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Dear Air Resource Board,
Thank you for accepting comments on the proposed Beneficiary
Mitigation Plan (hereinto referred as the Plan). Our comment is on
the sentence on page 4 of the Plan, which reads "The proposed
funding above provides a balanced approach for fully mitigating the
excess NOx by investing in cost-effective project using cleaner
combustion technologies, such as low NOx, and for committing to
long-term goals by investing in zero-emission technologies." The
Greater Sacramento Economic Council  asserts that the Plan does not
invest in zero-emission technologies, rather, the Plan invests in
the consumption of zero-emission technologies. Our comment is that
CARB should invest $11.2 million in a business startup accelerator
focused on future mobility sited in the Greater Sacramento region
to ensure a true investment in zero-emission technologies.

For CARB to have a positive impact on the workforce and job growth,
the funds must be put towards a targeted investment such as a
business startup accelerator focused on future mobility. Germany, a
global leader in ZEVs, has used this model to create advanced
industry jobs and spur innovation. Implementation of the German
future mobility accelerator model in Sacramento is expected to
generate $154 m in direct economic impact (and an indirect economic
impact of $4.86 b), prepare the next generation of auto industry
workers, and create a robust economic cluster. 

The suggested model would align well with CARB's current investment
Plan to reverse the disproportionate impacts of VW's 10,000 tons of
greenhouse gas on vulnerable populations. A center focused on
future mobility in Sacramento would offer educational experiences
to K-12 students (a vulnerable population), technicians and
engineers. Such a center would also provide education and design
development support for innovations in the automotive industry and
serve as the foundational building block to a future mobility
cluster here in Sacramento. The long-term outcome of this
investment will fill in the missing link in what is CARB's expected
investment impact: it will create inclusive job opportunities for
our low, middle and high-skilled labor force through ZEV
automobile/component manufacturing and R&D. The economic impact of
implementing this model is expected to result in a total of 4,860
direct and indirect jobs for the Sacramento region.

Full implementation of this model in Sacramento would need an
investment of $11.2m from the VW Environmental Mitigation Trust,
which would be leveraged to gather $86m in private investment for
implementation support. Investments in inclusive job growth will
drive sustainable growth in the ZEV industry, and we suggest you
start here in Sacramento.

Sincerely,
Barry Broome, 
President & CEO of the Greater Sacramento Economic Council

^1The Greater Sacramento Economic Council (GSEC) is a non-profit
organization whose mission is to drive sustainable, regional
economic growth.