On Friday, in advance of, and untethered from, the anticipated near-term release of a Notice of Proposed Rulemaking (NPR) that will ultimately (upon adoption) determine which companies and other entities are subject to the SB 253 (and SB 261) reporting requirements, CARB posted a draft reporting template for Scopes 1 and 2 GHG emissions that seeks an abundance of information from reporting entities, including information beyond what is required, or seemingly permitted to be required, under the governing legislation. The draft template is accompanied by a memo that, among other things, suggests CARB may consider limiting reporting entities’ approach to identifying organizational boundaries under the GHG Protocol “to support public transparency and improve comparability across entities.”
CARB is seeking public feedback on both the draft template and the topics addressed in the memo by October 27. See this summary from Ropes & Gray of the information sought by the template. The Society plans to respond to the NPR and to integrate our members' feedback on the template and the topics raised in the memo as part of our NPR comment letter.
If you are interested in participating in our response to the NPR, which is expected to be released tomorrow, please email Randi Val Morrison.