Comment Log Display

To: California Air Resources Board
Regarding: Cap-and-Trade Auction Proceeds to Benefit Disadvantage
Communities 
From: Association of California Community and Energy Services
(ACCES)

ACCES is an association of public and private non-profit, profit,
county agencies that provide weatherization to the low-income
communities throughout the state. Most of these agencies and
counties have provided these services for over 25 years.  These are
the entities who see the outcomes and benefits of the services
directly to the disadvantaged households.  Our comments are in
concern of the following.

Definition of Disadvantage Communities: 
•	Opening up the definition of Disadvantage communities is a
necessary step in establishing a successful program. Although there
are five current methods proposed in identifying disadvantage
communities, we feel they are still unable to capture the low
income population as a whole in the state of California.   
•	We are concerned that the current Cal Enviro Screen tool fails to
identify all the disadvantage communities throughout the state,
leaving many areas unable to benefit from the cap and trade
revenues. We understand the parameters that went into designing the
tool, however, we feel it fails to fully support the benefit
certain direct impact projects can have, such as weatherization.
Expanding to areas beyond what is currently defined as a
disadvantage community will allow more opportunities to reduce
greenhouse gas emissions and provide healthier and safer living
conditions for many low income Californians. 
•	ACCES proposes that to be considered a disadvantage community
they only have to meet one criteria characteristic within the high
pollution category or population characteristic. In its current
form money will be disproportionally spent throughout the state
leaving many areas without much needed help.  The heavy weight on
the intersections has eliminated many areas.  We understand that
the funding is limited now but still feel once a definition is in
place it will be difficult to change.  The inclusion of all of the
state’s low income to at the least having access to these benefits
from this funding is how we see the intent of the dollars and the
programs.  It will be a very difficult task to have a neighbor
across the street from a DAC census tract denied because of
location. The programs are diverse in their anticipated impact and
the method of identifying disadvantaged communities most in need
should be tailored to each program individually.


Respectfully Submitted,
 

Arleen Novotney
Executive Director