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Comment 19 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Rick
Last Name: Ramacier
Email Address: ramacier@countyconnection.com
Affiliation: County Connection, CalACT

Subject: SB535 Interim Guidance Comments
Comment:
I provide comments as:

Rick Ramacier
General Manager
County Connection
2477 Arnold Industrial Way
Concord, CA 94520

and:

Chair of the Board
California Association of Coordinated Transportation (CalACT)

We appreciate the level of thoughfulness that is in the draft
interim guidance. We note that public transit providers throughout
California are well poised to deliver projects and programs that
address many of the needs identified in Table 3 on page 17 of the
draft document. 

We also note that public transit is ideally positioned to deliver
the types of projects inherent in draft lists of 1.1, 1.2, and 1.3
of Appendix 1. 

We appreciate the acknowledgement in Figure 2 on page 20 that
projects funded under the Cap and Trade Auction Proceeds do not
always have to benefit a DAC as long as they demonstrate reductions
in GHG emissions. 

Specifically, I would like to comment on SB1018 requirement for
entities receiving Action Proceeds to prepare an expenditure report
as well as the need to show GHG reductions. We urge ARB to design
and develop metrics that are easily applied and take advantage of
the wealth of data already reported and collected. WE urge you
build on existing reporting processes wherever possible to work
ensure that preparing expenditure reports not be overly burdensome
on smaller transit systems. I personally suggest you look at what
Caltrans, the State Controller's Office, and the Federal Transit
Administration already collect from transit operators of all size
and shapes. You will likely find that much of the data you will
want to use is already in the hands of those agencies.

When you look at measuring the level of GHG reductions from a
particular transit project, we urge you to recognize how public
transit is often provided. For example:

* Many transit lines will be begin within a DAC, but end outside of
one. 
* Public transit must always remain open to anyone who wishes to
use it.
* Fare reduction programs will often have to be coordinated with
federal requirements under Title VI of the federal civil rights law
- which classifies disadvantaged communities in different manner
than the CalEnvrioScreen tool.
* Fare reduction strategies work best when entire systems are
included as opposed to select lines of service. 

Again, thank you for the opportunity to comment. Should you have
any questions, you contact me at: ramacier@countyconnection.com or
925-680-2050.

Sincerely,

Rick Ramacier

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Date and Time Comment Was Submitted: 2014-09-11 14:18:47



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