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The definition of Disadvantaged Communities does not fully
recognize the enormous challenges faced by former military bases
and their surrounding communities.  Typically, federal and state
funding programs have recognized the unique challenges base
closures bring to communities and, as a result, categorize former
military bases at the top of projects that should receive
assistance.  SB 535 required CalEPA and ARB to maximize the
benefits of investments to disadvantaged communities and achieve or
exceed the investment targets.  If the definition of disadvantaged
communities remains as is, the failure to score former military
bases in the lowest category, red, represents a missed opportunity
to maximize benefits and exceed investment targets.  In addition,
it fails to take into account what other federal and state programs
have recognized when assessing the barriers faced by former
military bases. 

Former military bases can be ideal locations for reducing GHGs. The
former Tustin Marine Corps Air Station is transit-rich with an
adjacent Metrolink station and future commercial development will
provide employment opportunities close to nearby residential
development.  While the former MCAS Tustin scores high in
environmental measures on Cal Enviroscreen, our proportionally low
population is reducing the score of this otherwise hJigh-scoring
area. We request CalEPA and ARB enhance their scoring methodology
to reflect an acknowledgement that the former military bases are
truly disadvantaged communities. 

Thank you.