1 2
Sacramento Group
Yolano Group
3 October 25, 2021
Rajinder Sahota
Deputy Executive Officer for Climate Change and Research California Air Resources Board
1001 I Street
Sacramento, CA 95814
RE: Request for GHG Inventories for California Local Governments
Dear Rajinder Sahota,
On behalf of 42 cities and towns, 10 counties, 3 councils of government, and 62 stakeholder groups representing coalitions of local governments, nonprofits, community-based organizations, and private sector firms working across California, the Local Government Commission respectfully submits this request for the California Air Resources Board (CARB) to conduct GHG inventories for all cities, counties, and special districts in California.
The IPCC 6th Assessment is a stark reminder that we need to act urgently. Even the leading jurisdictions in California, that have adopted climate action plans and supportive elected officials, struggle to put their plans into action. Part of the impediment is that a disproportionate amount of time and effort is directed toward planning and evaluation, rather than direct implementation and action. Your agency has an opportunity to relieve some local data burdens, which would increase local government capacity for implementation, while simultaneously improving data consistency and utility.
We request that, as a first step, CARB conduct GHG inventories for all cities and counties in California.
This statewide initiative would yield the following benefits:
• Comprehensive coverage across the state. Acknowledging there are a number of GHG inventories currently in process or recently published, the CARB CAP-MAP notes that nearly 40% of jurisdictions do not have any GHG inventories on record. Many of the GHG inventories listed are out of date and not likely to represent current practices. A GHG inventory is a precursor to developing climate action plans (CAPs) and ensuring investments in climate action strategies and programs target local pollution sources. This is particularly critical for communities that are disproportionately impacted by poor air quality and with limited resources and capacity to mitigate GHG emissions. Filling the gap for these jurisdictions will enable them to get closer to taking action.
• Data and methodology consistency. Currently, cities and counties have different levels of access to quality data and use different methodologies to conduct their GHG inventories. These inconsistencies prevent meaningful cross-jurisdictional comparisons and aggregation for effective regional planning. A centralized effort led by CARB, with the flexibility to go beyond CARB’s base methodology, would address this issue and enable local and regional agencies throughout the state to plan, coordinate, and accelerate climate mitigation efforts in a more effective, data- informed manner.
• Visibility into patterns and progress. The State, regional agencies, and local governments would gain visibility into the different emissions profiles across the state to identify key policy and programmatic opportunities for rapid and equitable climate mitigation measures. Tracking local
4 inventories over time would also provide insights into the effectiveness of targeted State investments and local programs to measurably reduce emissions.
To establish an effective statewide GHG inventory program that achieves the above noted benefits, we would like to share the following program design recommendations for CARB’s consideration:
• Engage local governments and stakeholders. We received numerous comments from local governments across the state that reflect the importance of a technical advisory committee made up of practitioners working on climate action plans to ensure the work would meet the needs of local government and regional agencies in addition to the State. We suggest forming an advisory committee comprised of local officials actively working to conduct GHG inventories that are connected to climate policy development and implementation. The advisory committee would also benefit from the participation of additional industry and subject matter experts. • Providing flexibility to go beyond the CARB process. The GHG inventories developed by CARB should serve as a starting point for local governments to build upon and finalize based on additional local datasets and information. Providing flexibility in how local jurisdictions can utilize State-developed GHG inventories will be critical to enabling cities, counties, and special districts to address their specific needs and tailor their GHG inventory to support climate action. Such flexibility can also help to spur innovations in the practice of climate action planning and help to inform continuous updates to the statewide program that lift up best practices. • Continually update CARB’s CAP-Map. The CAP-Map has served as a valuable tool for local governments and stakeholders to understand the status of climate action planning throughout the state; however, the information included in the current map is out of date. We recommend maintaining the CAP-Map so that it can continue to serve as a valuable resource. • Leverage existing tools. There are several existing platforms and tools that could be leveraged to support a statewide, State-led approach to conducting local GHG inventories, including tools developed by academics (UC Berkeley’s Cool Climate Network and UCLA’s Energy Atlas), nonprofits (ICLEI’s ClearPath), the private sector (Google’s Environmental Insights Explorer), regional public agencies (Vital Signs in the Bay Area), and other existing platforms. Additionally, the ability of other public and proprietary tools to access the statewide inventory data would also provide important access points to support innovation and efficiency.
Local governments, including cities, counties, and special districts, want to be key partners in meeting the State’s ambitious GHG emissions goals. As a recent reflection on The State of Local Climate Planning suggests, having a state agency take on inventories is an important step in evolving our collective practice. It is a critical part of improving the efficiency and effectiveness of climate action by focusing each level of government’s efforts on their unique role, in concert with the other levels of government.
Leading local governments, and some regional agencies on behalf of local governments, have been conducting individual GHG inventories for over a decade, more recently spending nearly $1 million every year collectively to create or update GHG inventories. In addition to yielding the benefits listed above, centralizing inventories would allow these public dollars to be redirected toward action.
Thank you for your time in considering our request and comments. The Local Government Commission staff who are coordinating this group letter request a follow up meeting to discuss the content of this request and would be pleased to bring together a small cohort of industry leaders to discuss this important issue with appropriate CARB staff. Julia Kim, Climate Change and Energy Program Director
5 ([email protected]) and Michael McCormick, Special Advisor ([email protected]) can help set up the follow up conversation and are available to answer any questions.
Respectfully,
Roger Dickinson
Policy Director
Local Government Commission
John Stephens
Mayor
City of Costa Mesa
Catherine Blakespear
Mayor
City of Encinitas
Justin Massey
Mayor
City of Hermosa Beach
Ellen Kamei
Mayor
City of Mountain View
Scott Sedgley
Mayor
City of Napa
Steven Zuckerman
Mayor
City of Rolling Hills Estates
Chin Ho Liao
Mayor
City of San Gabriel
Pauline Cutter
Mayor
City of San Leandro
Erica Stewart
Vice Mayor
City of San Luis Obispo
Kimberly Warmsley
Councilwoman
City of Stockton
Lisa Schmidt
City Councilmember
Town of Los Altos Hills
Anna Klovstad
Mayor
Town of Truckee
Diane Burgis
Chair, Board of Supervisors
County of Contra Costa
Dennis Rodoni
President, Board of Supervisors
County of Marin
Das Williams
Supervisor
County of Santa Barbara
Lynda Hopkins
Chair, Board of Supervisors
County of Sonoma
Jim Provenza
Chair, Board of Supervisors
County of Yolo
Danielle Mieler
Sustainability and Resilience Manager
City of Alameda
Elizabeth Carrade
Sustainability Coordinator
City of Albany
Billi Romain
Manager, Office of Energy and Sustainable
Development
City of Berkeley
Lisa K. Goldman
City Manager
City of Burlingame
6 Cory Downs
Conservation Specialist
City of Chula Vista
William R. Smith
City Manager
City of Colton
Ignacio Rincon
Planner
City of Commerce
Ashley Feeney
Assistant City Manager
City of Davis
Jason Behrmann
City Manager
City of Elk Grove
Rachel DiFranco
Sustainability Manager
City of Fremont
Jimmy Forbis
City Administrator
City of Gilroy
John Doughty
Public Works Director
City of Half Moon Bay
Erik Pearson
Environmental Services Manager
City of Hayward
Tricia Pontau
Associate Planner
City of Livermore
Larry Rich
Sustainability Coordinator
City of Long Beach
Andrea Pappajohn
Environmental Programs Manager
City of Millbrae
Daniel Hamilton
Sustainability Manager
City of Oakland
Peter Carr
City Manager
City of Orland
John King
Assistant Planning Director
City of Paramount
Steve Carmona
City Manager
City of Pico Rivera
Alyssa Dykman
Sustainability Program Manager
City of Piedmont
Radha Mehta
Management Analyst
City of San Bruno
Kerri Romanow
Director, ESD
City of San Jose
Rosemary Menard
Interim City Manager
City of Santa Cruz
Wayne M. Morrell
Director of Planning
City of Santa Fe Springs
Michelle Ramirez
Community Development Director
City of Torrance
Steven Palmisano
Assistant Director of Public Works
City of Watsonville
Robyn Eason
Long Range Planning & Sustainability Manager
City of West Hollywood
7 Aaron Laurel
City Manager
City of West Sacramento
Daniel C. Holler
Town Manager
Town of Mammoth Lakes
Albert Lopez
Planning Director
County of Alameda
Leighann Moffitt
Planning Director
County of Sacramento
Carolyn Bloede
Director, Office of Sustainability
County of San Mateo
Ashley Watkins
Sustainability Division Chief
County of Santa Barbara
Jasneet Sharma
Director, Office of Sustainability
County of Santa Clara
Kristin C. Doud
Principal Planner
County of Stanislaus
Alejandra Tellez
Sustainability Officer
County of Ventura
Nancy Pfeffer
Executive Director
Gateway Cities Council of Governments
Jenny Berg
Board Chair
Local Government Sustainable Energy Coalition
Marisa Creter
Executive Director
San Gabriel Valley Council of Governments
Suzanne Smith
Executive Director
Sonoma County Regional Climate Protection
Authority
Kim Fuentes
Deputy Executive Director
South Bay Cities Council of Governments
Timothy Burroughs
Executive Director
StopWaste
Linda Reis
Member
350.org
Constance M. Beutel
EdD
Air Watch Bay Area
Nick Peterson
Founding Member
Albany Climate Action Coalition
William Barrett
Senior Director, Clean Air Advocacy
American Lung Association
Patrick Guild
Chief Operating Officer
Breathe California Sacramento Region
Laura Tugwell
Admin Assistant/Sustainability Data Specialist
Carmel Building & Design
Sascha D. Landry
Administrator
Central Coast Climate Collaborative
Rosana Francescato
Communications Director
Clean Coalition
Jonathan Parfrey
Executive Director
Climate Resolve
8 Janelle London
Co-Executive Director
Coltura
Kristin Harms
Chair
Community Coalition of University Heights
Kirsten Liske
VP, Community Programs
Ecology Action
Ralph Propper
President
Environmental Council of Sacramento
Jeff Caton
Director, Sustainable Communities
Environmental Science Associates
Ari Isaak
Founder and CEO
Evari GIS Consulting, Inc.
Michael McCormick
President
Farallon Strategies LLC
Terry Taylor
CEO
Global Genesis, Inc.
Angie Fyfe
Executive Director
ICLEI Local Governments for Sustainability USA
Candice Kollar
Consultant, Sustainability Communications
Kollar EcoCreative®
Clay Sandidge
President and CEO
Muni-Fed Energy, Inc.
Marian Sedio
Secretary
North County Climate Change Alliance
Ty Keith
Electricity & Energy Consultant
Pacific Trade
Renata Langis
Project Planner
PlaceWorks
Mindy Craig
Executive Director
RAPID Climate Action Network
Gopal Shanker
President
Récolte Energy
Nancy Faulstich
Executive Director
Regeneración - Pajaro Valley Climate Action
Rita Norton
Consultant
Rita Norton Associates
Edith Thacher
Chapter Lead
Sacramento Chapter of Citizens' Climate Lobby
Colleen FitzSimons
Executive Director
San Diego Green Building Council
Anne Sheridan
CAP Committee Co-chair
SanDiego350
Alan Pryor
Chair
Sierra Club, Yolano Group
Barbara Leary
Chairperson
Sierra Club, Sacramento Group
Kateri Harrison
CEO
SWALE Inc.
9 Ellie Cohen
CEO
The Climate Center
Laurel Rothschild
Vice President
The Energy Coalition
Deborah Pendrey
Owner
The Solar Contractor
Casey Loosbrock
Co-Chair
UC Davis Environmental Law Society
Kevin Wolf
CEO
Wind Harvest
Martin L. Carver
Managing Partner
ZeroCity LLC
Amanda Bancroft
Board Member
350 Silicon Valley
Jan Dietrick
Policy Team Leader
350 Ventura County Climate Hub
David Diaz
Executive Director
Active San Gabriel Valley
Thomas Graly
Co-Leader
Berkeley Electrification Working Group/Climate
Action Coalition
Micheal Saint
Treasurer
Campaign for Sustainable Transportation
Tyler Maldonado
Organizer
Climate Action Resource Center
Cameron Gray
Director of Climate Mitigation Programs
Community Environmental Council
Leslie Alden
Executive Director and Co-Founder
DRAWDOWN Bay Area
Beth Love
Founder and President
Eat for the Earth
Corey Brophy
Director of Programs
EcoGreen Solutions
Edward Myers
Principal
Edward C. Myers, Consultant
Charles Cormany
Executive Director
Efficiency First California
Celeste Mirassou
Owner/Financial Planner
Financial Planning Focus
Eric Taylor
CEO
GreenNet IoT Global Alliance
Dave Shukla
Operations
Long Beach Alliance for Clean Energy
Ashley Gauer
Program Manager, Special Projects
Monterey Bay Economic Partnership
Christina Benz
Treasurer/Steering Committee Member
Napa Climate NOW!
Pauline Seales
Organizer
Santa Cruz Climate Action Network
10 Stuart Wood
Executive Director
Sustainable Claremont
Ramon Edrick Hilario
President
The American Engineers
CC:
Richard Corey, Executive Officer, California Air Resources Board Annalisa Schilla, Chief, Community Action Branch, California Air Resources Board Samuel Assefa, Director, California Office of Planning and Research (OPR) Erik de Kok, Deputy Director, Planning & Community Development, OPR Nuin-Tara Key, Deputy Director, Climate Resilience, OPR Lauren Sanchez, Senior Climate Advisor, Office of California Governor Newsom