Comment Log Display

Please see uploaded letter for signatures, footnotes, and
attachment.  A copy of the text is below:

To: California Air Resources Board, Department of Finance, and
Office of the Governor

The Center on Race, Poverty & the Environment (CRPE) submits these
comments on the Cap and Trade Auction Proceeds Investment Plan on
behalf of the undersigned individuals and organizations.  We
believe that funds and projects under this Investment Plan should
be directed to communities that fall within a 6 mile radius of
facilities regulated under Cap and Trade.  Communities that are
located in this area are more severely impacted by co-pollutants
and bear the burden of a Cap and Trade system. 

To be clear, we are vehemently opposed to California’s Cap and
Trade system.  Cap and Trade allows polluters to pay their way out
of making real on-site reductions at the expense of low-income
communities, communities of color, and indigenous communities.  Cap
and Trade ignores the reality that location matters.  Reductions of
greenhouse gases on-site reduces the co-pollutants emitted into the
surrounding community – a benefit that is forgone when that
facility buys allowances or offsets for planting trees somewhere
else.  While we are opposed to Cap and Trade and profits made at
the expense of our communities’ health, we feel we had to engage in
this process to keep our communities from being further ignored and
harmed by these policy decisions.  Any proceeds from Cap and Trade
should be invested back into the communities that are paying the
highest price for this system – communities within 6 miles of a Cap
and Trade facility.  

Populations living within 6 miles of industrial facilities
disproportionately bear the impacts of co-pollutant emissions, such
as particulate matter and toxics.   Over two-thirds of California’s
low-income African Americans and about 60% of low-income Latinos
and Asian/Pacific Islanders live within 6 miles of a Cap and Trade
facility.   Under Cap and Trade, the residents of these communities
will not receive the benefit of co-pollutant emission reductions,
and could even see an increase in emissions, if facilities purchase
allowances and offsets as Cap and Trade allows.  This violates
federal civil rights laws.   When comparing health effects of
co-pollutants, actual disparate impacts on people of color are even
more severe than can be captured by discrepancies in exposure
alone, as a result of the particular vulnerabilities of this
population.   As the California Department of Public Health (CDPH)
explained in its 2010 Health Impact Assessment of Cap and Trade,

[l]ow-income communities and communities of color in California are
disproportionately impacted by environmental exposures and have a
greater susceptibility to the negative health impacts of
environmental risk because of existing health and socioeconomic
vulnerabilities.   

Co-pollutant exposures from Cap and Trade facilities add to the
tremendous cumulative exposures to a variety of environmental
stressors borne predominantly by people of color.   As people of
color tend to be more susceptible to health risks and have lower
access to services to mitigate negative health outcomes, exposures
to co-pollutants are “exacerbated by poverty, poor quality housing,
and insufficient health care access in these communities.”   The
resulting picture is one of stark discrepancies in both exposures
and health outcomes.     

Because of this, we believe that all cap and trade proceeds should
be directed back into those census blocks within a 6 mile radius of
cap and trade facilities.  Given the high rate of minority and low
income communities found within 6 miles of a regulated facility,
this prioritization would likely meet the mandates of AB 1532 that
at least 25% of the investment benefit “disadvantaged communities”
and SB 535 requiring that at least 10% of investments occur within
“disadvantaged communities.”  

There is no amount of money that can remedy the disproportionate
impact that the Cap and Trade system inflicts on low-income
communities, communities of color, and indigenous communities. 
While we continue to strive toward a fair and just solution to
reducing greenhouse gases in California, we sincerely hope that you
do not continue to ignore our communities and that you will take
this small step toward recognizing that our communities – low
income communities and communities of color – are paying the true
cost of Cap and Trade with our health.