Submitted Comment Name omer amar Affiliation N/A Subject Feedback on Draft Reporting Template for Scope 1 and Scope 2 Message Hi, Thank you for the opportunity to provide feedback on the Draft Scope 1 and Scope 2 GHG Emissions Reporting Template. I'm sending this email on behalf on Arbor (arbor.eco), based on our experience providing scope 1,2,3 measurement services to our clients. After reviewing the current version, we would like to provide feedback on two of the points in the memo document: 1. Organizational Boundaries: We strongly encourage CARB to retain all three boundary approaches (equity share, financial control, and operational control). Companies from all different industries are subjected to this new regulation and allowing flexibility accommodates the wide variety of businesses. 2. Disclosure by Source vs. by Gas: We support disclosure by emission source as the primary reporting view. However, an optional table for allocating emissions by gas within each category would be a good long term option. Most companies, especially those using spend-based estimation methods do not have access to the underlying gas-specific data or emission factors. Requiring such detail could impose disproportionate data-collection burdens, especially on companies doing GHG disclosure for the first time. Optional granularity ensures comparability for those able to provide it while maintaining accessibility for all reporters. We appreciate CARB providing opportunities to submit feedback and would be happy to provide further input as the template evolves. Best, Omer File Upload (i.e., Attachments): N/A N/A
Submission information