Submission Number: 1669
Submission ID: 21806
Submission UUID: 57ddf772-f550-4b90-9685-9b3fffdaba2a

Created: Tue, 03/18/2025 - 15:54
Completed: Tue, 03/18/2025 - 15:54
Changed: Wed, 03/19/2025 - 09:31

Remote IP address: 75.82.59.14
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Douglas Hileman
DHC LLC
Comments to Inform Implementation of Calif. Climate Disclosure Laws

DHC is pleased to provide comments in CARB's invitation. The attached file addresses each item. The most critical comments:
Specify GHG Protocol for all parameters where applicable; ISSB S-2 where GHG Protocol does not address the topic.
Use CDP as the disclosure portal, and NOT a separate submittal to CARB. Provide guidance annually on what fields of the CDP questionnaire fulfill the Calif. disclosure requirements.
Do not specify what type of firm should perform assurance. Allow technical firms to conduct assurance. The assurance providers should indicate what standards they used in their report.
Change the reporting deadline to reflect the reality of obtaining data, resource limitations at regulated and otherwise affected entities (e.g., business partners), and convention established by other laws (Dodd-Frank Conflict Minerals) and disclosure portals (CDP).
Respectfully submitted, Douglas Hileman, FSA, CRMA, CPEA