Comment Log Display

Thank you for the opportunity to review and comment on the “Interim
Guidance to Agencies Administering Greenhouse Gas Reduction Fund
Monies” released August 22, 2014.

The Gateway Cities are 27 cities and unincorporated communities in
Southeast Los Angeles County with a total population of about 2
million residents.  Taken together, the Gateway Cities would be the
fifth largest city in the United States.  We are home to the Port
of Long Beach and neighbor to the Port of Los Angeles, and we house
much of the transportation and distribution infrastructure that
supports the movement of goods into and through our region to the
rest of the nation.

The Gateway Cities are one of the most impacted areas of the state
when considering disadvantaged communities.  According to
CalEnviroScreen results, on a census tract basis 1.18 million of
our residents – more than half – live in disadvantaged communities.
 On a zip code basis, this is true for three-quarters of our
residents.  This means that almost any investment of cap-and-trade
funds directed to the Gateway Cities will either be located within,
or will provide benefits to, disadvantaged communities.  Our high
CES scores are driven by numerous factors, including high
percentages of minority and low-income residents, high pollution
burdens, and persistent high unemployment.

Through the Gateway Cities Council of Governments, the member
jurisdictions have collaborated for over fifteen years on regional
planning efforts.  In recent years, the cities and communities have
collaborated on several major planning efforts that identify
numerous projects and investments that will reduce GHG emissions:

•	Subregional Sustainable Communities Strategy under SB 375, which
demonstrated that we could meet the regional GHG reduction targets
through our local and regional investments
•	Air Quality Action Plan identifying strategies that will reduce
GHG and criteria pollutant emissions
•	Comprehensive multi-modal Strategic Transportation Plan
identifying investments such as smart arterials, traveler
information systems, active transportation projects, transit lines,
highway projects, and associated stormwater management
•	Comprehensive Economic Development Strategy update
•	Integrated Regional Water Management Plan and Regional
Disadvantaged Communities Incentive Program (through the Gateway
Water Management Authority).
  
We have the following recommendations regarding the investment
criteria proposed in the Guidelines document:

1)	Proposed investments should be prioritized or given extra points
if they would represent an ongoing or multi-year commitment. 
Similarly, proposed investments should be prioritized or given
extra points if they are part of a regional plan that is supported
by multiple jurisdictions. These types of investment programs are
essential if the state is to reach its long-term GHG reduction
goals.  The Gateway Cities planning efforts enumerated above each
identify such multi-year, broadly supported programs that will get
the state closer to its emissions goal while also meeting the
disadvantaged community investment goals.

2)	Projects should be eligible for funding if they would reduce GHG
emissions by means of enhancing transportation efficiency through
technology, for example in the arena of goods movement.   The
Gateway Cities have developed and demonstrated intelligent
transportation systems and related technologies that will reduce
port-area congestion and thus reduce GHG and criteria pollutant
emissions.  Several other such projects could be implemented using
cap-and-trade funds and should be eligible.

3)	The funds should also be made available for investment in
infrastructure that will support the deployment of alternative
transportation fuel/energy sources, such as natural gas, hydrogen,
and electricity.  Without sufficient supporting fueling or charging
infrastructure, these alternative technologies are unlikely to be
adopted, thus hampering progress towards state emissions goals.

4)	Funding for home retrofits such as weatherization should be
prioritized for homes near railyards and similar industrial
facilities.  In these locations, this type of energy efficiency
project can have a dual benefit of also reducing the noise impacts
from proximity to industrial sites.

5)	As regulations are developed, we would recommend that if the
funds are to be invested in disadvantaged communities, no local
matching funds should be required.  To require such a match would
be contrary to the spirit of the legislation in directing resources
to communities in need.

Thank you again for the opportunity to comment on this important
initiative.

Submitted September 15, 2014, by Nancy Pfeffer, Director of
Regional Planning, Gateway Cities Council of Governments.