Report 2020-114 Recommendations

To improve its ability to isolate each of its incentive programs' additional GHG reductions, by February 2022 CARB should establish a process to formally identify its incentive programs' overlap with other programs that share the same objectives. As part of that process, CARB should document how it will account for the overlap to allow the most accurate program measurement possible.

As part of its work to measure both incentive and regulatory programs' additional GHG reductions, by February 2022 CARB should begin collecting and analyzing the data it needs to assess the extent to which the requirements in its regulatory programs are being exceeded by manufacturers. To the extent applicable, that analysis should focus on the components of the requirements that overlap with CARB's incentive programs, such as the extent to which manufacturers are complying with regulations for heavy-duty vehicles via low- and zero-emission vehicles.

To improve its ability to identify the effectiveness of each of its incentive programs in reducing GHG emissions, by August 2021 CARB should develop a process to define, collect, and evaluate data on the behavioral changes that result from each of its incentive programs. Having done so, by February 2022 CARB should collect and analyze relevant survey information for all consumer-focused incentive programs, as well as information about the behavioral effects of programs that other entities offer, such as the federal tax credit.

To better assist the State in achieving its GHG goals, CARB should use the information we describe to refine its GHG emissions estimates for its incentive programs in its annual reports to the Legislature, the funding plans approved by its board, and any longer-term planning documents or reports.

To promote transparency and inform stakeholders, beginning in December 2021, CARB should prepare an annual report for its board and the Legislature on its progress in isolating the GHG emissions reductions attributable to each of its regulatory and incentive programs. As a part of this report, CARB should identify any measurement challenges that persist and highlight any administrative barriers that prevent it from obtaining the information it needs to perform better analysis.

To strengthen the accuracy and integrity of its emissions reduction reporting, CARB should immediately begin retaining all supporting documentation it uses to perform calculations of GHG reductions for its cap-and-trade-funded incentive programs for a period of at least five years. In conjunction with this change, CARB should also document the justification for any instances in which the underlying data it uses to compile its annual reports vary from the information it publishes in those reports.

To better ensure the accuracy of its program data, by August 2021 CARB should develop a formal schedule and procedures for reviewing the supporting documentation maintained by its program administrators. These procedures, which CARB should begin using with the 2022 annual report, should specify a minimum number of records to review in relation to the program's size, should specify how staff will collect and maintain evidence to support conclusions, and should be standardized across all of CARB's incentive programs.

To ensure that the State is positioned to assess the status of the Sustainable Communities program, by April 2021 CARB should report to the Legislature whether it will have a usable source for measuring regional GHG emissions in time for the 2022 report. If CARB believes it may not, it should identify any administrative or bureaucratic barriers it faces in accessing data it needs for the estimates and request relevant action by the Legislature to make those data available.

To ensure that it communicates clearly to the Legislature about the extent to which programs benefit low-income households as the Legislature intended, by March 2022 CARB should begin reporting its spending in low-income communities at the household level wherever possible in its annual report to the Legislature.

To better define incentive programs' impact beyond GHG emissions reductions, by August 2021 CARB should review its incentive programs to ensure that it has clearly designated which programs focus primarily on socioeconomic benefits. As a result of this process, by February 2022 it should ensure that it includes the benefits expected for each program in its funding plan or other public documents, such as its annual report and individual grant agreements.

To better demonstrate the socioeconomic benefits that its incentive programs achieve, by February 2022 CARB should do the following:

- Identify clear and measurable metrics it will use to assess each of the socioeconomic benefits it intends its programs to achieve.
- Develop a process to collect data, or use existing data, to measure and report on each metric.
- In its funding plans and annual reports, CARB should report to the Legislature and its board on the metrics.

To provide transparency to the Legislature and other stakeholders, beginning in 2022 and using the metrics and data described above, CARB should make funding and design recommendations in its funding plans and annual reports based on which programs are effective in producing socioeconomic benefits and at what cost.

To ensure that the State has reliable information about the extent to which cap-and-trade-funded programs create and support jobs, by August 2021 CARB should begin collecting data on the jobs produced by each of its incentive programs. Where needed, CARB should pursue amendments to its agreements with its program administrators to make reporting this information mandatory. CARB should include an analysis of these jobs data in its annual reports to the Legislature beginning in 2022.

To ensure that its incentive programs promote effective and equitable job training, by August 2021 CARB should develop a process to assess which programs should include a job training element. For those programs it identifies, by February 2022 CARB should direct its staff or its external program administrators to collect and report on the quality of job trainings and outcomes experienced by participants, including who received training, the credentials participants received as a result, any actual or expected wages they received as a result of participating in the training or for developing the relevant expertise, and the number of participants from disadvantaged communities or low-income communities and households.

To ensure that it can account for the total costs of its transportation programs, beginning with fiscal year 2021-22 CARB should develop and implement processes to track the administrative costs it incurs to operate each of its transportation programs. After doing so, it should begin including those costs as part of the cost-effectiveness measurements in its annual reports to the Legislature.