Placer Land Trust

11661 Blocker Drive #110
Auburn, CA  95603
(530) 887-9222
Fax (530) 888-7720
info@placerlandtrust.org
www.placerlandtrust.org

Board of Directors

Fred Yeager, President

Barbara Brenner
Rich Ferreira
Gina Giambruno
Robert Gilliom
Jim Haagen-Smit
Doug Houston
Charles Leininger
Gregg McKenzie
Thomas McMahan
Larry Menth
Mehrey Vaghti
Larry Welch

Executive Director

Jeff Darlington

Placer Land Trust works with willing landowners and conservation partners to permanently protect natural and agricultural lands in Placer County for future generations.  

Placer Land Trust is a private, nonprofit 501(c)(3) charitable organization incorporated in 1991, accredited by the national Land Trust Accreditation Commission.  Federal Tax Identification Number:  68-0223143.

August 31, 2015

Mary D. Nichols, Chair
California Air Resources Board
1001 "I" Street
Sacramento, CA 95814

Re: Cap-and-Trade Auction Proceeds Second Investment Plan Draft Concept

Dear Ms. Nichols,

Thank you for the opportunity to comment on the Cap-and-Trade Auction Proceeds Second Investment Plan Draft Concept Proposal (Investment Plan). 

Placer Land Trust is a land conservation organization that works with willing landowners and conservation partners to permanently protect natural and agricultural lands in Placer County for future generations. We are an accredited land trust through the National Land Trust Accreditation Commission.  Since 1991 we have protected more than 8,000 acres in Placer County, which we now manage and monitor in perpetuity. 

On behalf of our organization and our members in the community, I would like to thank you for identifying increased investment in conservation in the proposed guidelines.  Investment in conservation meets numerous goals and objectives for the State of California in addition to reducing GHG emissions, and therefore multiplies the return the State will receive on the investment of Cap-and-Trade Auction Proceeds.

On the following pages I have provided comments on some areas of the Investment Plan, with specific recommendations related to barriers to rural conservation investment, and the importance of permanent protection of resource lands.

I appreciate all of the tremendous effort that has been made on these issues and presented in the draft concept paper, and I look forward to seeing the Cap-and-Trade program leverage the conservation work being done by Placer Land Trust and others around the State.  Please feel free to contact me if you have any questions about our comments or recommendations.

Sincerely,

Jeff Darlington

Greater Rural Community Investment is Warranted

We couldn’t agree more strongly that rural communities and small businesses have a critical role to play in achieving the state’s GHG emission reduction goals both now and beyond 2020.  We fully support the idea of developing additional programs or criteria within existing programs that will allow for more investment in rural resource areas to achieve statewide emission reduction, carbon sequestration and social/economic co-benefit goals.

We appreciate the explicit recognition that disadvantaged communities are both critical to the state achieving its goals and also in need of more targeted assistance – via awareness and capacity-building as well as targeted funding – to access the GGRF program opportunities.  However, we believe that increased technical assistance and capacity-building should not be limited just to disadvantaged communities as defined by Enviroscreen. In particular, we feel it is very important to provide assistance to rural resource areas that contribute substantially to GHG emission reductions, carbon sequestration and other benefits, such as reliable production and distribution of goods and services.  

We recommend adding to Subsection “rural and other underserved areas” in Section III to ensure that assistance is provided to rural resource areas.  

Similarly, the stated intent to improve “areas that have traditionally lacked investment” should include rural areas, not just those identified by the Enviroscreen tool.  This is especially important in the rural forested communities where projects can contribute to important forest/fire-related GHG emission reductions, carbon sequestration and other benefits.

We recommend the addition to Subsection “rural and other underserved areas” in Section III to put the emphasis on all underserved areas.

Placer Land Trust recognizes the importance of addressing the transportation sector, since it is responsible for 37% of the state’s GHG emissions. And we agree that to effectively address vehicle miles traveled (VMT), the Cap-and-Trade program must link affordable housing with transportation. However, research shows that VMT reduction opportunities exist beyond major urban areas with high population, job, and transit densities. Analysis by the California Housing Partnership Corporation and the Center for Neighborhood Technology, for example, points out that while rural households account for fewer trips, the actual vehicle miles travelled per trip outpaces small cities and major regions across all income levels. So increasing mobility options through integrated transportation, public transit, active transportation, land use, and housing decisions in rural areas can have a substantial impact on VMT.  Cap-and-Trade investments in rural communities will therefore achieve significant VMT reductions.

More than 4 million people live in rural areas of the state that are not covered by Metropolitan Planning Organizations and therefore are not required to develop Sustainable Communities Strategies for transportation and housing. The 2nd Investment Plan needs to include a companion program to create better options for more transportation-efficient rural communities across the state, including those not identified by Enviroscreen as DACs.

We recommend adding a rural community component to the Sustainable Communities Subsection under Section IV.  

We recommend removing eligibility/scoring barriers from funding programs that disproportionately affect rural projects.  

Instead of disproportionately excluding rural projects, consider, for example, a) assigning different, or relative, jobs and housing density standards for different regions of the state, b) adding a rural assumptions element to the CalEEMod update to allow for more accurate modeling in non-urban areas, and/or c) identifying alternative program delivery mechanisms besides MPOs and SCSs to ensure that rural areas have access to program assistance and project implementation funds.

Placer Land Trust agrees with the needs assessment statement that “bio-energy systems in California lag and need additional financial support to advance the market” in order to achieve reductions in carbon and additional short-lived climate pollutants (also discussed in the Natural Resources and Waste Diversion section) and other benefits. Similarly, we support the concept of creating more incentives for small businesses to upgrade refrigerant and other systems to reduce short-lived climate pollutants.  We have seen such programs work very effectively through the Sierra Nevada Energy Watch program, for example.

We recommend broadening the target to include “rural and underserved communities” in addition to Enviroscreen-identified DACs.

This will achieve greater emission reduction, air quality and carbon sequestration benefits, since rural residents are more likely to burn wood as their primary heating source and have need of green waste disposal from yard trimmings, property maintenance, defensible space clearing, etc.

More Funding for Agricultural and Resource Land Conservation is Warranted

We support the need to use the 2nd Investment Plan to direct more investment into management, restoration and protection of natural resources – including forests, wetlands, rangelands and agricultural lands – since the benefits from such activities take longer to accrue yet are critical to helping the state achieve its mid- and long-term emission reduction, carbon sequestration and co-benefit goals. 

The largest vehicle for GHG emissions reduction through large-scale carbon storage is the protection and proper management of large tracts of intact forest. The world’s forests are estimated to sequester up to 30% of annual global anthropogenic carbon emissions. In California, approximately 113,000 acres of forest were converted to other uses between 1969 and 1998.  Protection of forests with conservation easements, with management to maximize carbon storage, is essential to meeting our GHG emissions reduction goals.

There is currently a $4.2 million allocation to CALFIRE’s Forest Legacy program for forestland threatened by conversion, but the initial 3-year investment plan does not appropriately represent the critical role forest conservation plays in achieving our long-term GHG emission reduction goals. The current Enviroscreen definition of DAC leaves out virtually all the forested areas of the Sierra, southern Cascade and other interior mountain areas (as shown on Figure A-1, p. 25, regarding Statewide Map of Disadvantaged Communities).  We need to ensure that forested communities are eligible for conservation program funding, which will also help achieve significant VMT reduction benefits in rural areas.

We recommend increasing the allocation of funding for agricultural conservation easements, and we also recommend that the target be broadened to include “rural and underserved communities”.

Additionally, we believe an increase funding for agricultural conservation easements is warranted considering the following: agricultural conservation easements are an essential tool to store carbon, help cities combat sprawl, and maintain working lands close to where people live. Rangelands and croplands encumbered by agricultural conservation easements are protected so they can continually sequester carbon in soils – through the growth of vegetation and accumulation of organic matter (as well as the prevention of development). Agricultural lands also provide other climate and public benefits such as food security and jobs, and decrease GHG emissions from long distance commutes and food transportation. 

We recommend increasing the proportional amount of dedicated funding that goes to protecting existing agricultural lands that are at risk of conversion to higher-carbon uses.  In particular, we recommend that funding for the Strategic Growth Council’s Sustainable Agricultural Lands Conservation Program (SALCP) should be significantly increased immediately, and the SALCP should receive an increasing percentage of proceeds in future years.

We hope you find our above comments and recommendations comprehensive and equitable to all Californians.  Like the State of California, Placer Land Trust serves both urban and rural communities. In this way we feel it is our duty, and also the duty of the State, to recognize that climate change affects all Californians and therefore the Cap-and-Trade program should be benefit all communities. We also recognize the multiple benefits of investing in agricultural and resource conservation, and we believe greater investment of Cap-and-Trade funds in such conservation will pay much greater dividends to California’s environment, its economy, and its future.

Respectfully submitted by:

Placer Land Trust
Attn: Jeff Darlington, Executive Director
11661 Blocker Drive, Suite 110
Auburn, CA 95603
(530) 887-9222
jeffd@placerlandtrust.org