Comment Log Display
Below is the comment you selected to display.
Comment 43 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Josh
Last Name: Lee
Email Address: jlee@sanbag.ca.gov
Affiliation:
Subject: SANBAG Comment to Cap-and-Trade Auction Proceeds
Comment:
Dear Chair Nichols and Board Members, The San Bernardino Associated Governments (SANBAG) has reviewed both the draft Interim Guidance to Agencies Administering Greenhouse Gas Reduction Fund Monies and the draft Approaches to Identifying Disadvantaged Communities. SANBAG understands that there is no single methodology that would perfectly define, identify, and address all of the disadvantaged communities in California. However, representing a county with significant air quality, environmental, education, and socio-economic challenges, SANBAG strongly suggests that CalEPA and CARB use the currently available CalEnviroScreen Tool (v.2.0) to define disadvantaged communities (Method 1). SB 535 is very clear about how the definition of disadvantaged communities should occur: (Section 39711 Health and Safety Code) These communities shall be identified based on geographic, socioeconomic, public health, and environmental hazard criteria, and may include, but are not limited to, either of the following: (a) Areas disproportionately affected by environmental pollution and other hazards that can lead to negative public health effects, exposure, or environmental degradation. (b) Areas with concentrations of people that are of low income, high unemployment, low levels of home ownership, high rent burden, sensitive populations, or low levels of educational attainment. SB 535, Section 1(g) further states that resources are to be directed “to the state’s most impacted and disadvantaged communities to ensure activities taken pursuant to that authority will provide economic and health benefits to these communities as originally planned.” It is quite clear that disadvantaged communities should be defined as communities with the greatest socioeconomic challenges who are also impacted by “environmental pollution and other hazards”. The final definition must include both elements. Therefore, out of the five proposed methods, Method 1 most closely mirrors the basic intent of the SB 535. Recently, the California Transportation Commission (CTC) encountered the identical set of issues when defining disadvantaged communities for the Active Transportation Program. The CTC allowed three concrete definitions (CalEnviroscreen 1.1, median household income, and percentage of students eligible for the Free or Reduced Price Meals Program). The Commission also allowed a fourth definition whereby the applicants could propose an alternative disadvantaged community determination method. By allowing a broader definition of the disadvantaged communities, many of the applicants used that opportunity to define disadvantaged communities in very creative ways. In the end, certain communities were able to qualify as disadvantaged under the CTC guidelines, when in reality one would have to question whether this was appropriate. This led to 86 percent of the applicants being classified as disadvantaged. This was clearly not the intent of the disadvantaged community criteria. SANBAG would strongly suggest that the definition be kept consistent with the intent of SB 535 and be based on the extensive work conducted in CalEPA’s development of CalEnviroScreen. Therefore, rather than having multiple methodologies for defining disadvantaged communities, SANBAG would recommend the use of Method 1. As mentioned in the draft GGRF interim guidelines, the purpose is “preliminary guidance on approaches that agencies can use to maximize the benefits of investments to disadvantaged communities.” Currently, the GGRF Expenditure Plan looks at investment plans that will achieve the GHG reduction goals and targets while looking at investments that facilitate feasible and cost-effective GHG reductions. Since AB 32 is an air quality/GHG program, the air quality, GHG, and environmental burdens of a community should be the primary emphasis when investing on various projects. In other words, disadvantaged communities with these environmental burdens should be the priority of the program. The only methods that fully analyze the environmental burdens are CalEnviroScreen Method 1 and Method 5. However, in the interest of simplicity, SANBAG would again recommend that Method 1 be used as the single definition. SANBAG understands that improving the health of disadvantaged communities is important and that socioeconomic factors play a significant role in determining the health of a community. SANBAG works very closely with the San Bernardino County Department of Health in addressing these socioeconomic issues through partnerships and collaboration. However, it is important to point out that the GGRF program is not a social service program, but a program to reduce GHG. According to the American Lung Association 2012 and 2013 State of the Air report, our county is ranked the smoggiest in the nation. In San Bernardino County, more than 150,000 adults and children have asthma, 60,000 residents have chronic bronchitis, 23,000 have emphysema, and 420,000 suffer from heart disease. The state needs to recognize the true disadvantaged communities that have the most significant environmental impacts and make sure that these communities are not overlooked in funding opportunities. In that regard, Method 1 best captures the essence of the impacts. SANBAG requests that rather than utilizing a separate methodology, the CalEnviroScreen Tool be used for its intended purpose. Thank you for considering comments from SANBAG
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2014-09-15 00:05:49
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.