Comment Log Display

August 26, 2015

The Honorable Mary D. Nichols
Chair, California Air Resources Board
1001 “I” Street
Sacramento, CA 95814

RE: Cap-and-Trade Auction Proceeds Second Investment Plan

Dear Chair Nichols:

Thank you for your leadership and service to the State of
California. Your vigilant work in advocating for our environment
and public health has helped California play an international role
in efforts to address climate change. On behalf of the seven
elected members of the East Bay Regional Park District’s Board, we
wish to officially comment on the Cap-and-Trade Auction Proceeds
Second Investment Plan.

The Park District is a steward of nearly 120,000 acres in the east
San Francisco Bay – one of the most urbanized regions of California
– and operates 200 plus miles of paved active transportation
trails. The District is well positioned to support the State’s
efforts to achieve greenhouse gas reduction objectives.

The recent Concept Paper for the Cap-and-Trade Auction Proceeds
Second Investment Plan highlights a number of promising synergisms
with District operations. The Concept Paper clearly states more
than once that “achieving the State’s mid- and long-term climate
targets and goals will not be possible without investing now in
California’s natural resources, particularly through protection and
improved land management.” On behalf of the Park District, we
wholeheartedly agree.

Carbon Sequestration and Land Use Planning:
Based on an evaluation by ICF Jones & Stokes, the average amount of
carbon sequestered by the Park District’s lands is over 91,157
metric tons – the equivalent of removing 16,317 passenger cars and
sport-utility vehicles from the road annually, saving approximately
over 10.4 million gallons of gasoline. By preserving natural land
in perpetuity, the District’s parklands represent an important
permanent carbon stock of over 2.8 million metric tons (estimates
last updated in 2011). Additionally, our properties form natural
boundaries encouraging more sustainable and higher density
communities, which result in healthier lifestyles, increased
transit ridership, and more walkable cities. When considering the
stated goal of reducing greenhouse gases through improvements in
land use planning in major urban areas, the Park District is a
model example of what is possible. Directed financial incentives to
protect and maintain additional open space would present the
opportunity to expand the State’s stated Sustainable Communities
Strategies land use planning goal.

Urban Wildland Interface Fire Fuels Reduction:
District employees were first responders to the 1991 East Bay Hills
fire when 25 people died and 4,000 homes were destroyed resulting
in $1.5 billion in damages. According to studies,
from 2001-2010, annual carbon losses from forests and wildlands in
California represented as much as five to seven percent of state
carbon emissions – and the frequency of wildfires has
intensified since 2010. The Park District’s Fire Department and
Wildfire Hazard Reduction and Resource Management Plan demonstrate
our commitment to the best possible fire safety along
the urban/wildland boundary, but it is a multi-million dollar
on-going effort and worthy of Greenhouse Gas Reduction Fund (GGRF)
investment. We agree with other natural resource agencies and
advocates that increasing CAL FIRE funding for urban and rural
forest conservation should be in the 7-8% percent range.

Urban Greening:
While thinning highly flammable, non-native vegetation such as
eucalyptus is necessary in urban wildland interfaces like the East
Bay Hills, funding for the Urban Greening for Sustainable
Communities Program, overseen by the Strategic Growth Council and
administered by the Natural Resources Agency, should be expanded.
The planting of native, high sequestration value
trees and other less flammable native vegetation should be
incentivized. We also agree that, as will be expanded upon later in
these comments, we need to make our communities more climate
resilient. Including the Carbon-Smart Green Infrastructure concept
– which includes parks, wetlands, watersheds and greenways – as
part of the GGRF would be a significant benefit
for our state’s climate objectives. We support creating a 4-5%
allocation for a Carbon-Smart Green Infrastructure Program to
integrate more co-benefits into the Urban Greening for
Sustainable Communities Program.

Coastal Resiliency:
The green infrastructure managed by the Park District on over 40
miles of Bay-Delta shorelines provides the first line of defense
and resiliency against sea level rise for millions of people in the
East San Francisco Bay region. Adequately managing District
shoreline properties yields quantifiable greenhouse gas (GHG)
benefits. In addition, multiple resiliency co-benefits are
provided – adaptation to sea level rise, improved water quality and
wildlife habitat, to name a few. The Park District has developed
innovative, adaptive strategies to Bay and Delta shorelines – such
as the multi-million dollar Breuner Marsh wetlands restoration
investment in Richmond and the $5.6 million sand replenishment
effort along Shoreline Drive in Alameda – which provide buffer
zones for homes and infrastructure while providing multiple
co-benefits to the region. The Park District is restoring and
creating tidal wetlands in anticipation of sea level rise. The
development of “horizontal levees” and other adaptive ecosystem
based strategies offer the best opportunities to protect shoreline
communities from storms, flooding, and sea level rise. These
co-benefits will become increasingly important in providing
protection to billions of dollars of investment along the State’s
shorelines. We support meaningfully expanding the pilot concept of
investing in restoration of wetlands areas to increase carbon
sequestration and provide co-benefits such as increased native
species populations and water quality improvement.

Economic Benefits:
A recent San Francisco Public Press report indicates builders plan
to invest more than $21 billion in offices and homes in flood-prone
areas, where waters could climb 8 feet above today’s high tide by
the end of this century. This is in addition to the $25 billion of
vulnerable investment around the Bay already identified. Given the
immense economic investment in need of natural, green
infrastructure resiliency strategies, we believe more Cap-and-Trade
auction proceeds should be allocated to wetland development,
enhancement, and restoration. As the Concept Paper indicates,
“wetlands not only sequester carbon, they are the first line of
defense against sea-level rise and storm surge.” We further agree,
“these co-benefits should be sought at every opportunity and
pursued through innovative integration of natural resources into
other GGRF investment priorities, such as energy and sustainable
communities.” Again, meaningful financial investment in wetlands
management should be a high priority in the Second Investment
Plan.

CalEnviroScreen:
East Bay cities such as Richmond, Oakland, and Pittsburg have
genuine disadvantaged communities. Under the CalEnviroScreen
criteria, however, disadvantaged communities near the Bay or Delta
shorelines receive an oversimplified analysis. By way of example,
the overly objective process could exclude projects like a fishing
pier along the Richmond shoreline or in West Oakland since it would
consider the San Francisco Bay as part of the “service area” and,
by virtue of no population density in the water area, undervalue
the project benefit. The reality in these communities, however, is
that the fishing piers would be used by subsistence anglers from
nearby neighborhoods. These shoreline parcels are also key in
developing resiliency to sea level rise as mentioned in the
previous paragraph. The CalEnviroScreen criteria need to reflect
the diversity of California’s landscape of disadvantaged
communities. A regional approach to CalEnviroScreen should be
adopted.

Paved Trail Active/Green Transportation Network:
In the mid-1970s, the Park District pioneered the concept of
developing an integrated network of paved bicycle and pedestrian
trails linking the 33 communities throughout the East Bay. Working
closely with local and regional transportation planners and transit
agencies, the Park District has developed over 200 miles of paved,
non-motorized trails. These “Green Transportation” corridors
provide “last mile” connections to transit, as well as access to
schools, employment centers and businesses. Providing safe and
convenient non-motorized alternatives for commuters, students,
employees and shoppers reduces highway congestion, greenhouse
gasses and our dependence on fossil fuel, creates livable
communities, and provides the opportunity for a healthy lifestyle
close to home. Due to the San Francisco Bay Area’s mild climate,
these transportation alternatives are used year-round. The Park
District also has a history of working with communities along the
Iron Horse Trail to develop, finance and manage overcrossings of
key, busy intersections. Overcrossings, such as the Treat Boulevard
bicycle/pedestrian bridge near the Pleasant Hill BART station,
reduce the need to stop traffic below for bicycle/pedestrian
crossings, thus reducing traffic idle times and, therefore,
greenhouse gas emissions. Completing the remaining overcrossings
and gaps in the paved trail network will require significant
investment from multiple partners, including Cap-and-Trade
proceeds. We support an increase of GGRF investment in Active
Transportation.

As is stated in the Draft Concept Paper, “there is a strong history
of land conservation in California [and particularly the East Bay]
to protect wildlife, preserve agricultural viability, improve water
supply and quality, and provide parks and open space for residents
and visitors from around the world.” The District concurs that
“California’s lands should be protected and managed holistically
and in a way to systemically utilize natural and working systems to
reverse carbon loss and to preserve and grow carbon stocks.” To
reach our collective goals, there must be significant investment
from Cap-and-Trade proceeds in managing, maintaining and restoring
our natural lands – including the parks, open space, wetlands, and
rangelands of the East Bay.

Thank you again for your leadership on this issue. We look forward
to continuing to work with you. Please feel free to contact us if
you have any questions or would like additional support
documentation.

Regards,

Robert E. Doyle
General Manager
East Bay Regional Park District

cc:
Governor Edmund G. Brown, Jr.
The Honorable Matthew Rodriquez, Secretary, California
Environmental Protection Agency
The Honorable John Laird, Secretary, California Natural Resources
Agency
The Honorable Michael Cohen, Finance Director, California
Department of Finance
East Bay California Legislative Delegation
EBRPD Board of Directors