Submitted Comment Name Jenelle Sams Affiliation Imerys SA Subject SB 253 Reporting Comments Message From our perspective, there may be a misalignment between CARB’s template and the GHG Protocol’s requirements. The breakdown of each scope is not always required, as some emission types may not be material. To increase alignment, reporting entities should be given the option of whether to separate emissions by source whether an emission type is material (or not) to the business. Moreover, it may not be feasible at this moment to break down the historical data to the level of emission type requested in CARB’s template. Moving forward, parent companies may not break down the data by emission type, as this would require significant effort on areas that are not material to the business. File Upload (i.e., Attachments): N/A N/A
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