Número del envío: 8497
ID del envío: 59166
Submission UUID: 1bab1bfd-3e51-4944-846d-e834f027a87c

Creado: Mié, 15/04/2026 - 08:05
Completado: Mié, 15/04/2026 - 08:06
Modificado: Mié, 15/04/2026 - 10:46

Remote IP address: 76.170.111.65
Enviado por: sgrover
Idioma: English

Is draft: No

Marcado: Sí
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Submitted Comment
Mónica Galisteo
Howmet Aerospace
Answer to Public Consultation on Proposed Concepts for Subsequent SB 253 Rulemaking- Howmet Aerospace Inc.

Dear Sirs,

Howmet Aerospace Inc, a US headquartered leading global provider of advanced engineered solutions for the aerospace and transportation industries that will be reporting as per SB 253, welcomes the opportunity to provide feedback on the Proposed Concepts for Subsequent SB 253 Rulemaking.

The company offers this commentary to support implementation of SB 253, leaning on experience learned from similar reporting structures globally. As of end of 2025, the company employed over 2,400 Californians across manufacturing sites in the state, producing parts and components that enable the future of various modes of sustainable transport.

Please find attached our feedback on the public consultation.

Key points in our feedback are:

• CARB should align its rulemaking to the main standards on GHG calculation and reporting, such as the GHG Protocol. Flexibility on reporting scope 3 categories should be identical to the main standards, especially for the scope 3 categories that the GHG protocol deems as optional, like for example, category 11 for non-energy using products. This flexibility should be maintained independently of the scope 3 reporting option, among the three presented in the March 2026 workshop, that is finally chosen by CARB (Broad Applicability, Sectorial Phase-In or Category Phase-In).
• CARB should allow for flexibility on the timeline to integrate acquisitions and exclude divestitures from the report.

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