Submitted Comment Name Jimmy Nguyen Affiliation CPA / Advisor Subject SB 253 Message HSC Section 28532(c)(2)(A)(i)(I) states, "That a reporting entity, starting in 2026 on or by a date to be determined by the state board, and annually thereafter on or by that date, publicly disclose to the emissions reporting organization, if contracted for services, or the state board, all of the reporting entity’s scope 1 emissions and scope 2 emissions for the reporting entity’s prior fiscal year." My comment is focused on the phrase "by a date to be determined by the state board." In informal guidance, CARB has proposed making this "date" to be June 30, 2026. This date does not offer enough time for a reporting entity to engage a third party, obtain limited assurance, and provide a complete and accurate report on 2025 data. CARB should make the implementation deadline December 31, 2026, providing as much time as possible to meet the legislative requirements. HSC Section 28532(c)(1) states, "On or before July 1, 2025, the state board shall develop and adopt regulations to require a reporting entity to annually disclose all of the reporting entity’s scope 1 emissions, scope 2 emissions, and scope 3 emissions, and obtain an assurance engagement performed by an independent third-party assurance provider." Since CARB has taken the liberty to extend its July 1, 2025 legislative deadline, CARB should offer the same extension to the reporting entities attempting to comply with the legislative requirements. File Upload (i.e., Attachments): N/A N/A
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