Submitted Comment Name Jason Cole Affiliation N/A Subject Opposition to Senate Bill 253 Message To Whom It May Concern, SB 253 is not grounded in how the real world actually works. On paper, requiring companies to report emissions across their entire footprint might sound reasonable. In practice, it pushes companies into tracking and certifying data they do not control and, in many cases, cannot even reliably access. Scope 3 reporting is the biggest issue. You are asking companies to estimate emissions across suppliers, customers, and third parties, often several steps removed. That is not real data—it is modeling, assumptions, and guesswork that will be treated as fact. From an operational standpoint, this is going to be expensive and time-consuming. Those costs do not stay with large corporations—they move downstream. Smaller operators, distributors, and retailers will feel it, and so will consumers. In a business like fuel distribution, where margins are already tight and heavily regulated, this is not a minor administrative burden. It is another layer that chips away at viability. There is also a competitive reality that cannot be ignored. Companies operating in California will be held to a standard that competitors in other states and countries simply are not. That does not reduce global emissions—it just shifts business activity somewhere else. We have seen this pattern before. Another concern is liability. You are effectively requiring companies to publicly report numbers that are, by definition, estimates. That creates legal exposure tied to information that cannot be fully verified. It puts businesses in a position where they are penalized not for actual emissions, but for how well they can model them. I am not opposed to responsible environmental policy. But this bill is not targeted, and it is not practical. It adds cost, complexity, and risk without a clear line to meaningful results. If the goal is to move the needle, the focus should be on infrastructure, technology, and realistic timelines—not forcing companies to build reporting systems around data they do not control. I would strongly encourage you to reconsider SB 253. Sincerely, Jason Cole File Upload (i.e., Attachments): N/A N/A
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