Tell the Youngkin DEQ that the Biden EPA guiding documents for the Climate Pollution Reduction Grant (EPA CPRG) center Environmental Justice, not narrow and ineffective greenwashing GHG targets, as the path to truly addressing the global climate crisis. Make sure agencies and localities, including your city, put forward projects in keeping with EPA guidance that affirms the validity of the true Modern Money Theory (MMT) Green New Deal.
The core of the Green New Deal was a Job Guarantee which was the missing piece that could have made the Biden COVID response even more effective and catalyzed economic and political transformation to truly Build Back Better. The American Climate Corps (ACC) has this intent and could be boosted as the missing piece in the Inflation Reduction Act to which the EPA CPRG points. Bring representation of frontline communities to on-line listening sessions and use your 3 minutes to affirm the MMT environmental social justice Job Guarantee potential of the ACC.
While people have to set priorities and the funds are small compared to ARPA, it seems like if people had time to stop by a hearing they might be able to steer the direction closer to the intent of the guiding documents which could divert the funds from creating ruts that will later have to be overcome.
This is the list of the public input community meetings for the Climate Pollution Reduction Grants Program:
Tuesday, January 9, 6-7:30pm: Virtual Community Meeting.
Summary of a letter sent to DEQ:
The guiding document Climate Pollution Reduction Grants Program: Implementation Grants General Competition indicates on page 9 “Update building and zoning codes …” as a GHG reduction measure example. A benefiting locality in which the legislative body meets twice a month, as in the case of Harrisonburg’s City Council, could, for example, repeal an exclusionary zoning ordinance in order to encourage broad community adoption of capital expenditure projects for “new green space and/or community beautification,” in a worker-centric way that includes individuals with barriers to employment. This draws on examples of expected direct and indirect benefits to Low-Income and Disadvantaged Communities listed on pages 35 and 36 of the cited guiding document and would be both squarely within the scope of the program and permissible under the Dillon Rule. It would also be achievable well within the grant deadlines. There is also time for some EJ General Assembly measures like banning high PAH parking lot sealants (a CAP and HAP source), which is likely to be submitted this session, could be on its way to the Governor’s desk before the grant’s March 1 deadline.
While a large portion of the scoring is dedicated to capital infrastructure directly related to GHG reduction subject to a cost-effectiveness test, the LIDC section carries nearly 15% of the available points and contributes to the attainment of the global, potentially disqualifying, goal of also being consistent with program objectives including “Result in benefits (and do not result in negative impacts) to low-income and disadvantaged communities, such as CAP and HAP reductions, equitable economic growth, and improved quality of life outcomes, where applicable” on page 8 of the implementation guiding document. My reading of the guidance is that, to get better than a B, how we reduce GHG emissions counts.
The guidance repeatedly stresses meaningful community involvement where “[m]eaningful involvement means people have an opportunity to participate in decisions about activities that may affect their environment and/or health; the public’s contribution can influence the regulatory agency’s decision; community concerns will be considered in the decision-making process; and decision makers will seek out and facilitate the involvement of those potentially affected”, as stated on page 36 of the guiding document for 10 possible LIDC points.
Across the country, communities are experiencing more deadly wildfires and storm surges, more extreme drought and water scarcity, and dangerous levels of flooding, among other impacts. The Fourth National Climate Assessment found that intense extreme weather and climate-related events, as well as changes in average climate conditions, are expected to continue to damage infrastructure, ecosystems, and social systems that provide essential benefits to communities. If left unchecked, future climate change is expected to further disrupt many areas of life and exacerbate existing challenges to prosperity posed by aging and deteriorating infrastructure, stressed ecosystems, and long-standing inequalities. However, with this challenge comes an opportunity to invest in a cleaner economy that will spur innovation and economic growth while building more equitable, resilient communities.
The goals of the EPA in the planning grant are:
The goals for communities in the, second phase competitive, implementation grant are:
Accordingly, the CPRG general competition for implementation grants is designed to enable states, municipalities, tribes, and territories to achieve the following goals:
The criterion for meaningful community input (not met in the Harrisonburg listening session):
Meaningful involvement means people have an opportunity to participate in decisions about activities that may affect their environment and/or health; the public's contribution can influence the regulatory agency's decision; community concerns will be considered in the decision-making process; and decision makers will seek out and facilitate The involvement of those potentially affected
The plans must be consistent with:
EPA expects to receive implementation grant applications covering a broad range of potential GHG reduction measures. Applicants have flexibility to tailor the new or expanded GHG reduction measures included in their applications to the specific plans and needs of their jurisdictions. Applications that successfully address the specific evaluation criteria in Section V will also be consistent with the following program objectives:
...The grant is subject to numerous executive orders, including targeting specific proportions of benefits to low-income and disadvantaged communities and :
EPA is committed to accelerating environmental justice (EJ) in communities overburdened by pollution through its IRA investments, including through the CPRG program. This program is responsive to the Administration’s call for agencies to advance EJ in Executive Order 14096:
Revitalizing Our Nation's Commitment to Environmental Justice for All.
The cited
After its street renaming, Harrisonburg brought forward its 7-11 project, to create a community green space in an empty lot. Incarceration rates plummeted and the city bloomed for a time. This brought into focus the barriers posed by city structures originally devised to impose segregation, including its Department of Community Development whose signature interface with residents is a Tall Grass and Weed ordinance. More than 90 percent of nearly 200 voters surveyed favored repealing state enabling legislation that allows such ordinances. The 7-11 project fit squarely within :
Examples of expected direct and indirect benefits to these communities from GHG reduction measures could include: - Improved public health resulting from reductions in co-pollutants (e.g., CAPs, such as NOx, ozone, PM2.5, and HAPs), such as reductions in new asthma cases and reductions in hospital admissions and emergency department visits; - Creation of high-quality jobs and new workforce training opportunities in low- income and disadvantaged communities with an emphasis on expanding opportunities for individuals that face barriers to employment; - Improved access to services and amenities; - New green space and/or community beautification; - Improved housing quality, comfort, and safety; and/or, - Other benefits identified during consultation with residents of low-income and disadvantaged communities.
article on the comprehensive intent of the ACC, which appropriately reaches across and ties together multiple federal programs.