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Comment 55 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Dennis
Last Name: Osmer
Email Address: dennis@energyservices.org
Affiliation: Central Coast Energy Services

Subject: Disadvantaged Communities
Comment:
Central Coast Energy Services respectfully submits the following
comments on the identification of disadvantaged communities. We are
a not for profit organization providing direct weatherization
services to low income communities in Monterey, San Benito, Santa
Cruz and San Mateo counties with federal Low Income Home Energy
Assistance Program (LIHEAP) funding from the State Department of
Community Services and Development.  We also provide Software
Services for program management in 22 other agencies delivering
energy assistance services in California.  
1.	5 Methods of Identifying Disadvantaged Communities Presented at
Public Workshop – Program Appropriate Application
In regard to the five methods introduced at recent public
workshops, we hope the board will consider applying specific
methods that are appropriate to each of the programs to be funded.
Adopting a single method and applying it to each of the programs
regardless of the targeted goals of each program would introduce an
unnecessary difficulty in accomplishing those goals in every
program from the start. The programs are diverse in their
anticipated impact and the method of identifying disadvantaged
communities most in need should be tailored to each program
individually.
2.	Method of Identifying Disadvantaged Communities to Benefit from
Weatherization/Renewables - Low Income Weatherization Program

In regard to a method applied to the Weatherization/Renewables
Program and specifically the Low Income Weatherization Program
(LIWP), we advocate for any method making all households within the
CalEnviroScreen top scoring 25% of census tracts eligible. The LIWP
would offer yet another weatherization program competing with the
CPUC mandated Energy Savings Assistance Program and the Low Income
Home Energy Assistance/Department of Energy Program (LIHEAP/DOE)
administered by the State Department of Community Services and
Development. This will certainly increase customer confusion and
lack of acceptance of both programs implementers currently
experience. The potential for leveraging existing programs is
highly overrated. A broader eligibility criteria will provide for
more efficient service delivery and greater value to people in
disadvantaged communities using investment funds. This approach
would also make the goal of committing 100% of the
Weatherization/Renewables funds to directly benefit disadvantaged
communities a reality.




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Date and Time Comment Was Submitted: 2014-09-15 12:00:04



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