Comment Log Display

June 18, 2010


Mary Nichols, Chairman
California Air Resources Board (CARB)
1001 “I” Street
Sacramento, CA 95814

RE: SB 375 Community Participation 

Dear Chairman Nichols:

The Kennedy Commission is a broad based coalition of community
organizations and advocates that focus on building sustainable
communities by creating a supportive environment for the creation
of affordable home opportunities for families earning less than
$20,000 annually in Orange County. 

The Commission would like to acknowledge the extensive work the
California Air Resources Board (CARB) has done to prepare a
framework to embark on the implementation of SB 375 and setting
regional targets to reduce greenhouse gas emissions from motor
vehicles. 

As CARB move towards planning for SB 375 implementation and
setting regional greenhouse gas emission targets, the Commission
would like to emphasize the importance of seeking out and
considering input from traditionally underrepresented group and
organizations that represent or advocate for these underrepresented
groups. We want to ensure the plan and strategies provide for early
and meaningful public participation in the decision-making
processes in the implementation of SB 375 and setting regional
targets for greenhouse gas emission.  In addition, we ask CARB to
set ambitious targets that facilitates the development of
sustainable communities at a regional level. 

The Commission believes the implementation of SB 375 and setting
regional targets for greenhouse gas emissions can address
environmental, transportation and housing issues to create more
sustainable and healthier communities in Orange County. While SB
375 has great potential to enhance the quality of life for
residents, the Commission is deeply concerned that without specific
language, strategies and modeling, SB 375 implementation strategies
could fail to address housing needs and affordability as key
factors to reducing vehicle trips and commutes that will create
more sustainable communities. 


Orange County ranks among the top ten least affordable
metropolitan areas in the country, the need for homes affordable to
low-wage earners is enormous (National Low Income Housing Coalition
(NLIHC), 2010).  Orange County’s Fair Market rent for a two-bedroom
apartment is $1,594 and the housing wage (hourly wage needed to
afford a typical two-bedroom apartment) is over $30.00 per hour
(NLIHC, 2010).  

In order to afford the average priced apartment in Orange County,
a minimum wage earner must work 151 hours a week or have 3.8
full-time jobs (NLIHC, 2010).  Also, the high cost of housing
forces many households looking for an affordable home to live
outside Orange County (i.e. Inland Empire) while working and
commuting to Orange County’s job centers (Orange County Business
Council Workforce Housing Scorecard, 2007). 

As CARB reviews the Metropolitan Planning Organization’s (MPO)
planning scenarios and prepares to release the region’s draft
greenhouse gas emission targets, the Commission urges that the
following issues be addressed:

Effective Public Participation

The creation, planning process and implementation of SB 375 should
be conducted with meaningful outreach and participation from: 1)
low-income and minority community members and; 2) the partnering of
affordable housing advocates and developers to ensure that the
un-met needs of homes affordable to families are addressed. 

Affordability for Extremely Low, Very Low and Low-Income
Households

SB 375 should be created and implemented to ensure that the
development of affordable homes for extremely low, very low and
low-income families are encouraged and facilitated.  Specifically,
CARB should ensure MPO planning scenarios and the draft target
setting encourages and facilitates residential rental developments
that are 100% affordable to lower income families. 

While SB 375 promotes higher-density development, higher-density
does not necessarily produce more affordable homes. In Orange
County, higher density mixed-use and transit oriented development
have been planned or developed to provide housing opportunities for
higher income households.  These developments lack housing
opportunities that are affordable for lower income households.

Performance Measure Consideration

To facilitate the development and objectives of an effective SB
375, the process in setting the region’s greenhouse gas emission
targets should reflect, analyze and incorporate performance
measures such as: 1) co-benefits that positively impacts and
maximizes community and environmental community benefits and; 2)
jobs-housing “fit” that addresses the discrepancies between the
housing costs of a community and the actual wages and earnings of
the residents living in the community. 

By addressing these concerns, our goals in the implementation of
SB 375 and reducing greenhouse gas emissions would be achieved. 

The Kennedy Commission looks forward to working with CARB to
achieve our mutually beneficially goals in creating more
sustainable, healthier and equitable communities in Orange County. 
Specifically, the Commission welcomes the opportunity to continue
our dialogue that will result in the production of new homes
affordable to extremely low, very low and low-income households. 

If you have any questions, please feel free to contact me at (949)
250-0909 or cesarc@kennedycommission.org.

Sincerely,

Cesar Covarrubias
Executive Director

cc: Hasan Ikhrata, SCAG