Submitted Comment Name Max Conerly Affiliation N/A Subject Clarification Questions Message Thank you for the opportunity to provide feedback on the content introduced in the August 21, 2025 Climate Disclosure Workshop. As part of a large, conglomerate company that is headquartered outside of the U.S., we would like to ask the following clarifying questions, while also pointing out the organizational complexity that you may want to consider in your final rules. We are a U.S. based company, and we own subsidiaries in the U.S. Our ultimate parent company is based outside of the U.S. 1. We are a U.S. based company under the 200s reporting scope. Our parent company based in Asia calculates Scope 1 & 2 to represent their global operations in Asia, U.S., and Europe. They also get limited assurance from their Asia-based auditor. Can we submit our Asia parent company’s total Scope 1 & 2 with their limited assurance? 2. As a U.S. based company that owns many subsidiaries in the U.S., we have different revenues. Our “standalone” revenue reflects our own entity’s sales, and then we have a much larger “consolidated” revenue that includes our entity’s sales + sales of all our subsidiaries. Our standalone revenue puts us out of scope, but our consolidated revenue puts us within scope. Which revenue will you use to determine applicability for the 200s? 3. Our company, like many others, follow reporting on a fiscal year (April – March). We understand that reporting FY24 GHG emissions in 2026 is under consideration by CARB, but from our perspective, this would not be consistent with our parent’s reporting timeline and it would cause more burden. We believe FY25 GHG data should be reported in 2026. At the same time, if the deadline is June 30, 2026, it is difficult to finalize our FY25 (April 2025-March 2026) GHG emissions and get limited assurance in only 3 months. We ask you to consider extending the deadline to September 30, 2026, to give the full 6 months to prepare, so that we can submit FY25 data in 2026, in line with the reporting practices of our parent company and many other companies. 4. We are a U.S. based company with some subsidiaries subject to the 200s, and we have other subsidiaries not subject to the 200s. If we are disclosing a consolidated parent report, should our report reflect only our subsidiaries that are within scope of the 200s? Or should our parent report represent all our subsidiaries, regardless of whether the subsidiary is individually subject to the 200s? File Upload (i.e., Attachments): N/A N/A
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