California Air Resources Board

California Air Resources Board (CARB)
1001 I Street
Sacramento, CA 95814
P.O. Box 2815
Sacramento, CA 95812
Subject: Request for Optional Designation of Emissions Intensity Metrics in SB 253/SB 219 Reporting Template
To Whom It May Concern:
As a private employee-owned company, Schweitzer Engineering Laboratories, Inc. (SEL) does not publicly disclose its annual revenue. This information is confidential and commercially sensitive. Requiring emissions intensity disclosures per million dollars of revenue, as outlined in lines 51 and 58 of the template report, would effectively reveal proprietary financial data.
SEL respectfully requests that the emissions intensity metrics be designated as optional, without penalty. We recommend considering alternative intensity indicators, such as production-based metrics aligned with EPA EPCRA Toxics Release Inventory (Form R) reporting.
This request is consistent with the intent of SB 253 and SB 219, which do not mandate this specific ratio. It also aligns with guidance from the World Resources Institute (page 63), which classifies ratio performance indicators as optional, and with ISO 14064-1, section 9.3.2(g).

Thank you for your consideration,

Electronic signature

Mike Wilfong
Environmental Health and Safety Director
Schweitzer Engineering Laboratories, Inc.