HomeMy WebLinkAboutLetter from Sac Valley Air Pollution Control Council 06-17-15 E,N cotj�vry
SACRAMENTO VALLEY ADMIN
BASINWIDE AIR POLLUTION CONTROL COUNCIL JUN 9 2015
P.O. Box 2994,Paradise, CA 95967'
Vice-Chair Chair
Butte Colusa_—r-eather—Ri—verGlenn – Placer Sacrunento Shasta 'rehama Y010-solano
June 17, 2015 NOMMSUMMM
JUN 19 7015
The Honor-able Edmund G. Brown Jr. OQVILLE;CAUFORNIA Matthew Rodriquez
Governor,State of California Secretary for Environmental Protection
State Capitol CaIEPA Building
Sacramento, CA 95814 P.O. Box 2815 Sacramento,CA 95812-2815
Michael Cohen Mary Nichols, Chairman
Director, Department of Finance CA Air Resources Board
State Capitol, Room 1145 P.O. Box 2815
Sacramento, CA 95814 Sacramento,CA 95812-2815
RE: Interim Guidance to Agencies Administering Greenhouse Gas Reduction Fund Monies,
""In vestments to Benefit Disadvantaged Communities"
Dear Governor Brown:
on behalf of the nine counties within the Sacramento Valley Air Basin with a population of
approximately three million, I appreciate the opportunity to express my opinion regarding the
disposition of Cap and Trade,funds.
The Sacramento Valley Basinwide Air Pollution Control Council (BC Q is disappointed with the proposed
distribution of the proceeds to "Disadvantaged Communities" as directed in SB 535 (DeLeon). As per S8
535, 25% of the over $850 million annual Greenhouse Gas Reduction Fund (GGRF) is to be directed to
disadvantaged communities as determined by a program called CalEnviroscreen 2.0, developed by the
Office of Environmental Health Hazard Assessment (OEHHA), 5B 535 requires CalEP'A to identify
disadvantaged communities based on, Environmental Effects, Exposure, Sensitive Populations, and
Socioeconomic Indicators. The main goal of CalEnviroscreen 2.0 was to accurately locate
areas/neighborhoods using pollution "scores' based on census tract data. After reviewing the scatter
graphs shown on the OEHHA guidance document titled "APPROACHES TO IDENTIFYING
DISADVANTAGED COMMUNITIES," it appears as though most of the geographical areas contained
within the boundaries of the BCC, as well as most of rural California, will be ignored with regards to
funding. The inclusion of fuels into the Cap and Trade Program began January 2015. Residents within
the BCC and rural California are contributing to the Cap and Trade coffers but will have little chance of
receiving meaningful benefit from this additional tax burden. The bottom line is that Sacramento Valley
and the rest of rural California will be subsidizing projects for the urban portions of the state.
A majority of the GGRF monies have already been earmarked primarily for urban projects. High-speed
rail, inter-city rail grants, low-emission vehicle rebates, and transit-oriented development grants will
receive approximately $600 million. Another $80 million will go to low-income weatherization
programs. The remaining portion of the fund appears to be headed toward projects under the general
headings:
• General Services-energy upgrades to state buildings ($20 million)
• Food and Agriculture - Reducing Ag wastes($20 million)
• Water Resources- Water Action Plan-water use efficiency($20 million)
• Forestry and Fire Protection- Fire prevention and urban forestry$(50 million)
• Fish and Wildlife—wetlands restoration ($30 million)
• CalRecycle--waste diversion ($30 million)
Residents within the Sacramento Valley and rural California will receive little, if any, direct benefit from
the funded categories listed in the above paragraph. The population-weighted criteria used in
ColEnviroscreen 2.0 makes the BCC and rural California non-competitive for funding. It is ironic that the
majority of the areas within the BCC are not considered disadvantaged communities when one
considers that the median household income is well below the state average, the college educated
population is also well below the state average, and the number of persons living below the poverty
level is significantly higher than the state average. Yet because of the population weighted criteria in
CalEnviroscreen 2.0, BCC areas and rural California are not considered to be "disadvantaged," and thus
not eligible to receive GGRF funding.
According to the Legislative Analyst's Office (LAO) letter of August 4, 2014, to Assembly member Henry
Perea, the introduction of fuels into the Cap and Trade Program will likely result in gasoline price
increases of between $.13 and $.20 per gallon by 2020, but that price increase could exceed $.50 per
gallon. The LAO letter relies on several studies as part of this analysis, including a California Air
Resources Board study that estimated gasoline prices rising between 4% and 8% by 2020 and diesel fuel
prices rising 2% to 4% by 2020. In the BCC counties, approximately 1.3 billion gallons of gas were
pumped by consumers in 2012, and a $.13 per gallon increase would result in almost $169 million in
annual additional costs for those consumers. if the increases were to be $.20 to $.50 per gallon, as
suggested as possible by the LAO, the result would be an additional annual cost of$260 to $650 million.
These amounts do not include increases to prices for diesel fuel, which would be substantial due to the
rural agrarian economy and their location along the 1-5 corridor, or propane, which is the primary
heating fuel in several unincorporated areas that lack natural gas service. In addition,fuel prices in rural
areas are typically higher than in urban areas, adding an additional burden to BCC consumers.
Although the authors of CalFnviroscreen 2.0 worked diligently attempting to capture the intent of
accurately identifying "Disadvantaged Communities," it appears they fell short of being equitable to the
BCC and the rest of rural California. Perhaps a more equitable approach could be an automatic
allocation back to the counties collected from the fuels Cap and Trade Program. This would be similar to
the transportation funds collected from vehicle registrations, or state Air District subvention, or even
the Carl Moyer Program funding where all districts receive a base amount and larger districts receive
more as per their population. Subject to the spending guidelines or approved policies and procedures,
these funds could be used locally to create jobs as well as provide economic and sustainability benefits
and measurably reduce greenhouse gases and black carbon.
These returned monies could go toward various projects:
• Residential and commercial solar power projects
+ Municipal waste efficiency projects
• Electric vehicle infrastructure
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• Locally produced alternative fuels such as biodiesel
• Energy efficiency and black carbon reduction projects including wood stove change out
programs
• Diesel-to-electric and electric-to-solar agricultural irrigation projects
Such projects in rural areas, particularly those in state and federal non-attainment for one or more
pollutants, would result in not only climate pollutant reductions but also co-benefits in the reduction of
criteria pollutants. This would assist the economically-challenged rural nonattainment areas in reaching
attainment as expeditiously as possible.
We ask that you consider the financial impacts on the Sacramento Valley Basin and rural California as a
result of the inclusion of fuels into the Cap and Trade Program and the long term benefits that can be
achieved through sending funding back to the BCC counties and rural California at a base rate rather
than funding entirely by the results of a screening tool that may not capture a true picture of what a
"Disadvantaged Community" really is. If you have any further questions, feel free to contact me at (530)
458-0508.
Thank you for your time and consideration.The Sacramento Valley Basinwide Control Council Members:
Denise Carter, Colusa County APCD, Steve Lambert, Butte County AQMD, Gary Baland, Feather River
AQMD, Leigh McDaniel, Glenn County APCD, Stan Nader, Placer County APCD, Don Nottoli, Sacramento
Metro AQMD, David Kehoe, Shasta County AQMD, Steve Chamblin, Tehama County APCD and Duane
Chamberlain, Yolo-Solano AQMD.
. cerely,
D ise Carte , BCC hair,Supe Colusa County, dcarter@countyofcolusa.org
cc's: Ted Gaines, State Senator, District 1
Lois Wolk,State Senator, District 3
Jim Nielsen, State Senator, District 4
Cathleen Gagliani, State Senator, District 5
Richard Pan, State Senator, District 6
Brian Dahle, State Assembly Member, District 1
James Gallagher, State Assembly Member, District 3
Bill Dodd, State Assembly Member, District 4
Frank Bigelow, State Assembly Member, District 5
Beth Gaines, State Assembly Member, District 6
Kevin McCarty,State Assembly Member, District 7
Ken Cooley, State Assembly Member, District 8
Jim Cooper, State Assembly Member, District 9
Jim Frazier, State Assembly Member, District 11
Board of Supervisors: Butte, Colusa, Glenn, Placer, Sacramento, Shasta, Solano, Sutter,Tehama, Yolo, Yuba
City Mayors: Biggs, Chico,Gridley, Oroville,Town of Paradise, Colusa, Williams, Orland, Willows,Auburn,
Colfax, Lincoln, Loomis, Rocklin, Roseville, Citrus Freights, Elk Grove, Folsom, Galt, Rancho Cordova,
Anderson, Shasta Lake, Redding, Davis, Dixon, Rio Vista, West Sacramento, Winters, Woodland,Vacaville,
Live Oak, Marysville, Wheatland, Yuba City, Corning and Red Bluff
Mary Pitto, Rural County Representatives of California
Richard Corey, Executive Officer, California Air Resources Board
PAG-E