Submitted Comment Name Matt Pigozzo Affiliation N/A Subject Comments Message I have the following comments and suggestions related to the August 21, 2025 workshop on implementing SB 261 and SB 253: 1. The proposed June 30, 2026 deadline for SB 253 reporting would appear to be tight, especially given that final minimum requirements and regulations have not been issued and the need for third party assurance. I would suggest moving to December 31 for the first several years to allow companies adequate time to improve the timeliness of their reporting. 2. Please clarify the reporting scope of the parent company report under SB 253. TCFD would typically require operational boundaries which would potentially include emissions related to non-U.S. and non-California subsidiaries. 3. Please clarify if existing TCFD reporting can be used to satisfy SB 261 and SB 253 reporting requirements and if there are any format requirements. For example, a company may have TCFD disclosures in the form of a table that references different parts of their sustainability report and/or their responses to the CDP questionnaire. Is it sufficient to reference a report in this format (assuming the information satisfies the required disclosures under SB 261 and/or SB 253). 4. I would suggest allowing for different assurance frameworks, especially in the initial reporting periods. Changing to a different framework may require using a different assurance provider which could take considerable time to switch. There may also be resource constraints in the marketplace. Thank you, Matt Pigozzo File Upload (i.e., Attachments): N/A N/A
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