviroScreen indicators fail to identify:

•	Bay View/Hunter’s Point in San Francisco,
•	Portions of West Oakland adjacent to the Port of Oakland,
•	Portions of Richmond and Rodeo, and
•	Portions of East Palo Alto and San Jose.

In fact, CalEnviroScreen Method 1 using a 20% threshold identifies
fewer than 3% of Bay Area census tracts as disadvantaged."

Why is it important that Rodeo be included on the map, as could
Crockett that is certainly down wind of all refinery releases?
Cap-and-Trade funds can be used to offset the cost of electricity
for low-income households that are about $200 dollars per month or
$50 thousand dollars over 20 years. Thus, unbelievably, a low
income family pays five times out of pocket for electricity than an
upper middle class family pays to own outright a photo-voltaic
solar collectors and pays nothing else on a monthly basis. 

II. I intend to propose, under the DeLeon CA Senate Bill 535, for
Cap-and-Trade Investments to Benefit Disadvantaged Communities,
that a solar farm be built in Rodeo/Crockett, perhaps on the
64-acre asphalted superfund site of Selby Slew, The electricity
generated from this site will primarily go to the most
economically-disadvantaged households, to markedly reduce their
electrical bill and to reduce greenhouse gasses produced from the
burning of natural gas at investor owned utilities. The project
would be primarily local hire. 

Another portion of the funds could possibly be invested to improve
public transportation, both within Rodeo and Crocket and for better
connecting those two communities to BART, bus hubs and shopping
areas.

The entity that would operate the solar farm would be a non-profit
Community Choice Aggregation (CCA) using non-fossil fuel-based and
sustainable clean energy. The project would start with solar that
would generate enough energy for about 1,000-2,000 people. The area
is high in solar sunlight availability, and could also be sited, in
the future, for vertical axis wind generation that could be more
closely spaced than larger horizontal wind towers. 

The CCA would distribute the electricity to the qualified
households, in the communities of Rodeo and possibly Crockett, in
the form of Renewable Energy Credits (RECs) as spelled out by AB32,
the 2006 California Clean Air Act.

Charles Davidson