California Air Resources Board

Q1. If your company reports under another jurisdiction’s program, what elements of that framework should CARB take into account?
A1. We respectfully request that the level of data disclosure required under SB-253 be aligned with existing reporting standards. For instance, certain details regarding emission sources by category (e.g., stationary combustion, mobile combustion, process emissions), which are included in the current SB-253 template, are not mandated by other major frameworks such as ESRS or IFRS S2. Therefore, we suggest that CARB consider removing these items, which are currently designated as optional fields, from the reporting requirements entirely, and limit mandatory reporting to only the most essential information to ensure alignment with global standards.

Q2. Are there topics from the initial regulation adopted at the February 2026 Board hearing that need to be revisited, including reporting deadlines post 2026, applicability definitions, and/or exemptions?
A2. For companies exempt from 2026 reporting obligations that will commence their first disclosure in 2027 (covering Scope 1 and 2), we propose that their Scope 3 reporting be deferred by one year to 2028. This mirrors the current schedule for 2026-obligated companies, who report Scope 1 and 2 in 2026 but defer Scope 3 to 2027.
This adjustment recognizes that organizations performing emissions measurement and verification for the first time may not be ready to calculate Scope 1, 2, and 3 emissions simultaneously in their initial reporting year. Allowing a one-year deferral for Scope 3 for these new entrants would provide the necessary time to establish robust data collection systems.
Furthermore, for companies already providing consolidated reporting under other standards (e.g., ESRS, IFRS S2) who wish to use such reports to satisfy SB-253 requirements, we request clear guidance on organizational boundaries. Specifically, clarification is needed on whether emissions must be reported separately for California entities or if consolidated global emissions data are sufficient.

Q3. Are there other approaches to organizational boundary setting that CARB should consider?
A3. From our company's perspective, no additional methodological approaches are required.

Q4. How should entities explain their choice of organizational boundary?
A4. We believe it is sufficient for companies to provide a brief explanation of the rationale behind their chosen reporting boundaries (e.g., a specific approach was selected to align with other consolidated reporting standards).

Q5. What additional information for Scope 1 and 2 reporting should CARB consider when developing final reporting templates?
A5. Given the evolving landscape of global reporting standards such as ESRS and IFRS S2, we propose removing items classified as "optional fields" from existing templates. Mandatory reporting items should be limited to essential data points only.

Q6.What accounting methods does your organization currently use for Scope 1, 2, and 3 GHG emissions?
A6. Although our company has not yet calculated greenhouse gas emissions, we intend to adopt a hybrid approach that combines the methodologies best suited for each specific scope and emission category.

Q7.Should CARB consider allowing other accounting methods? If so, which ones and why?
A7. Our company has no further requests, provided that organizations are permitted to select the most appropriate methodology from the proposed options for each specific scope and emission category.

Q8. What criteria should emission factors meet to be used in this program?
A8. To accommodate companies already reporting under standards like ESRS and IFRS S2, we believe SB-253 should adopt criteria that are compatible with global requirements. Additionally, to alleviate the reporting burden on enterprises, we suggest allowing companies the flexibility to choose among multiple approved emission factor databases or standards.

Q9.How should reporters document and explain their use of a particular emission factor, including proprietary models?
A9. We believe it is sufficient for companies to disclose the rationale for selecting specific emission factors. In cases where proprietary models are used, disclosure should include confirmation via third-party verification that the resulting emission factors do not deviate significantly from global standards.

Q10. How should reporters document and explain when changing EFs from a prior year?
A10. Companies that have changed their emission factors must disclose, when reporting, the emission factor data used before and after the change, the reason for the change, and the recalculated emission figures for the previous reporting year based on the new emission factors.

Q11. Should reporting entities be able to report as de minimis certain categories due to lack of relevance/materiality and/or feasibility?
A11. We agree that non-disclosure of certain categories should be permitted based on practical considerations such as relevance and measurability (de minimis thresholds). For example:
- Companies operating entirely via remote work may reasonably be exempt from reporting Category 7 (Employee Commuting).
- Manufacturers of intermediate goods may, in certain cases, be exempt from Categories 10, 11, and 12 if estimation is deemed unreasonably difficult, consistent with GHG Protocol guidelines.

Q12. What specific thresholds, definitions, or decision frameworks should CARB use to determine when a Scope 3 category is considered de minimis to be reported?
A12. As noted in the example above, reporting requirements must account for industry-specific characteristics, operational relevance, and data availability. We are concerned that setting minimum reporting thresholds based solely on emission volume may not significantly reduce the initial burden, as companies would still be required to calculate emissions across all categories at least once to determine their eligibility for exemption.

Q13. How should CARB weigh reporting flexibility against alignment with current mandatory and voluntary practices and other international standards?
A13. We recommend an initial implementation phase that prioritizes flexibility to reduce the burden on companies. As the regulatory framework becomes more established, the scope of requirements can be gradually expanded if necessary.

Q14. Are these sectors the appropriate starting point for a phased approach to Scope 3 reporting? What factors should CARB consider in confirming or adjusting this prioritization?
A14. We find the option to mandate reporting starting with specific industries to be appropriate. When determining priorities, criteria should be based on the actual presence of Scope 1 and 2 high-emission sources, such as manufacturing facilities and direct transportation fleets.

Q15. Are these the appropriate categories to prioritize for initial reporting based on data availability and relevance across sectors?
A15. We believe that high-emission categories vary significantly by industry. Furthermore, some sectors may have negligible emissions in the proposed "top five" categories. Therefore, we consider Option 2 to be more appropriate than a rigid top-5 category requirement.

Q16. Are there assurance standards or frameworks not currently included in staff’s proposed list that should be recognized and why?
A16. From our perspective, the currently proposed list, which includes recognized international standards, is sufficient. No additional standards or frameworks are required at this time.

Q17. Approximately how many GHG assurance engagements can your organization complete annually for limited assurance?
A17. Not applicable. (This question is directed toward verification bodies.)

Q18. What cost ranges are reporting entities currently experiencing for limited assurance engagements?
A18. Not applicable. (Our company is not currently undergoing verification.)

Q19. What factors are driving assurance costs, and how do costs vary across entity size, sector, and assurance level?
A19. Not applicable. (This question is directed toward verification bodies.)

Q20. Are the costs presented today in the ballpark of your company's estimates for compiling, reporting, and assuring GHG emissions?
A20. Not applicable. (Our company is not currently undergoing verification.)

Q21. Will most of the costs associated with reporting be incurred in state or through offices in other jurisdictions (e.g., headquarters in other states, countries)?
A21. Not applicable. (Our company is not currently undergoing verification.)