Submission Number: 1539
Submission ID: 20336
Submission UUID: 38ede597-9061-4831-883f-eb97e22606d0

Created: Wed, 01/29/2025 - 00:20
Completed: Wed, 01/29/2025 - 00:20
Changed: Wed, 02/05/2025 - 09:44

Remote IP address: 113.149.138.65
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Chika Nakanishi
N/A
Proposal about exemption and where to disclose

I would like to share my thoughts on the disclosure methods stipulated by the California Climate Disclosure Law.

Many large companies are required to disclose GHG emissions and climate-related financial risks due to compliance with the EU's CSRD, sustainability disclosure laws in the parent company's home country, and similar regulations.
They are already disclosing or preparing to disclose the information.

I'd like CARB to consider adding an exemption to SB253/SB261, which exempts companies if they are already disclosing in accordance with CSRD, ISSB or local disclosure standards equivalent to ISSB.

In the future, if other states develop similar regulations and require submission to state-specific platforms, it would increase administrative burdens without enhancing the effectiveness of climate change mitigation efforts.

In order to widely disseminate the disclosure status and content of the target companies to information users, it should be sufficient to publish a collection of links to each company's disclosure site, rather than collecting the disclosures themselves on a specific platform.

N/A