California Air Resources Board

Dear California Air Resources Board Team,
Thank you for the opportunity to review and provide feedback on the draft Scope 1 and 2 greenhouse gas (GHG) emissions reporting template, as part of the implementation of SB 253 and SB 261.
As an ESG Reporting Strategy Leader, I appreciate CARB’s efforts to streamline the reporting process and for providing tools for our disclosures. The inclusion of structured sections and ability to leverage existing reporting is helpful in guiding reporting entities through the process.
On behalf of Dow, I would like to offer the following feedback and suggestions for consideration:
1. Streamlining of Template Questions
Many companies, including those smaller and just beginning their reporting processes, would benefit from streamlining of template questions. In particular:
• Breakdowns by emissions source for scope 1 and 2 should be optional as this requires more resources for companies to measure and track.
• Biogenic emissions should also be optional as they are not easily assessed and mechanisms to report are not widely available.
• As most companies will implement a single type of organizational boundary, there are multiple questions that are duplicative (e.g., facilities excluded from organizational boundary versus excluded from inventory).
2. Emission Factor Drop Downs & Year
Would encourage CARB to consider free text options or a “Other – Please Specify” for emission factor reporting. Many companies have multiple sources of emission factors. A drop-down list may not be inclusive. Allowing free text or alternative options would allow more accurate reporting. Similarly, Dow would suggest CARB revise the template from a date form to a free text form. As there are multiple emission factors that may be used and the publication dates for each varies, we would need to be able to report each date of publication.
3. Optional Fields and Future Alignment
The inclusion of optional fields such as base year emissions and emissions reductions is forward-looking. To support comparability and alignment with other regulatory frameworks (e.g., California Mandatory Reporting Regulation), CARB might consider providing guidance on how these fields will evolve in future reporting cycles.
4. Integration with SB 261 Risk Disclosures
Given the overlap in covered entities between SB 253 and SB 261, it may be beneficial to explore opportunities for harmonizing data collection and reporting timelines to reduce duplication and administrative burden.
5. Feedback Timeline and Engagement
The October 27 deadline for stakeholder feedback is appreciated. Continued engagement through workshops and iterative updates to the template will be critical to ensure the final framework is both robust and practical. We would encourage CARB to allow additional time for feedback collection, such as 60-day public commentary periods.
Thank you again for your leadership in advancing climate transparency and accountability. We look forward to continued collaboration as these important programs are finalized.
Sincerely,
Ashley DuPuis
ESG Reporting Strategy Leader