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Invest Cap and Trade Funds to Benefit Underserved Communities and Communities of Color

The City Project joined with allies in Northern and Southern California to ensure that public funds provide tangible, meaningful benefits for underserved communities and communities of color under California’s cap and trade greenhouse gas reduction funds. We submitted public comments to the Air Resources Board (ARB) of the California Environmental Protection Agency as follows.

A.  Southern California environmental justice and community development organizations submitted the following recommendations:

  1. Disadvantaged communities must receive substantial, focused funding to transform historic burdens into future benefits, with priority given to those communities with the greatest need.
  2. Program criteria, metrics, and evaluation should emphasize accountability and a performance management approach to ensure that investments create true benefits and meet requirements under the law.
  3. Programs and projects incorporating authentic community engagement should receive funding priority.
  4. Programs and projects must do no harm in disadvantaged communities.
  5. SB 535 investments must benefit disadvantaged communities in a significant and measureable manner.
  6. SB 535 investments should also support transformative policy planning and regulatory activities.

B. Northern California environmental justice and social equity organizations submitted the following recommendations:

  1. ARB’s Guidance must avoid using location as the sole touchstone for assessing whether a project provides a benefit to disadvantaged communities.
  2. The Guidance must ensure that projects avoid displacement and other burdens.
  3. Investments that provide multiple and cumulative benefits to disadvantaged communities should be prioritized.
  4. Projects that authentically include disadvantaged communities in the planning, implementation, evaluation and/or selection process, should receive funding priority.
  5. SB 535’s two set aside categories should be counted separately so that a minimum of 35% of GGRF funds is spent to benefit disadvantaged communities and populations, and should set target benefit levels for all GGRF programs

C. The City Project submitted separate public comments to CalEPA and ARB on the need to explicitly address equity and disparities based on race, color, and national origin, and for compliance in the planning and implementation process with federal and state civil rights and environmental justice laws and principles.

CalEPA has selected CalEnviroScreen (CES) as the tool to identify underserved communities for the distribution of cap and trade funds. The City Project supports guidance and an improved CES tool that properly considers race, color, and national origin, as well as green access, in order to identify underserved communities and to distribute funds.

We recommend the following steps.

  1. Reinstate race, color, and national origin data as an indicator in the CES score.
  2. Include green access as an indicator in addition to pollution burdens and population characteristics in CES.
  3. Guidance documents on the distribution of greenhouse gas reduction funds under SB 535 should incorporate race, color, and national origin, as well as green access.
  4. Guidance documents, CES, and other public documents should refer to “underserved communities,” rather than “disadvantaged communities.”

“[W]hen society’s rewards – including the right to breathe clean air[,] live far away from toxic wastes[, and live near parks and green space] – are systematically distributed by race, it is better to know than to remain dangerously ignorant,” as USC Prof. Manuel Pastor has written in a related context.

Good social research needs data on race and ethnicity. There is no sound social science or technical reason to exclude such data. Federal law requires collecting, analyzing, and publishing data based on race, color, or national origin where, as here, there is evidence of racial and ethnic disparities regarding pollution burdens, vulnerability, and green access. No law prohibits it. Claims that Prop 209 or other state laws prohibit or constrain agencies from collecting, analyzing, and publishing such data to include in the CES or to distribute greenhouse gas reduction funds are false, prejudicial, and discriminatory.

Thus, for example, people of color disproportionately live in the areas of the state that are the most burdened for pollution, are the most vulnerable to health risks, and are park poor.

CES POC 20140915

Click on the map for a larger image

As the preceding map illustrates dramatically:

  1. In the areas with the 10% highest CES score (most burdened) for pollution burden and vulnerability, fully 89% of the people are of color; only 11% are non-Hispanic white people. Statewide, the population average is 58% people of color.
  2. In the areas with the 10% lowest CES score (least burdened) for pollution burden and vulnerability, only 31% of the people are of color; fully 69% are non-Hispanic white people.
  3. 64% of people of color in the state live in areas with the 50% highest CES scores (most burdened) for pollution burden and vulnerability; only 31% of non-Hispanic white people live in those areas.
  4. Only 36% of people of color in the state live in areas with the 50% lowest CES scores for pollution burden and vulnerability; fully 69% of non-Hispanic white people live in those areas.

To learn more please see the attached public comments to CalEPA and ARB from The City Project, Southern California allies, and Northern California allies.