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Comment 11 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Colleen
Last Name: Edwards
Email Address: colleen.edwards1234@yahoo.com
Affiliation: Affordable Housing Developer

Subject: DRAFT: Investments to Benefit Disadvantaged Communities
Comment:
Page 12 of the Draft Guidelines lists the programs and
appropriations expected to benefit disadvantaged communities.
Please be aware that the programs are not all equal in nature. Some
are direct benefit to end users such as weatherization (assuming
this program will target consumers directly). Others such as
affordable housing projects financed in the Sustainable Communities
program are very highly leveraged. Every $1 of Cap-and-Trade
investment in affordable housing will be matched by $3-$4 of
outside sources to create housing in these communities. Therefore
if 50% of the Sustainable Communities funds went to projects in
disadvantaged communities (15-20% of census tracts), it could
result in almost 50% of ALL affordable housing projects in the
state going to 15-20% of census tracts in the state. That doesn't
seem equitable to the remaining 80-85% of census tracts. Therefore
I suggest that the program take into account leveraging in the
final allocation of funds to affordable housing projects in
disadvantaged communities.

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Date and Time Comment Was Submitted: 2014-09-04 14:52:51



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