Submitted Comment Name Jake Rascoff Affiliation Ceres Subject Ceres Report - Companies Covered by the California Climate Disclosure Laws: An Updated Estimate Message Ceres worked with S&P Global to produce an updated estimate of the number of companies covered by SB 261 and SB 253. Initial estimates of 10,000 and 5,000 covered companies, respectively, likely overstated the number of reporting companies because of double counting of subsidiary entities. Altogether, S&P estimates 2,675 companies, both public and private, with revenues over $500 million; and 1,971 companies with revenues over $1 billion. These findings are based on fiscal year 2022 revenue alone; we did not attempt to screen for “doing business in California.” This submission supplements Ceres' main, forthcoming comment letter. File Upload (i.e., Attachments): Companies Covered by the California Climate Disclosure Laws_Final.pdf
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