California Air Resources Board

Dear Chair Sanchez and California Air Resources Board Staff,

LIHI appreciates the opportunity to provide written comments to the California Air Resources Board (CARB) in response to the request for public comments on its March 23, 2026, Climate Disclosure Workshop. Please see the attached file for LIHI's comments that further discuss our recommendations that :
• Scope 2 reporting should follow the GHG Protocol’s 2015 Scope 2 Guidance as CARB begins implementing SB 253. If CARB later seeks to incorporate a different framework for Scope 2 reporting, including any changes that emerge from the ongoing extensive revisions to the GHG Protocol Corporate Standard, CARB should solicit stakeholder feedback before final adoption of any changes.
• Scope 3 reporting should consider the GHG Protocol’s recently published Land Sector and Removals Standard to incorporate emissions from water reservoirs, including those used to generate hydropower (i.e. Category 3).

LIHI applauds CARB’s efforts to create a robust climate disclosure reporting program pursuant to SB 253 and is eager and available to provide further assistance as CARB finalizes the reporting frameworks and sectoral guidance.

Best,
Surabhi