Submission Number: 7648
Submission ID: 53181
Submission UUID: b8958ce7-aad9-4fc3-a295-97b7c900bf43

Created: Tue, 10/14/2025 - 15:00
Completed: Tue, 10/14/2025 - 15:00
Changed: Tue, 10/28/2025 - 10:49

Remote IP address: 169.224.183.83
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Casey King
N/A
Draft Reporting Template for Scope 1 and Scope 2 Greenhouse Gas Emissions Pursuant to Health and Safety Code § 38532

We noted that the Scope 1 and 2 template appears to mandate the use of AR4, as the definition for "Global Warming Potential" states that entities "should" utilize the AR4 GWP values. This is somewhat contradicted by the question in the Form tab, row 66, that asks entities to indicate the source of the GWP factors they are using (i.e., implying optionality). We have transitioned to the use of AR6 for our voluntary reporting, and would appreciate any clarity on whether AR4 is mandated or optional for reporting to CARB (with our preference for optionality).

Additionally, we would appreciate further clarity on the extent of the data required to be covered by the 3rd Party Verification, given the various Disclosure items in the draft reporting template. Should the limited assurance opinion cover only total Scope 1 and 2 emissions, or also the breakouts by source that are reflected in the Form tab (mobile, process, fugitive, etc.)?

Lastly, we noted that there appears to be rows missing on the Form tab for Disclosures related to direct emissions from Stationary Combustion (for Scope 1), and indirect emissions from Purchased Electricity (for Scope 2).

Thank you,
Casey King, ESG Controller

N/A
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