Comment Log Display

On behalf of the Sierra Nevada Alliance, we write to provide
comments on the “Cap-and-Trade Auction Proceeds, Investments to
Benefit Disadvantaged Communities: Interim Guidance to Agencies
Administering Greenhouse Gas Reduction Fund Monies – Draft for
Comment.” Since 1993 the Sierra Nevada Alliance has been protecting
and restoring Sierra lands, water, wildlife and communities. Our
mission is to protect and restore the natural resources of the
Sierra Nevada for future generations while promoting sustainable
communities. We are truly an Alliance, with over ninety-five Member
Groups and nearly 10,000 individuals that span the entire 400 mile
mountain range. Our member groups work on a broad range of
conservation issues including watersheds and energy. We also work
with and coordinate all 12 of the Sierra Region Integrated Regional
Water Management (IRWM) groups through the Sierra Water Workgroup.

As you know, over 60% of California’s developed water comes from
Sierra watersheds and we provide nearly half of the state’s timber
resources. The Sierra Nevada region is home to a disproportionately
large number of disadvantaged communities (DACs). Using the median
household income (MHI) indicator, our region’s income is at or
below 80% of the state’s (MHI). According to 2010 Census Data, over
40% of the range’s (based on Sierra Nevada Conservancy’s boundary)
communities and nearly 70% of our individual residents lives in
disadvantaged communities, which is concerning as compared to other
regions of the state. Given the geographically dispersed nature of
the range, disadvantaged communities within the Sierra lack the
resources necessary to adequately quantify, monitor and protect
their resources. The Sierra Nevada region accounts for about 22% of
California’s land area, but less than 7% of the state’s population.
This makes it very difficult for Sierra sustainability efforts to
compete with large population centers.

The Cap-and-Trade Auction Proceeds will provide much-needed funding
for communities across California and we thank you for this
opportunity to provide input. Our top concern with the Draft is the
proposed DAC criteria. The CalEnviroScreen tool is not a good
indicator of disadvantage. It almost exclusively precludes Sierra
Nevada and other rural areas in the state. Median household income
(MHI) should be the primary indicator for directing funding to DACs
until a tool that ensures more equity is developed. 

We thank you for taking public comments and look forward to the
release of the final guidelines.

Gavin Feiger 
Acting Executive Director