Submitted Comment Name Seth Herron Affiliation WSP Subject WSP comments to the Draft Reporting Template for Scope 1 and Scope 2 GHG Emissions Message Dear CARB Team, WSP respectfully submits comments to CARB related to the Scope 1 and Scope 2 Emissions Draft Reporting Template. We are pleased to offer our insights based on WSP's experience compiling hundreds of GHG inventories for corporate clients over the past two decades. We have uploaded a version of the template with our detailed comments in the "WSP Comments" column. We hope you will find these insights valuable in refining the template. One key point we would like to emphasize is the importance of maintaining flexibility in identifying organizational boundaries for reporting entities. We understand that CARB is currently evaluating whether to limit the approach or retain flexibility to accommodate diverse corporate structures. Based on our experience, we strongly advise against specifying which organizational boundary approach reporting companies should use. Flexibility in this aspect is crucial to accurately reflect the varied and complex nature of corporate organizational structures, and retains the optionality allowed by the GHG Protocol. Thank you for considering our comments. We appreciate the opportunity to contribute to this important initiative. Seth Herron Assistant Vice President Sustainability, Energy and Climate Change WSP File Upload (i.e., Attachments): sb253_draft_scope1_2_ghg_template_wsp-10-22-25.xlsx N/A
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