California Air Resources Board

3Degrees Group Inc. (3Degrees) appreciates the opportunity to provide feedback to the California Air Resources Board (CARB) on the implementation of the California Corporate Greenhouse Gas Reporting Program. 3Degrees’ comments focus on the following key recommendations to strengthen CARB’s SB 253 reporting framework:

+ Organizational Boundaries: 3Degrees recommends that CARB align organizational boundary options with the GHG Protocol’s (2004/2015) established approaches
+ Accounting Methods: 3Degrees recommends CARB (1) require companies to dual report emissions for scope 2 disclosure; (2) precisely define contractual instruments in CARB’s reporting template; and (3) specify that the SB253 Reporting Guidance aligns with GHG Protocol’s Scope 2 Guidance (2015)
+ Emission Factors: 3Degrees supports CARB providing recommended emission factor datasets for all scopes and recommends CARB establish differentiated scope-specific criteria that clearly distinguishes required vs. preferred datasets as well as conditions for using proprietary data
+ Scope 3 Reporting: 3Degrees supports the Broad Applicability approach to scope 3 reporting in order to provide reporting flexibility for de minimis categories
+ Requested Feedback on Alternatives: 3Degrees requests that CARB implement a complete reporting exemption for companies that exceed the revenue threshold but emit fewer than 10,000 mt CO2e across scopes 1 and 2

3Degrees' attached proposal provides additional detail and background on these recommendations.