Submission Number: 7762
Submission ID: 53886
Submission UUID: c7819283-b29e-4322-a85f-1481d1b2f831

Created: Mon, 10/27/2025 - 20:32
Completed: Mon, 10/27/2025 - 20:32
Changed: Tue, 10/28/2025 - 10:39

Remote IP address: 98.98.28.178
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Ursula Antunez
SGS North America Inc
Comment on Template for Scope 1 and Scope 2 GHG for SB 253

Hi, I reviewed the template and identified some topics that were not included: disclosure of biogenic CO2, that as per GHG protocol shall be done separately from the scopes but at line 175 says scope 1 at page 25 of GHG protocol in section Scope 1; materiality threshold for the verification; it is missing NF3 which was a GHG added by the GHG protocol in its amendment of february 2013; it is not clear if the report will be only for GHG emissions or also for removals, as per GHG protocol that includes GHG emissions and removals.

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