California Air Resources Board

The California Retailers Association (CRA) appreciates the opportunity to continue to provide comments on the rulemaking for California’s Corporate Greenhouse Gas Reporting Program (The Program) following the California Air Resources Board’s (CARB) virtual public workshop held on March 23, 2026 to support the development of The Program authorized by Senate Bill 253 (Wiener, Stats. 2023; codified in Health & Safety Code (HSC) § 38532), as amended by SB 219 (Wiener, Stats. 2024, Chapter 766; codified in HSC §§ 38532 and 38533).

The uploaded file is a letter to CARB that contains CRA’s comments and concerns that remain following CARBs March 23 workshop, which included an update from CARB staff on additional information for the August 10, 2026, Scope 1 and Scope 2 emissions reporting deadline; the next stage in regulatory development; overview of the development of the greenhouse gas reporting requirements for 2027-2030 under HSC § 38532; preliminary staff options for Scope 3 emissions reporting requirements for 2027-2030; solicitation of alternative approaches; and an overview of staff’s approach to the economic analysis.

We look forward to ongoing dialogue and are happy to make our subject matter experts available to answer specific questions or provide additional information that may be useful as CARB moves forward with finalizing California’s Corporate Climate Reporting regulations.