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Comment 31 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Gail
Last Name: Church
Email Address: gail@treemusketeers.org
Affiliation: Tree Musketeers
Subject: CalEPA and CARB Guidance on Cap-and-Trade Implementation and SB 535
Comment:
We are pleased that advocacy efforts of those of us in California’s urban forestry community resulted in a significant role for urban forestry in the State’s Cap-and-Trade expenditure plan for 2014/15 and beyond. We do have some comments regarding implementation. Of the options proposed for identifying disadvantaged communities, we urge that methods 1, 4, 5, and 6 be given the greatest consideration. These address the intent, requirements and spirit of SB 535. We do not believe that methods 2 and 3 meet the statutory requirements of SB 535. We also believe that the Air Resources Board suggestion that $10.5 million (or 55%) of the Urban Forestry funds be dedicated to disadvantaged communities would allow CalFire to meet or exceed the requirements of SB 535. As for the percentage of the funds that could be spent on projects that “benefit disadvantaged communities,” we encourage you to thoughtfully consider the broad array of benefits that are not specific to a narrowly-defined geographic area. Finally, in consideration of the magnitude of work done by trees in existing canopy, we believe it is important to include funding in the Urban Forestry program guidelines for management and maintenance of standing urban trees. California needs both new trees and our existing canopy to reach our AB 32 goals.
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Date and Time Comment Was Submitted: 2014-09-12 15:57:02
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