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Comment 135 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Jerry
Last Name: Craig
Email Address: jcraig@tustinca.org
Affiliation: Cityof Tustin
Subject: Disadvantaged Communities definition
Comment:
The definition of Disadvantaged Communities does not fully recognize the enormous challenges faced by former military bases and their surrounding communities. Typically, federal and state funding programs have recognized the unique challenges base closures bring to communities and, as a result, categorize former military bases at the top of projects that should receive assistance. SB 535 required CalEPA and ARB to maximize the benefits of investments to disadvantaged communities and achieve or exceed the investment targets. If the definition of disadvantaged communities remains as is, the failure to score former military bases in the lowest category, red, represents a missed opportunity to maximize benefits and exceed investment targets. In addition, it fails to take into account what other federal and state programs have recognized when assessing the barriers faced by former military bases. Former military bases can be ideal locations for reducing GHGs. The former Tustin Marine Corps Air Station is transit-rich with an adjacent Metrolink station and future commercial development will provide employment opportunities close to nearby residential development. While the former MCAS Tustin scores high in environmental measures on Cal Enviroscreen, our proportionally low population is reducing the score of this otherwise hJigh-scoring area. We request CalEPA and ARB enhance their scoring methodology to reflect an acknowledgement that the former military bases are truly disadvantaged communities. Thank you.
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Date and Time Comment Was Submitted: 2014-09-16 12:59:39
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