Comment Log Display

Dear Dr. Alexeeff and Ms. Livingston,

I writing to you on behalf of Tree Davis, a small non-profit
organization based in Davis, California.  We are very excited about
the upcoming opportunity for urban forestry made possible by
cap-and-trade auctions.  We look forward to seeing this significant
investment come to fruition in California communities.  We also
look forward to better air and water quality, energy savings,
reduced pollution, and ultimately happier, healthier Californians! 
Thank you for all of your work to make this happen.

While Davis is not a disadvantaged community, we strongly support
the effort to focus 55% to 70% of cap and trade funds for urban
forestry into communities defined as disadvantaged through methods
such as CalEnviroScreen. The CalEnviroScreen 2.0 tool is a very
thorough method of analyzing which communities are being confronted
with both environmental and poverty challenges (which unfortunately
tend to go hand in hand).  

While the CalEnviroScreen tool and other methods of determining
what communities are disadvantaged are very impressive, we do not
believe that it is possible for any of them to be completely valid.
 For this reason, we believe there should be some flexibility
concerning what percentage of cap-and-trade funds go to communities
defined as disadvantaged.

Recently, we heard that 100% of the funds would be directed to
communities defined as disadvantaged and that disadvantaged may be
defined as the top 15% or 20% of CalEnviroScreen scores.  To be
clear, we do believe that all of the funds should go to
disadvantaged communities, but we think there is no perfect method
of determining which communities are disadvantaged, so there should
be some flexibility when it comes to CalEnviroScreen scores.  This
is why we support the lower threshold of 55% to 70% of the funds
being directed to communities that have the highest 20% of
CalEnviroScreen scores (or whichever method ends up being the one
which defines disadvantaged).

For example, we want to help Yolo County Housing plant trees on ten
of their sites around Yolo County.  These sites are not all in one
place, but scattered within different census tracts.  The
CalEnviroScreen scores for these sites range from 40%-70%, but we
believe this is misleading.  The average household income for
residents at these sites is around $20,000 and there are a
significant number of elderly and disabled people.  While the
communities that surround them are not in the top 20% of scores,
they are still moderate to very high.  It was great that the 2.0
CalEnviroScreen tool focused on census tracts to analyze smaller
units of analysis, but there are also large disparities even within
census tracts.  

So, we propose a strategy where 55%-70% of monies are directed to
the top 15 or 20% of CalEnviroScreen scores, with the rest being
more flexible to give urban foresters an opportunity to help
residents who may have been missed such as those who live in Yolo
County Housing.  Thank you!

Sincerely,

Keith McAleer
Executive Director
Tree Davis
keith@treedavis.org
(530)758-7337