California Air Resources Board

1. Mandatory Disclosures

1.1 Organization boundaries

Feedback:

CARB should further specify expectations for organizational boundaries while keeping flexibility to accommodate diverse reporting structures. In particular, we recommend allowing foreign based parent companies with subsidiaries operating in California to report consolidated data at the parent company level, rather than submitting multiple reports for each U.S. legal entity.

Rationale:

This approach avoids duplicative filings, improves comparability, and stays consistent with other frameworks that allow consolidated reporting (such as CSRD).

1.2 Disclosure by Source

Feedback:

In the Yes/No questions on “inventory boundary” (e.g., “Indicate Yes or No to confirm whether Scope 1 – Stationary Combustion is included in your reporting boundary.”), please clarify whether “included in the reporting boundary” means (a) the source is part of the disclosed totals, or (b) information is only available but excluded from disclosed totals.

Rationale:

Without this clarification, filers may interpret “included” as data availability rather than inclusion in the disclosed amounts, which would undermine consistency and assurance.

2. Optional fields

2.1 Disclosure by gas

Feedback:

Maintain gas level disaggregation as optional. Retrieving emissions by individual gas can be disproportionately complex for certain energy forms, particularly Scope 2 for purchased steams.

Rationale:

Many systems capture Scope 2 as CO2e totals and are not configured to disaggregate gases, forcing disaggregation could degrade data quality or introduce workaround estimates. Retaining optional status enables a pragmatic, quality first implementation while still encouraging best effort disclosures where feasible.