Comment Log Display

I am writing on behalf of Sierra Business Council (SBC), a
non-profit network of 4,000 business, local governments and
community partners working to foster vibrant, livable communities
in the Sierra.  We appreciate the chance to comment on the Draft
“Interim Guidance to Agencies Administering Greenhouse Gas
Reduction Fund Monies” related to investments to benefit
disadvantaged communities, released August 22, 2014.

While we understand the rationale and obvious need to focus
resources on the state’s most disadvantaged communities, we are
concerned about a number of the indicators CalEnviroScreen 2.0 uses
to identify those communities.  We support the CalEnviroScreen tool
(Method #1) in general because it offers a scientifically based
scoring rubric; however, the current scoring criteria skew against
rural areas, meaning the screening system fails to meet the intent
of the underlying legislation (AB 32) to reduce emissions and
improve conditions across the entire state.  Since CalEnviroScreen
is being used to identify disadvantaged communities for purposes of
other funding sources, as well, it is critical for the tool to
adequately address geographic and other disparities affecting the
current version.  

Per AB 32, global warming affects all parts of the state, posing a
“serious threat to the economic well-being, public health, natural
resources, and the environment of California” [§38501].  As an
example, adverse impacts are already being felt on Sierra snowpack,
which in turn affects water supply, water quality and major
industry sectors, such as agriculture, wine, tourism, skiing,
recreational and commercial fishing, and forestry.  In addition,
warmer temperatures and drier conditions are creating
record-breaking wildfires in the Sierra, affecting local households
and businesses, burning up stored carbon, and negatively impacting
air quality, water quality and, in some cases, energy distribution
in the Sierra and connected urban centers.

AB 32 clearly states that GHG emission reduction measures should
maximize additional environmental and economic co-benefits for
California (§38562 and §38570).  In addition to 
“reductions in other air pollutants” – which is reflected in the
“pollution burden” portion of the CalEnviroScreen scoring rubric,
the list of co-benefits includes “diversification of energy
sources, and other benefits to the economy, environment, and public
health,” which are not as robustly reflected in the scoring
criteria.
  
Disadvantaged rural communities will be paying into the
Cap-and-Trade Greenhouse Gas Reduction Fund indirectly through
higher prices for gasoline and other products that fall under the
cap.  They should not be unnecessarily handicapped in achieving
benefit, as well.  As a result, we ask you to amend the
CalEnviroScreen indicators to ensure that benefits accrue
throughout the state – especially under the Affordable Housing and
Sustainable Communities Program, the Energy Efficiency programs,
the Wetlands and Watershed Restoration Program and Fire
Prevention.

To that end, please see the attached letter outlining our
observations and suggestions to more thoroughly address the letter
and intent of the underlying laws.