Comment Log Display

April 24, 2013  

Hon. Mary Nichols
Chair, California Air Resources Board
1001 I Street
Sacramento, CA 95814

Hon. Ana J. Matosantos
Director, California Department of Finance 
915 L Street
Sacramento, CA 95815

RE: Draft Investment Plan for Cap-and-Trade Auction Proceeds

Dear Chairman Nichols and Director Matosantos:

We represent economic justice, public health, housing,
environmental justice, transportation, faith, and environmental
groups in the Bay Area. For the past 3 years, we have been working
collaboratively to ensure that the Bay Area adopts a Sustainable
Communities Strategy that meets environmental, economic and equity
goals – the “three Es” – that are vital our region’s and the
state’s future. We submit these comments in response to the Draft
Investment Plan (“draft plan”) released by the California Air
Resources Board (ARB) and the Department of Finance (DOF) on
Tuesday, April 16, 2013.

We commend ARB, DOF and all other the State agencies involved in
this effort for their hard work and commitment to eliciting broad
public input and participation in the development of the draft
plan. In particular, we support the draft plan’s commitment to
ensuring that disadvantaged communities benefit from cap-and-trade
auction proceeds and the focus on achieving sustainable communities
by investing in public transportation and affordable homes near
transit-oriented development.  

To strengthen the plan, however, we urge ARB and DOF to expressly
include transit operations as an investment priority in order to
sustain and expand transit service levels and ridership. While the
draft investment plan includes funding for transit capital needs,
it does not explicitly prioritize the operating funds that are
needed to sustain and improve service on the street. 

Investments in the State Transit Assistance program and/or new
transit operating grants are desperately needed so that the
operators in our region (e.g., Alameda-Contra Costs Transit
District (AC Transit), San Francisco Municipal Transportation
Agency (Muni), Santa Clara Valley Transportation Authority (VTA),
San Mateo County Transit District (SamTrans), etc.) can provide the
local transit service our communities depend upon for access to
jobs, schools, and healthcare.

It is well-established that spending more on transit operations
improves access to opportunity for disadvantaged residents, seniors
and youth, while creating jobs for drivers and mechanics and
cutting down on pollution. On top of all that, studies demonstrate
that investments in local transit service can have a ten-fold
economic multiplier effect on the local economy. 

Just this month, the Metropolitan Transportation Commission (MTC)
and Association of Bay Area Governments (ABAG) released further
evidence that investing in transit operations is critical to
achieving the GHG reductions called for in SB 375 while also
performing well on social equity and public health indicators. The
Plan Bay Area draft Environmental Impact Report (EIR) recently
released by MTC/ABAG includes study of the “Equity, Environment and
Jobs” (EEJ) alternative, an alternative that includes nearly $8B
additional dollars to invest in transit service. In combination
with an equitable distribution of affordable housing and increased
protections against displacement of low-income residents, the
emphasis on investing in transit operations led the EEJ alternative
to be designated as the “environmentally superior alternative”
while also performing best on a series of public health metrics
(lowest levels of the polluting emissions that lead to asthma and
other respiratory diseases; highest levels of walking and biking;
lower increases in residents’ injuries and fatalities from
collisions) and social equity metrics (lowest combined housing and
transportation costs for low-income households; lowest displacement
pressure on overburdened renters). In other words, the EEJ
alternative demonstrates that investments in transit operations and
affordable homes are critical to realizing the promise of SB 375
and achieving the GHG reductions called for in AB 32. 

We stand ready to work with you to strengthen the investment plan
by prioritizing transit operations as one of the plan’s investment
areas so that we can demonstrate the benefits of AB 1532 and SB 535
in our communities. Thank you for the opportunity to provide this
feedback.


Sincerely,

 
Wafaa Aborashed
Bay Area Healthy 880 Communities  

Carl Anthony and Paloma Pavel
Breakthrough Communities

Wendy Alfsen
California WALKS

Tim Frank
Center for Sustainable Neighborhoods

Genesis (Member, Gamaliel of CA)

Gladwyn d’Souza
Green Youth Alliance

Joshua S. Hugg
Housing Leadership Council of San Mateo

Myesha Williams
New Voices are Rising Project

Guillermo Mayer
Public Advocates Inc.

Jill Ratner
Rose Foundation for Communities and the Environment

Bob Allen
Urban Habitat

Reverend Earl Koteen
Environmental Justice Minister

Alberta Maged 

Jane Day, Member
Woodside Road United Methodist Church
 
 
cc: 	Martha Guzman-Aceves, Office of the Governor
Cliff Rechtschaffen, Office of the Governor
Karen Finn, Department of Finance
Mike McCoy, Strategic Growth Council
Richard Corey, Air Resources Board 
Ashley Conrad-Saydah, Office of the Secretary, CalEPA
Brian Kelly, Business, Transportation and Housing Agency
Claudia Cappio, California Housing Finance Agency
Camille Wagner, Office of the Governor
Brian Putler, Office of the Governor
Cynthia Marvin, Air Resources Board, CalEPA
Miriam Ingenito, Office of the Secretary, CalEPA
Matt Rodriguez, CalEPA
Arsenio Mataka, Cal/EPA
Members of the Air Resources Board
Steve Heminger, Metropolitan Transportation Commission