Comment Log Display

Allocations of the Greenhouse Gas Reduction Fund should go to
programs that provide assistance to improve energy efficiency,
solar and other distributed renewable energy generation, improved
public transit, and transit oriented development and housing
designed to assist low-income communities which disproportionately
suffer the impacts of greenhouse gases and related air and water
pollution.

The CPUC’s Energy Savings Assistance Program provides no-cost
weatherization services to low-income households who meet the CARE
income guidelines.  Attic insulation, energy efficient
refrigerators, energy efficient furnaces, weather-stripping,
caulking, low-flow showerheads, water heater blankets, and door and
building envelope repairs which reduce air infiltration are
effective means of reducing energy use and thus GHG.
  
Investments in energy efficiency also reduce localized air
pollution from power plants; reduce reliance on capital intensive
and environmentally disruptive electric transmission lines; create
jobs carried out by California workers, businesses, and community
based organizations; generate beneficial economic multiplier
effects to local economies; and increase energy and climate
engagement.

Energy efficiency programs can be structured to promote or provide
job creation, workforce development and green jobs training
opportunities. EE improves indoor air quality, making low-income
homes more comfortable and safe for sensitive populations such as
children and the elderly. Finally, EE can provide enduring
long-term bill relief to disadvantaged communities, which spend a
disproportionate percentage of their income on basic services like
electricity, natural gas, and water. EE also provides opportunities
to engage low-income communities on the relation between their
consumption and climate change, as well as steps they can take to
address it.
Providing Disadvantaged communities with low cost solar generation
and passive solar space heating and water heating would be a good
use of cap and trade revenues.  The California Solar Initiative
(CSI) Single-family Affordable Solar Homes (SASH) Program and
Multi-family Affordable Solar Housing (MASH) Program offer solar
incentives to energy customers.  SASH and MASH should be scaled up
with the goal of reaching more low-income household across
California.

Distributed solar energy provides a zero-carbon alternative
generation resource. Home solar energy systems reduce a households
carbon footprint, cut greenhouse gas emissions, and help fight
global warming.  Home solar systems reduce localized air pollution
from power plants; reduce reliance on capital intensive and
environmentally disruptive electric transmission lines; create jobs
carried out by California workers, businesses, and community based
organizations; generate beneficial economic multiplier effects to
local economies; and increases energy and climate engagement for
disadvantaged communities.

Some of the money should go to transit in disadvantaged
communities.  The State Transit Assistance (STA) program provides
funding to local public transit agencies and regional
transportation planning agencies (RTPAs) to fund a portion of the
operations and capital costs associated with local mass
transportation programs. Funds should be allocated to operate
increased levels of public transit service statewide, but
particularly in the Central Valley because of the concentration of
disadvantaged communities there. Funds would target routes with
strong GHG emissions reduction potential and pay for operating
costs associated with increased service levels. Capital uses would
be limited to maintenance and the purchase of new transit vehicles
necessary to operate additional service.

Reducing driving through increased use of public transit is a
necessary component of an effective strategy to meet AB 32 goals.
California’s transportation sector is responsible for the most GHG
emissions of any sector, and private vehicle use is the largest
contributor to a household’s carbon footprint.

Public transit provides Californians with a low-carbon alternative
to driving. Studies show that public transit reduces automobile
use, produces significantly lower GHG emissions compared to
single-occupant vehicle use, and facilitates higher density
development and travel patterns with lower carbon impacts.
  
Using public transit is one of the most significant steps
individuals can take to reduce household GHG emissions.  By taking
public transit to work instead of driving, an 
individual with a 20-mile round trip commute will reduce his or her
CO2 emissions by approximately 4,800 pounds per year.  This
represents a 10% reduction of all GHG emissions for a typical
two-adult two-car household.  If a two-car household eliminated 
one car and used public transit instead, it could potentially see a
30% reduction in its GHG emissions.

While transit ridership has reached record levels in recent years
and demand continues to rise, transit systems have struggled to
maintain existing service levels due to insufficient funds to pay
for operating expenses. The recession’s impact on local 
revenues combined with diversions of transit operating funds by the
State between 2000 and 2009, forced nearly every transit agency to
implement deep service cuts and fare increases. Operating funds are
desperately needed as California already has an estimated $22
billion transit operating shortfall through 2020.

Public transit reduces localized air pollution, creates jobs
carried out by California workers (e.g., bus and train operators,
mechanics) and businesses, generates beneficial economic multiplier
effects to local economies,  and increases mobility for
disadvantaged communities.

Transit riders are disproportionately low-income and live in
households that have lower automobile ownership rates than the rest
of the population. Public transit also serves 
high concentrations of people of color, the elderly, persons with
disabilities, immigrants and youth. Increasing transit service can
be a powerful anti-poverty strategy as very-lowincome households
can spend up to 55% of their budget on transportation.  Households
that use public transit save an average of $6,251 per year.
  
To count towards the SB 535 25% minimum for funds spent to benefit
residents of disadvantaged communities, STA funds should provide
increased service on transit routes that carry high proportions of
disadvantaged residents. To count toward the 10% 
minimum for funds that are spent within disadvantaged communities,
STA funds should provide increased service on routes that run
through disadvantaged communities. Eligible uses of the SB 535
portion of the GGRF allocation would include transit 
operating expenses and fare subsidies that incentivize greater
transit utilization by disadvantaged residents, and capital uses
necessary to increase service levels.

Disadvantaged communities often lack access to public transit or
suffer from inadequate service levels and high fares. For many of
their residents, public transit is the primary way to access
employment, education, health care, grocery stores and other 
vital necessities. Cuts to public transit services throughout
California over the past decade have fallen hardest on low-income
residents, people of color, seniors, and persons with disabilities.
In Los Angeles alone, nearly 1 million hours of bus service were
eliminated between 2007 and 2011, affecting a ridership population
that is overwhelmingly low-income and 90 percent African American,
Latino, and Asian Pacific 
Islander.  The average income of an LA Metro bus rider is just
under $14,000.

Residents of disadvantaged communities in the Central Valley--as
indicated in the maps displayed at the workshop in Fresno on
February 19, 2013--suffer greatly because of the lack of adequate
public transit.  The long travel distances from small rural towns
to jobs and services in large cities adds greatly to greenhouse gas
generation.  Adequate public transit with more daily round trips
per day from small towns like Mendota and Huron to Fresno would
greatly reduce GHG produced when economically disadvantaged people
drive their old gas guzzlers long distances to jobs, shopping, and
services.  More public transit would have the co-benefit of
reducing transportation costs to these low-income rural residents. 
Presently, Central Valley Counties do not have the necessary
funding to provide this transit, so the GGRF could be well spent on
public transit in these areas.
  
Few burdens are associated with increasing transit service. Nominal
increases in traffic and emissions resulting from additional
transit vehicles in service are offset by overall 
reductions in traffic and emissions from reduced automobile use. In
contrast, transit capital expansion projects can involve
construction and activities that displace or otherwise negatively
impact surrounding neighborhood residents and local businesses.

The state’s Transit-Oriented Development (TOD) Housing Program
promotes the development of homes in close proximity to transit
access.  The program provides low-interest loans as gap financing
for rental developments that include homes affordable to
lower-income households, and as mortgage assistance for
homeownership developments. In addition, grants are available to
cities, counties, and transit agencies for infrastructure
improvements necessary for the development of specified housing
developments, or to facilitate connections between these
developments and the transit station.

CA Department of Housing and Community Development provides
transit-oriented housing affordable to very low income households,
who depend on and use transit at significantly higher rates than
the general population. SB 375 aims to reduce GHGs by coordinating
regional planning of transportation and land use so as to reduce
driving and increase transit use. TOD can be an important strategy
for meeting these goals. Proximity to transit is a major
contributor to transit use and can significantly reduce VMT.

By bringing housing closer to transit stops, TOD reduces VMT and
GHG emissions, especially when both jobs and housing are within
easy reach of transit. A 1993 study of California TODs showed that
of residents who had previously “lived away from transit, 52.3
percent switched to transit commuting upon moving within ˝ mile
walking distance of a rail station.”

TOD, however, is not by itself enough to reach the policy goals of
reducing VMT and GHG emissions.  In fact, it can backfire by
displacing lower income families from transit-rich urban
neighborhoods.  (TOD rents are typically 10-20% higher than in
comparable residential neighborhoods.) Residents with household
incomes under about $20,000 – those in the very low income category
– have far lower rates of auto ownership and higher rates of
transit ridership than the general population. A quarter of these
households own no car at all (compared to 8.3% overall), and
another half own only one car.

More dependent on transit, very low income residents take more than
four times as many transit trips as members of the population at
large.  When TOD displaces these families, it not only reduces
ridership by making transit inaccessible to the most frequent
transit riders, it also increases the likelihood that a very low
income household will purchase a high-polluting but cheap used car.
 For TOD to succeed as a GHG-reduction strategy, it must include
housing affordable to very low income families.

Providing housing near transit affordable to very low income
families has health, mobility and economic co-benefits. Health
co-benefits include reduced auto emissions, including
co-pollutants; increased active transportation (walking, biking),
associated with lower rates of obesity and chronic diseases like
diabetes; and health benefits associated with stable, safe and
affordable housing. Mobility co-benefits include greater
accessibility to transit; increased transit ridership, which
improves the economic viability of transit agencies and allows them
to increase service; and reduced vehicle traffic. Economic
co-benefits include greater job accessibility for low-income
families, the creation of permanent jobs carried out by California
workers (e.g., property managers, grounds maintenance staff, bus
and train operators, mechanics) and businesses; the generation of
economic multiplier effects to local economies; and the leveraging
of federal funding streams.  Construction of TOD projects leverages
private and federal investment and provides new job opportunities.

Finally, affordable TOD housing is an effective anti-poverty
program, significantly reducing the combined housing and
transportation (H+T) cost burden on low-income families.  Benefit
to Disadvantaged Communities:  Affordable TOD housing allows
disadvantaged residents to live near transit and jobs, reduces
household H+T cost burden, and stabilizes and protects against the
risk of displacement low-income residents who are core transit
riders. This increased residential stability has major health
benefits for low income families, such as  reducing stress and
increasing available resources for nutritious food and health care
costs. Proximity to transit increases access to amenities,
education, healthcare, grocery stores and other vital destinations,
especially for people of color, the elderly, people with
disabilities, and youth. When affordable TOD is located in healthy,
high-opportunity places, lower income families benefit from
improved health, education and economic outcomes.

Eligible uses of Greenhouse Gas Reduction Fund (GGRF) allocations
under SB 535 would include low-interest loans for affordable
homeownership and rental development affordable to very low-income
residents. To count towards the 25% minimum for funds spent to
benefit disadvantaged residents, GGRF allocations for the TOD
program should fund the development of housing affordable to very
low income residents near transit nodes, both in disadvantaged 
communities and in other communities. To count toward the 10%
minimum for funds that are spent within disadvantaged communities,
GGRF allocations should fund the development of housing affordable
to very low income residents near transit nodes in disadvantaged
communities.

Housing and transportation planning agencies would be required to
hold accessible workshops to solicit and consider input from
residents of disadvantaged communities for a proposed TOD project.
The workshops would occur early enough in the planning process to
influence staff recommendations on how to invest GGRF allocations. 
Local public workshops would identify high priority residential and
commercial development needs of disadvantaged communities for the
TOD project. To address high poverty and unemployment in
disadvantaged communities, they should be hired for jobs associated
with constructing the TOD project.  Without affordable housing, TOD
can impose displacement and other burdens on low-income residents,
including the loss of the small business that serve them. Funds
earmarked for the TOD Housing Program will protect against those
burdens by producing homes affordable to very low income
households. This will help stabilize gentrifying neighborhoods,
promoting mixed-income communities that include disadvantaged
residents and high propensity public transit users.