Comment Log Display

Mary Nichols,
Chairperson
California Air Resources Board
1001 I Street
Sacramento, CA 95184

Re: Local Governments’ Proposal for CARB Auction Revenue Investment
Plan

Dear Ms. Nichols, 

The undersigned cities, counties, special districts and
associations collectively have developed a proposal for investing
cap and trade auction revenue in local governments in an effort to
achieve the greenhouse gas reduction goals of AB 32 that is
consistent with the provisions of AB 1532 and SB 535.  We
respectfully request that our proposal be considered for inclusion
in the Investment Plan.

The underlying principle of our proposal is that the state would be
best served if it employed local governments as a delivery tool for
a range of investments, and that the Investment Plan should create
a program for local governments to access a portion of the funds
generated from the Cap and Trade auctions.

Local governments are already engaged in many of the same type of
GHG reduction activities contemplated in the Governor’s Budget and
are best able to identify and implement projects to reflect local
needs, leverage other funding and achieve the greatest reductions
of Greenhouse Gases.  Local governments have already developed
programs that improve energy efficiency, divert waste, increase
urban greening, upgrade fleets and facilities, and plan for cleaner
more efficient communities, but funding to continue these projects
is dwindling.

Another advantage for local governments is that they have a greater
understanding of the local economy, providing an advantage over the
state to leverage private capital and allowing auction revenue
funds to go further.

Our coalition would like to work with CARB and the Administration
to create an effective approach to maximize GHG reductions and
propel California’s communities forward through expenditure of
auction revenue.  As mentioned above, local governments can be a
key facilitator for the state to achieve these goals, and request
you consider the following principles in creating a local
government program:

1.	Allocate auction revenue for local assistance grants and other
financial assistance to develop and implement GHG emission
reduction projects;
2.	Administer the program in coordination with the Strategic Growth
Council
3.	Develop standards and guidelines for grant funds that achieve
one or more of the following:
a.	Promote public-private partnerships to implement energy
efficiency and clean energy projects with financing incentives for
residential and commercial facilities.
b.	Decrease air or water pollution
c.	Reduce the consumption of natural resources or energy
d.	Provide opportunities to achieve greenhouse gas emission
reductions in ways that increase localized energy resources
e.	Increase the reliability of local water supplies
f.	Increase solid waste diversion from landfills
g.	Increase electric vehicle infrastructure
h.	Achieve greenhouse gas emission reductions in ways that reduce
vehicle miles traveled.
i.	Prevent conversion of agricultural, forest, and open space lands
to uses that result in higher greenhouse gas emissions
4.	Prioritize projects that have the ability to be implemented
regionally, leverage additional public and/or private funding,
achieve co-benefits, are replicable and consider geographic and
socioeconomic issues.
5.	Provides opportunities for jurisdictions with either small or
large populations.
6.	Provides funding for both:
a.	The development and implementation of innovative projects that
create new systems or technologies to be deployed at a local or
regional level
b.	Implementation of existing, proven GHG emission reducing or
sequestering projects, especially those projects and programs
already adopted by local agencies.  These projects should receive
funding on a competitive basis.

We respectfully request that you consider these principles and
allow us an opportunity to work with you to refine these concepts
so that local governments can continue helping the state meet the
goals of AB 32.

Sincerely,

Jennifer Whiting, Legislative Representative, League of Cities

Kate Meis,Associate Director, Local Government Commission

Cara Martinson, Associate Legislative Representative, California
State Association of Counties

Carol Misseldine, Director, Green Cities California