Submitted Comment Name Margaret McCallister Affiliation N/A Subject Comments on March 23, 2026 Climate Disclosure Workshop Message We submit these comments on behalf of a confidential client in response to the California Air Resources Board’s (“CARB”) request for comment on the March 23, 2026 Climate Disclosure Workshop. Proposed Emission Factor Datasets: Slide 16 CARB provided four potential emission factor sources for Scope 3 categories: (1) EPA’s Emissions & Generation Resource Integrated Database (eGRID); (2) IPCC Emissions Factor Database (EFDB); (3) EPA’s Emission Factors (EF) Hub; and (4) U.S. Environmentally-Extended Input-Output (USEEIO). This list should not be an exhaustive one. Regulations to implement SB 253 and SB 261 (as applicable) should account for companies that already align their reporting with the Comprehensive Environmental Data Archive (CEDA). Much like USEEIO, CEDA is an Environmentally Extended Input-Output (EEIO) database. CEDA, however, is more expansive than USEEIO, covering 400 industries across 148 countries and regions, covering 95% of the world’s GDP. CEDA meets the standards of the GHG Protocol and should be included as an emission factor dataset. Scope 3 Reporting Options: Slides 25-28 CARB provided three options for Scope 3 Reporting: (1) broad applicability; (2) sectoral phase-in; and (3) category phase-in. Category phase-in is an appropriate approach to implement reporting requirements as companies work to comply with these novel regulations. CARB has identified categories 6, 1, 3, 7, and 5 as the most-reported categories. It is appropriate for CARB to require reporting in these well-developed categories and provide companies with the necessary time and flexibility to develop reporting infrastructure for the remaining categories. Scope 3 emissions represent the majority of emissions for many companies and reporting requires intensive data review and synthesis. A phased, categorical approach with gradual expansion over time would allow companies to build out compliance capabilities and develop complete, accurate inventories for less-reported categories of emissions while prioritizing those categories that CARB has determined most essential for reporting. Thank you for your consideration of these comments. File Upload (i.e., Attachments): N/A N/A
Submission information