Starting earlier this year, the California Natural Resources Agency (CNRA) started holding workshops to receive public input for both different regions throughout the state and on different topics that relate to the 30×30 (read as 30 by 30) conservation movement and planning. One such workshop held was on the topic of advancing equity as it relates to 30×30.
Below is a comment letter submitted by the 30×30 California Coalition’s Equity Subgroup. This document was co-created by CalWild’s André Sanchez and several key partners in response to the CNRA’s June 15th Using Nature-Based Solutions to Advance Equity topical workshop and the “Using Nature-Based Solutions to Advance Equity Advisory Panel Summary Document.” In the document, the Equity Subgroup puts forth several suggestions to CNRA on how to advance equity under 30×30 including potential measurable outcomes, how to better improve the public process for engagement on 30×30, and expanding and protecting cultural heritage sites.
For more information on California’s 30×30 process, please visit the California Natural Resource Agency’s Expanding Nature Based Solutions page.
30×30 California Coalition Equity Committee Comment Letter
June 25, 2021
Dear Deputy Secretary Norris,
On behalf of the 30×30 California Coalition’s Equity Committee, we are writing to provide our response to California Natural Resources Agency’s (CNRA’s) June 15th Using Nature-Based Solutions to Advance Equity topical workshop and the “Using Nature-Based Solutions to Advance Equity Advisory Panel Summary Document.” Our organizations appreciate CNRA’s invitation to submit detailed written comments to follow up on the issues we raised verbally during the workshop.
Our group represents a diverse group of organizations that are working to support the State’s efforts to conserve at least 30% of California by 2030. Our organizations work on a broad spectrum of climate and social justice issues, and it is our firm belief that the state of California has both a unique opportunity and a profound moral responsibility to lead boldly on 30×30. We support the Parks Now Principles and Recommendations for Equitable Implementation of 30×30 Initiative and have drafted the following points as a guide for approaching the 30×30 process with an equity lens.
We deeply appreciate the work that went into organizing this panel and its composition of participants, as well as its focus on and acknowledgement of structural racism. We support the findings of the panel and the report, and offer the following specific suggestions for making sure the recommendations in the report translate into on-the-ground actions that benefit California’s community and nature.
To ensure that all communities have the right to enjoy the social, health, environmental, and economic benefits of nature for future generations, we agree with the panel and the report that 30×30 must be inclusive, collaborative, and transparent. We believe that clearly-established and openly-communicated metrics for success must be communicated at every stage of the process.
CNRA did an excellent job of outlining admirable equity values and frameworks in “Using Nature-Based Solutions to Advance Equity Advisory Panel Summary Document”. However, the document would be improved by being more specific as to how these goals will be achieved. As an example, the section in the document that focuses on implementing equity and antiracism could include suggestions on how this will be accomplished and how communities of color will be engaged in the process. Identifying and implementing actionable next steps will be essential to meeting these goals by 2030.
Additionally, we request that CNRA provide more clarity on how it will engage people of color and Tribes in the 30×30 process. A process that prioritizes community input is a necessary first step to establishing measurable outcomes. The process will be more effective and efficient if stakeholders are operating from a shared understanding about terms, processes, and outcomes.
To reassure community members that the comment period and workshop engagement process will lead to substantive action items with meaningful outcomes, we recommend:
- Partnering with community-based organizations, particularly those which support underserved communities to develop clear definitions for terms like “conserved,” “cultural resource,” “equity,” and “access”;
- Making available a shared and regularly-updated progress tracking dashboard; and
- Developing and publishing interim goals and milestones prior to 2030.
We believe that measurable outcomes cannot be established until CNRA first provides the opportunity for community input so that we are all operating from a shared understanding about terms, processes, and outcomes.
Improving Public Process
We strongly encourage CNRA to work with relevant stakeholders to establish details, standards, processes, and protocols to advance procedural equity as a public-facing agency and within the 30×30 process. CNRA’s commitment to equity in the public process must also be a meaningful recognition of the current and historical burdens on communities to engage public agencies and the larger conservation movement. Overall, many engaged stakeholders have described CNRA’s public process as rushed and presenting barriers to meaningful engagement.
We encourage CNRA to continue to improve public workshops, especially since remote public participation presents special barriers for accessibility and engagement. We recommend that where possible, the state provide opportunities for participation after work hours or on weekends, since midday sessions limit engagement from members of the public with daytime jobs. We understand this places an additional burden on state staff and hope that a healthy compromise that provides adequate input opportunities can be found. Moreover, we encourage CNRA to continue to include the breadth and quality of translation services. While Spanish translation services were provided, there are other groups that would be encouraged to participate with additional translation services. Also, CNRA should know that some Spanish-speaking members of the public felt that the translators were not accurately conveying their comments on multiple occasions and we encourage CNRA to ensure high-quality translation services.
Nonprofit and community groups are committed to assisting CNRA with outreach and achieving broader and more inclusive engagement from community members. We encourage CNRA to consider providing financial and technical assistance to increase capacity among community-based organizations and groups to complement state staff and their outreach efforts.
Expanding Equitable Access
In order to address and expand access to nature for all Californians, we agree with the panel and report that it must first be acknowledged that there is an inequitable distribution of nature in America. Due to historical patterns of racial exclusions, discrimination in human settlement, and the violent removal of Indigenous peoples from their ancestral homelands, communities of color are three to four times more likely to live in nature-deprived areas. Expansion of direct access to green spaces is an opportunity to address the historical policies and programs that have perpetuated these inequities.
New parks must be established for rural and urban communities to meet the access needs of each region. As suggested in the panel and the report, we agree that in order to inform these efforts, CNRA must conduct community-level needs assessments and collaborate with CBOs to lead public engagement similar to other state-led programs such as the Transformative Climate Communities (TCC). Different communities use green spaces differently and as a result, proper consultation and engagement can support coordination of various land uses and support habitat connectivity to maximize ecosystem services, biodiversity protection, and climate resilience in proximity to disadvantaged communities. CNRA must also address access gaps with current green spaces by incorporating analyses of how transportation networks either support or hinder access. The State should also consider addressing cost barriers by eliminating or reducing park fees for disadvantaged communities. A potential option of reducing cost barriers may include a dedicated time frame during park operating hours that offers a reduced rate open space entry and use fees, which could be especially marketed to disadvantaged communities to encourage increased access.
In order to protect and maintain access to these green spaces, CNRA should take proactive measures to ensure lands are not “loved to death” and supported with educational programs and “leave no trace” signage and by ensuring adequate natural resources like water are accounted for in green space maintenance. Funding must also be included to build adequate infrastructure that meets the needs of communities, to properly maintain green spaces, and to ensure the safety and inclusion of all visitors.
Expanding and Protecting Cultural Heritage Sites
It is critical that 30×30 include specific strategies for expanding cultural heritage sites which preserve the history of those excluded from recognition starting with Indigenous tribes and people of color in California. The definition of “cultural resource” should be defined with the input of Tribes and other communities of color and should encompass community-identified cultural heritage sites and efforts to rename places to reflect the values of the surrounding communities. People of color must see themselves represented in conservation efforts and cultural heritage sites. The preservation of their cultural history will serve to engage and inspire a new generation in heritage conservation, both natural and cultural.
The Equity Advisory Panel report, Using Nature-Based Solutions to Advance Equity (Equity Report) has a good start on this objective regarding Indigenous tribes but must expand the goals to include Black, Latinx and Asian historic sites by working with local community groups and equity cultural preservation groups such as Latinos in Heritage Conservation, Asian and Pacific Islanders in Heritage Conservation, and California Preservation Foundation. This work is time-sensitive and, in order to advance work on historic sites related to the civil rights movement, this issue must be addressed urgently. Due to development threats and the lack of funding/resources in local communities to preserve such sites, time is of the essence. As an example, many of the historic Farmworker Movement sites in the Central Valley, Black Student Movement, or Chicano Moratorium sites have been altered so significantly that designations are very challenging.
As acknowledged in the panel discussion, planning and implementation of 30×30 needs to incorporate the understanding that ecosystem health and natural processes are directly tied into human existence and wellbeing. Since the time of colonization and westward expansion, this relationship has been disrupted and the gap has increasingly broadened as significant resource extraction has occurred, large landscape conversions have taken place, and the uprooting of Indigenous peoples and their stewardship of the land has been forcefully terminated. While each region has differing needs, the 30×30 process can improve overall ecosystem services and should take into account and re-establish natural processes that once allowed humans, wildlife, and ecosystems to thrive and maintain a deep connection to one another. These deep historical and essential connections of coexistence in a healthy ecosystem should be highlighted through the language that is used in formal documents by enforcing the idea that humans are directly connected to the ecosystem and not a separate entity or part of the landscape.
Economic and Job opportunities
As noted in the Advisory Panel Summary Document, economic or career driven incentives should be planned for and implemented as part of the 30×30 process. That is to say, incentivizing restoration and conservation management actions, green economy jobs, and job training for environmentally focused positions at the local and statewide level should be included in the planning process of meeting the 30×30 goal. Local efforts such as those of local conservation corps including but not limited to the San Jose Conservation Corps, Fresno Conservation Corps, or Los Angeles Conservation Corps should not only be supported but further expanded.
Similarly, increased support for non-governmental organizations and programs that promote positive and healthy transformation and management of the natural and built environment, especially around under-resourced or low-resource communities. One example is the work that Groundwork USA is performing in their Groundwork Richmond (California) local trust by which they have implemented partnership programs such as the Urban Forestry or Richmond Greenway projects. Similar governmental-based efforts should include the continued expansion of the state workforce that better reflects the diversity of residents in the state, particularly in natural resource management agencies whose actions most impact communities of Black, Indigenous, and People of Color. Through such efforts, the reclamation, restoration and conservation of vacant lands and historic habitats, especially in the most urban and modified parts of the state, can be used as economic drivers through jobs creation and recreation spending on restored and conserved spaces.
The goals identified in the “Using Nature-Based Solutions to Advance Equity Advisory Panel Summary Document” are laudable, a great step forward for the state, and ambitious:
- Establish long-term stable and dedicated funding sources for natural climate solutions
- Invest in organizational diversity and capacity as well as a commitment to building pathways to wealth for under-resourced communities.
We support these goals.
We appreciate the Governor’s proposal for hundreds of millions of dollars to fund increasing outdoor access however, we note that state and other public funding programs for natural resources do not have a reliable track record when it comes to operationalizing these and other types of goals. Historically, at every level of government, natural and cultural resource funding has been inadequate to protect the public trust and cultural assets. Furthermore, inadequately funding integral agencies and programs has exacerbated many environmental injustices and access disparities. The Newsom administration and the Legislature should immediately capitalize on the current state budget surplus to more adequately fund natural and cultural resource protection and increased, more equitable access to nature.
The majority of the identified funding goals outlined in the “Using Nature-Based Solutions to Advance Equity Advisory Panel Summary Document” are admirable, especially those goals intended to develop community capacity and provide essential investments. Yet it remains unclear how these goals will be funded, especially considering that the Department of Finance has taken a hard line on allowing the types of expenditures that are necessary to engage the community. For example, meeting incentives for access programs are no longer offered and operational and community engagement costs, which are essential for effective programs, are no longer covered. At the macro level, there needs to be a data driven approach to 30×30 in order to ensure that investments are made where disparities exist and adequate funding is allotted to support meaningful community engagement.
As acknowledged in the Equity Report, due to historical disinvestment, achieving equity will require investment targets and resources be dedicated to support meaningful community engagement in processes that underserved communities identify as beneficial. As an example, LAC’s Safe Clean Water Program requires an investment of 110% of revenues collected in underserved communities (DACs). However, the lessons learned from this program are that you have to be very specific about what and who determines that a project/program constitutes a benefit to that community. Community-led design is essential to making these types of decisions. Lastly and perhaps most importantly, is the “sustainability” issue. At this juncture, there is a budget surplus but that is unfortunately likely to be temporary. CNRA must disclose to the public the steps it plans to take to ensure that these recommendations become part of permanent baseline funding and are not dependent on one-time or bond funding. This will ensure that 30×30 has meaningful outcomes rather than joining the long list of broken promises suffered by our respective communities.
California’s working lands will play an essential role in supporting healthy ecosystems and thriving communities. While these lands are important carbon sinks, historical injustices in land protection and habitat conversion have often led to reduced ecological function and increased pollution for communities in close proximity. California can face this critical juncture in reconciling historic land uses and land management practices by co-valuing carbon sequestration and biodiversity with the community health of historically marginalized communities.
By incorporating equity into working lands program goals and procedures, CNRA and other state agencies can begin the process of meaningfully rebalancing community and biodiversity priorities. CRNA’s Climate Smart strategy must incorporate equity into program design, funding awards, and amongst desired beneficiaries.
To meet these goals, CNRA must ensure that its climate smart strategy fully incorporates equity and public health analyses to ensure program implementation beneficiaries include small farmers of color and the needs of disadvantaged communities including but not limited to: farms for farmworkers, groundwater recharge, heat mitigation, access to green space, biodiversity, reduction of agricultural burning, elimination of pesticides, and air quality. We recommend that where possible, priority be given to small farmers and multi-benefit projects with strong evidence of co-valuing the needs of disadvantaged communities and the environment. In order to identify investments to improve carbon sequestration and community health, CNRA must consider existing health metrics such as CalEnviroScreen and other available data to identify investments.
We recommend that working land investments must be prioritized near disadvantaged communities to improve environmental quality and climate resilience. CNRA should consider factors like habitat connectivity and proximity to disadvantaged communities as considerations in grant applications prior to awarding funds. In regions like the San Joaquin Valley, the Sustainable Groundwater Management Act also provides an opportunity for land repurposing to better meet the ecological and social needs of the region. Funding projects that emphasize regenerative agriculture and agroecology as an alternative to corporate farming also provides an exciting opportunity for CNRA to shape the future of land management practices. Conversely, CNRA and other agencies must ensure extractive industries do not exacerbate existing pollution concerns and do not adversely affect tribal rights and self-determination, biodiversity, or climate resilience.
Thank you for your consideration of these comments. We look forward to collaborating with the State and other stakeholders to advance 30×30 and the Climate Smart Natural and Working Lands strategy.
Engagement Program Manager
Urban Wildlands Campaigner
Center for Biological Diversity
Brenda Ileana Gallegos
Conservation Program Associate
Hispanic Access Foundation
San Joaquin Valley Organizer
California Wilderness Coalition
California Program Director
Conservation Lands Foundation