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Comment 14 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Luke
Last Name: Hunt
Email Address: lhunt@amrivers.org
Affiliation: American Rivers

Subject: DAC Definition
Comment:
I am writing regarding the Cap-and-Trade Auction Proceeds,
Investments to Benefit Disadvantaged Communities: Interim Guidance
to Agencies Administering Greenhouse Gas Reduction Fund Monies.  I
would like to register American Rivers' concerns about the use of
the CalEnviroScreen 2.0 Tool in assessing Disadvantaged Communities
for the purpose of distributing these funds.  By using this tool,
seriously disadvantaged communities in California's most important
sourcewater areas, including the entire Sierra will not be
considered as a DAC. This puts these communities at an unfair
disadvantage, when applying for funding. We urge instead that you
use the income-based DAC status determined based on the DAC
definition provided in DWR's Proposition 84 and 1E IRWM Guidelines,
dated August, 2010.

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Date and Time Comment Was Submitted: 2014-09-10 11:12:42



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