Submitted Comment Name Anthony Livecchi Affiliation Internal Audit Director Subject Public Comment Responses Message The following represents my personal opinions on the legislation, not of any group, Company, or affiliate. Does business in California: This should be defined as a corporation or company which is headquartered in California, or, 50%+ of the company's revenues are within the state of California. This is state legislation. It should be specific to the state. Protocols and Standards: Companies should be able to report on whatever standards are available, as long as a bridge or restatement of previous ghg emissions are also recalculated based on the standards used for reporting if there is a change. Data Reporting Companies are already hammered with regulatory compliance, and unclear new state rules add more complexity, confusion, and costs. Companies which voluntarily report currently feel like their efforts are being wasted if CARB doesn't know how to obtain that publicly available information. Scope 1 and Scope 2 emissions shouldn't need to be reported to CARB if they're already submitted via a Corporate Sustainability Report (most large companies already do this). If CARB needs that information submitted to them, because Google is hard, create a website with input fields and require a Company to submit by a certain date and link to the company's CSR. GHG Protocol Use the GHG protocol. Don't create your own standards. Assurance Providers CARB needs to get with the public accounting firms on this to clearly define what standards are to be used to comply with CARB. There are years of experience in the limited assurance space around corporate sustainability reports, so use it. Also, strip reasonable assurance out entirely. The public doesn't care that Company X has designed and effectively operated a key control which ensures that Joe reviews Brenda's work that calculated that 1+1=2. Many of the co2e factors change constantly and it is publicly noted that this is not an exact science. The standards and the assurance providers are NOT ready for reasonable assurance, and probably never will be. Typically, the people which are inputting and reviewing this data are not trained finance professionals, they're operators or SHE personnel. SB261 Most companies are already reporting to TCFD and are reporting climate related risk factors in their 10Ks. California should align themselves with TCFD. Scope 3 Remove scope 3 requirements. Thanks, Anthony Livecchi Director, Internal Audit Koppers, Inc. (412) 609-9704 File Upload (i.e., Attachments): N/A
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