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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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