Submitted Comment Name Carolyn Payne Affiliation JELD-WEN, Inc. Subject Feedback on proposed template Message I am strongly supportive of the requirements established by California Senate Bill 253 for large companies conducting business in California, as these measures enhance transparency and accountability across organizations. However, I would like to express concerns regarding the practicality and value of two specific disclosure items in the Draft Reporting Template: 1. Indirect Emissions from Purchased Heating and Cooling: In most manufacturing facilities, electricity submetering is typically applied to process equipment rather than to heating and cooling systems. As a result, estimates for heating and cooling emissions are likely to be overly generalized, limiting the usefulness of the reported data. Furthermore, the effort required to develop auditable assumptions for these estimates may not be justified by the incremental value provided. 2. Reporting of Immaterial Emission Sources: Companies should be permitted to demonstrate that certain emission sources are immaterial without the need to quantify and report these emissions annually. If a company can reasonably substantiate that an emission source cannot be material, a clear explanation should suffice for CARB’s purposes. Requiring annual quantification of such emissions would likely necessitate significant assumptions or considerable time investment, with little to no benefit, given the immateriality of the emissions in question. Thank you for considering these comments as you refine the reporting template. File Upload (i.e., Attachments): N/A N/A
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