Comment Log Display

On behalf of the nearly 50 organizations listed below, we recommend
that the Administration adopt and act according to the following
principles to ensure that SB 535 is implemented in a manner that
meaningfully benefits disadvantaged communities:

1. Make the process inclusive, transparent and accountable. ARB
should ensure transparency, accountability and the robust public
participation of disadvantaged communities in the process of
developing and implementing an investment plan: 
- Public participation of disadvantaged communities – a core
principle of Environmental Justice – must be integrated into the
implementation of SB 535, at both the state and regional/local
level. 
- Proposed investments of SB 535 funds should be transparently
itemized as falling under the 25 percent or 10 percent category.
- All agencies (including local and regional agencies) responsible
for carrying out projects funded with SB 535 funds should be held
accountable to ensure that promised benefits are delivered,
measured and reported. 

2. Invest in High Priority Needs. Disadvantaged communities have
needs that are distinct from those of the general public; for
instance, they are subject to well-documented disparities in health
outcomes. Disadvantaged communities benefit when their distinctive
needs are met. The benefits of each investment made with SB 535
funds should specifically address high priority needs of
disadvantaged communities. ARB should ensure that projects deliver
significant benefits by meeting priority needs well. Eventually,
ARB should implement metrics to quantify the co-benefits to
disadvantaged communities (e.g., improvements in housing, transit,
job and public health outcomes) of GHG-reducing projects. Setting
performance measures will make the process more transparent while
also facilitating DOF reporting on the outcomes of these
investments.

3. Benefits Must Outweigh Burdens. There are many projects that,
while considered beneficial to some, generate harmful impacts that
are disproportionately concentrated in disadvantaged communities. 
The benefits of SB 535 investments on disadvantaged communities
must significantly outweigh the burdens that the projects may
impose on those communities. 

These principles are submitted on behalf of nearly 50 organizations
from across California:

Asian and Pacific Islanders California Action Network (APIsCAN)
Allen Temple Baptist Church
Asian Pacific Environmental Network (APEN)
Asian Immigrant Women Advocates
Asian Neighborhood Design
Asian Pacific Policy & Planning Council (A3PCON)
Bay Area Healthy 880 Communities
Bay Localize
Breakthrough Communities
CA ReLeaf
California Housing Partnership Corporation (CHPC)
California Rural Legal Assistance Foundation
California Rural Legal Assistance, Inc.  
California WALKS
Catholic Charities, Diocese of Stockton
Center for Sustainable Neighborhoods
Chicana/Latina Foundation
Coalition for Clean Air
East Bay Housing Organizations (EBHO)
El Concilio of San Mateo County
EndOil / Communities for Clean Ports
Fresno Metro Ministries
Environmental Justice Task Force of A3PCON
Genesis
Great Leap
Green for All
Greenlining Institute
Housing California
Kennedy Commission
Leadership Counsel for Justice and Accountability
Marin Grassroots
Nail Salon Women Greening Their Jobs and the Environment  
New Voices Are Rising Project (of the Rose Foundation for
Communities and the Environment)
North Bay Organizing Project
People's Community Organization for Reform and Empowerment
(People's CORE)
Public Advocates Inc.
Public Interest Law Project / California Affordable Housing Law
Project
Regional Asthma Management & Prevention (RAMP)
Sacramento Housing Alliance (SHA)
Safe Routes to School National Partnership
Sierra Club California
The City Project
TransForm
Unitarian
Universalist Legislative Ministry California (UULMCA)
Urban Habitat
WALKSacramento
Western Center on Law and Poverty

See attached for a PDF version of the principles.

Sincerely,
Parisa Fatehi-Weeks
Public Advocates, Inc.