Submitted Comment Name Benjamin Martin Affiliation eBay Inc. Subject SB 253 Implementation and Scope 2 Accounting Message As a company headquartered in California and subject to CA SB 253, eBay thanks CARB for seeking public input as it implements SB 253. We respectfully submit high-level considerations for CARB as it finalizes GHG reporting rules. We encourage CARB to maintain consistent GHG disclosure rules for the initial phase of its reporting program and through 2033. This means allowing companies to use the GHG Protocol’s Scope 2 Guidance from 2015 to calculate Scope 2 inventories. The 2015 Scope 2 Guidance was in place when SB 253 was enacted, and this guidance is broadly used by companies to report their Scope 2 footprints today. We and other companies have relied on the 2015 Scope 2 Guidance to inform our procurement of clean electricity, and uncertainty around Scope 2 reporting rules could disrupt how we and others can procure clean electricity. CARB should provide clarity that the 2015 Guidance will be a permitted accounting framework for its reporting standard through at least 2033. CARB should not automatically adopt updates to the GHG Protocol. CARB should engage stakeholders to understand how new reporting rules may impact clean electricity procurement and GHG emission reductions. To ensure companies are not penalized for any long-term offtake agreement for clean electricity that they execute prior to 2033, CARB could continue to allow companies to report under 2015 Scope 2 Guidance. If CARB considers alternatives, CARB should recognize the importance of transition provisions, such as legacy clauses allowing existing clean electricity transactions to be used in Scope 2 reporting. We share the ambition of the GHG Protocol and other stakeholders to further accelerate carbon-free electricity (CFE) deployment and believe that achieving global greenhouse gas reduction goals depends on robust, voluntary demand for CFE. As this crucial guidance undergoes its first significant update in a decade, we are extremely concerned that the proposed revisions to market-based accounting which would require voluntary buyers to match CFE purchases to individual company load on an hourly and physically deliverable basis could: 1. Result in limited benefits to carbon accounting accuracy 2. Drive inefficiencies in private-sector action, slowing system-wide decarbonization 3. Discourage voluntary clean energy procurement, potentially dramatically 4. Increase electricity prices for individuals and companies We thank you for the opportunity to provide comments and look forward to further engagement on this important topic. File Upload (i.e., Attachments): N/A N/A
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