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Comment 49 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Janet
Last Name: Cohen
Email Address: janet@commaction.com
Affiliation:
Subject: Cap and Trade Auction Proceeds and DACs
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 my serious concerns about the use of the CalEnviroScreen 2.0 Tool in assessing Disadvantaged Communities for the purpose of distributing these funds. The tool is still under development and currently contains no DACs in a huge swath of the state including the Sierra region where I live and work - not because there isn't persistent rural poverty and disadvantaged communities in the Sierra, but because there is not enough documentation available to establish DAC status in our region and because the criteria favor urban areas. This tool effectively disqualifies all communities in the Sierra from applying for funds such as these, despite the fact that DACs in our region have extremely urgent needs that could be funded with funds such as these. It seems especially egregious that, in the region that supplies most of the state's water and contains most of the state's forests, no community in this vast region will be able to qualify for watershed or fire prevention monies. I urge that you use the DAC status determined based on the DAC definition provided in DWR's Proposition 84 and 1E IRWM Guidelines, dated August, 2010. This definition uses a much fairer methodology which includes ALL regions of the state. Thank you.
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Date and Time Comment Was Submitted: 2014-09-15 11:10:46
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