California Air Resources Board

We respectfully urge CARB to modify the SB 253 disclosure form’s approach to emissions intensity reporting, such that it does not mandate the following metrics:
• Scope 1 emission intensity per million dollars in revenue (mtCO₂e per million dollars).
• Scope 2 emission intensity per million dollars in revenue (mtCO₂e per million dollars).

Public companies are already required under SEC regulations to disclose revenue, and many choose to report carbon intensity relative to revenue. However, private companies are not obligated to publicly file or disclose financial statements, including revenue. As a privately held, wholly family-owned organization, maintaining our private status—including not disclosing revenue—is a core principle. Requiring disclosure of carbon intensity per million dollars in revenue would effectively reveal our revenue figures, since emissions totals are also reported, allowing for straightforward back-calculation.

We recognize that the supporting memorandum for the California Corporate Greenhouse Gas Reporting Program: Scope 1 and Scope 2 Emissions Draft Reporting Template states that at least one intensity metric should be provided and lists “per million dollars in revenue” only as an example. Yet, the current draft template includes this metric as a mandatory field, without offering flexibility for alternative intensity measures.

We further recognize that the reporting template itself states in its disclaimer that it “does not modify, replace, or supersede the statues and does not impose requirements on anyone”. However, as currently written, the inclusion of a mandatory field for carbon intensity per million dollars in revenue represents a substantive new requirement not explicitly outlined in SB 253.

In summary, we urge CARB to revise the template to permit alternative intensity metrics, or otherwise exclude intensity, to avoid creating new disclosure obligations that would compromise private company confidentiality.