On February 6, the Society submitted to the California Air Resources Board (“CARB”) and other policymakers this member-informed comment letter on CARB’s proposed Climate Data and Financial Risk Reporting Fee Regulation to implement SB 253 and SB 261. The Society’s letter focuses primarily on the deadline for SB 253 reports and associated timing considerations; the fee structure and process; the record-keeping requirements; and various rulemaking-related assumptions and process concerns. Thank you to the many members of the CARB Working Group who informed our positions and participated in the drafting and vetting of this letter.
Additional comment letters are here. The Society’s prior written submissions relating to SB 253 and SB 261 are posted here. To join the CARB / state climate disclosure working group, email Randi Val Morrison.