California Air Resources Board

As a sustainability practitioner and principal consultant responsible for climate-related data gathering and reporting on behalf of clients, including my company Vaco (which meets the threshold for reporting under both SB 253 and 261), I have several comments to the solicitation for feedback released by CARB on December 16, 2024.
First, with respect to the Standards in Regulation, paragraph 3, I would like to highly encourage CARB to minimize duplication of effort for entities required to report emissions or risk under existing paradigms by utilizing a voluntary reporting platform provider. Consider the CDP, which has the largest market share of climate reporting entities and in 2024 collected data from over 24,000 companies. CDP has recently ensured alignment of its questionnaire with frameworks such as the Task Force on Climate-related Financial Disclosures (TCFD), the Science Based Targets initiative (SBTi) and the International Sustainability Standards Board (ISSB) under the IFRS guideline S2. Given the alignment with TCFD, CDP is naturally aligned with SB 261 since both leverage TCFD as the foundational framework. Also, CDP collects scope 1, 2, and 3 information which aligns with the SB 253 disclosure requirements.
To more directly address questions 5 and 6 under General Data Reporting, I believe that CARB should contract reporting to the CDP or, at a minimum, accept an export of the reporting entity’s CDP response as sufficient to meet the needs of SB 253 and 261. This would significantly reduce the burdens of compliance on companies as they would not need to build new reporting processes from scratch. It also offers a ready-built structured and standardized disclosure format which makes it easier for regulators at CARB to review and compare reports while removing the upfront workload of building a reporting framework from scratch.
By adopting the CDP as the primary disclosure platform for SB 253 and SB 261, CARB ensures alignment of its regulatory frameworks with international regulator frameworks while also meeting global investor expectations for transparent, accurate, decision-useful climate reporting. This alignment reduces the burden of reporting on sustainability practitioners so that they can focus efforts on executing projects to make progress against emissions reduction goals instead.