California Air Resources Board

RSM US LLP (RSM, we) values the opportunity to offer our comments on the California Air Resources Board’s (CARB) California Corporate Greenhouse Gas Reporting Program: Scope 1 and Scope 2 Emissions Draft Reporting Template (the Public Memo). RSM is the leading provider of assurance, tax and consulting services focused on the middle market, with nearly 18,000 professionals in 77 U.S. cities, six locations in Canada, one in El Salvador and four in India.

Overall Comments on the Proposal

Overall, we support the intent and function of the Scope 1 and Scope 2 Greenhouse Gas (GHG) Emissions Draft Reporting Template (the Draft Template) for certain U.S. entities that do business in the State of California. We believe the Draft Template will assist with entities’ compliance with reporting requirements to make publicly available biennial climate-related financial risk reports and to disclose measures adopted by the entity to reduce and adapt to climate-related financial risk. We believe the Draft Template will allow for transparency for consumers and investors.

Our responses are based on our understanding of the regulations as discussed at the previous meetings. We understand that any changes in the regulation may have an effect on the Draft Template.