Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation

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Comment From: Green America (Cathy Becker)

2/26/26 @ 12:33 PM

Please find our comment attached. Thank you.

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Comment From: Otto Starzmann

2/26/26 @ 10:41 AM

I submit the attached written testimony in strong support of CARB's proposed SB 253 regulations, with five targeted technical recommendations on the three decisions before the Board today: (1) graduate the flat fee structure by revenue tier; (2) allo...↓

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Comment From: Biocom (Gilbert Lara)

2/26/26 @ 10:26 AM

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Comment From: Sandia National Laboratories (Konstantin Parkhomenko)

2/26/26 @ 9:37 AM

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Comment From: U.S. Tire Manufacturers Associ... (Stephanie Schlea)

2/26/26 @ 9:22 AM

Please see attached comments from the U.S. Tire Manufacturers Association regarding CARB's Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation. Please don't hesitate to reach out to ...↓

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Comment From: Leona Hwang

2/09/26 @ 11:06 PM

1. Regarding Reporting Entities

1.1. Request for additional criteria beyond revenue for determining entities subject to disclosure
- It appears excessive to impose disclosure obligations on companies that only perform sales functions, have no pr...↓

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Comment From: Leona Hwang

2/09/26 @ 11:03 PM

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Comment From: Class of '85 Regulatory Respon... (Yuyan Pu)

2/09/26 @ 9:21 PM

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Comment From: Consumer Technology Associatio... (Katie Reilly)

2/09/26 @ 7:14 PM

Please see attached file for comments from the Consumer Technology Association.

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Comment From: Edison International (Aurora Winslade)

2/09/26 @ 7:04 PM

Thank you for accepting Edison International's comments regarding the reporting deadline and Scope 2 definition for the proposed rulemaking for SB 253.

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Comment From: California Environmental Voter... (Gracyna Mohabir)

2/09/26 @ 6:15 PM

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Comment From: Covington & Burling LLP (Jayni Hein)

2/09/26 @ 6:10 PM

Dear Deputy Executive Officer Sahota and California Air Resources Board:

Please find the attached comment letter submitted on behalf of our client in response to the California Air Resources Board's request for public comment on its December 23, 202...↓

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Comment From: American Coatings Association (Annebelle Klein)

2/09/26 @ 6:04 PM

Please see ACA's comments in response to CARB's proposed regulations for SB 253 and SB 261 attached.

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Comment From: Davis Wright Tremaine LLP (Stacey Sprenkel)

2/09/26 @ 6:01 PM

Davis Wright Tremaine LLP provides the attached comments.

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Comment From: Alisa White

2/09/26 @ 5:56 PM

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Comment From: The California Retailers Assoc... (Sarah Pollo Moo)

2/09/26 @ 5:45 PM

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Comment From: California Chamber of Commerce (Jonathan Kendrick)

2/09/26 @ 5:42 PM

Attached please find the comments of the California Chamber of Commerce and others on the SB 261 and BS 253 ISOR and proposed regulatory package

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Comment From: POET (Joshua Wilson)

2/09/26 @ 5:32 PM

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Comment From: Nixon Peabody LLP (Alison Torbitt)

2/09/26 @ 5:32 PM

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Comment From: Supply Chain Federation (Sarah Wiltfong)

2/09/26 @ 5:25 PM

Please see the attachment.

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Comment From: Jeremy Weinstein

2/09/26 @ 5:24 PM

Please see attached letter.

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Comment From: Environmental Defense Fund (Stephanie Jones)

2/09/26 @ 5:22 PM

Please see attached.

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Comment From: California Water Association (Kaitlyn Johnson)

2/09/26 @ 5:10 PM

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Comment From: Sequent Energy Management (Erin Sullenger)

2/09/26 @ 4:59 PM

Please see attached comments from Sequent Energy Management. Thank you.

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Comment From: California Manufacturers and T... (Elizabeth Esquivel)

2/09/26 @ 4:54 PM

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Comment From: Community Health Group (Ann Warren)

2/09/26 @ 4:52 PM

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Comment From: Carbon Accountable (Michael Schmitz)

2/09/26 @ 4:49 PM

Carbon Accountable has been deeply involved in providing legal and technical support for this legislation since its inception in 2021. We strongly believe these landmark laws will help usher in a new era of corporate transparency and provide critical...↓

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Comment From: Kern Energy (Brooke Holland)

2/09/26 @ 4:49 PM

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Comment From: Arizona Chamber of Commerce & ... (Grace Appelbe)

2/09/26 @ 4:41 PM

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Comment From: California Council for Environ... (Kirstin Kolpitcke)

2/09/26 @ 4:34 PM

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Comment From: Association of Independent Cal... (Nick Romo)

2/09/26 @ 4:34 PM

Dear Chair Sanchez,

On behalf of the Association of Independent California Colleges and Universities (AICCU),
which represents more than 80 non-profit colleges and universities, I am submitting
comments in support of the staff recommendation to exem...↓

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Comment From: ACORE (Jeffrey Gorham)

2/09/26 @ 4:20 PM

Please see attached for ACORE's comments. Thank you very much for your consideration.

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Comment From: Lawrence Livermore National Se... (Nick Graves)

2/09/26 @ 3:33 PM

Please see the attached file.

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Comment From: US Sustainable Investment Foru... (Maria Lettini)

2/09/26 @ 3:14 PM

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Comment From: Western States Petroleum Assoc... (Jodie Muller)

2/09/26 @ 3:05 PM

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Comment From: American Iron and Steel Instit... (Tyler Hengen)

2/09/26 @ 2:51 PM

Attached are the comments of the American Iron and Steel Institute regarding the proposed implementation of CARB's GHG Emissions Disclosure and Climate-Related Financial Risk Programs. Questions and additional follow-up may be directed to Tyler Heng...↓

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Comment From: SIFMA (Kim Chamberlain)

2/09/26 @ 2:10 PM

Attached please find SIFMA's Comments on CARB's Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation. We appreciate the opportunity to provide feedback and are happy to answer any que...↓

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Comment From: Dave Jones

2/09/26 @ 2:00 PM

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Comment From: American Forest and Paper Asso... (Julie Landry)

2/09/26 @ 1:48 PM

Comments from the American Forest and Paper Association can be found in the attachment.

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Comment From: Berkshire Hathaway Energy Comp... (Jennifer McIvor)

2/09/26 @ 1:43 PM

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Comment From: The Greenlining Institute (Monica Palmeira)

2/09/26 @ 1:42 PM

Comments from The Greenlining Institute on the Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation Implementing Senate Bills 253 and 261

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Comment From: Coalition of Farm Credit Syste... (Rachel Saltzman)

2/09/26 @ 1:26 PM

Please see attached comment letter.

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Comment From: CARB (Board Clerk - 2,847 Non-Docket Submissions Received)

2/09/26 @ 1:25 PM

Form Letter Received to cotb@arb.ca.gov - Submitted to docket system by Board Clerk on behalf of the Public.

* CARB RECEIVED 2,847 NON-DOCKET SUBMISSIONS CONTAINING THE COMMENT SHOWN BELOW: *

"California Air Resources Board Official Comment SB 253,

I u...↓

Insurance companies play a significant role in financing and backing fossil fuel infrastructure and invest heavily in industries that drive climate change. At the same time, many insurance companies are sticking Californians with the climate bill by withdrawing from communities and denying and delaying claims. Excluding insurance companies from emissions reporting leaves out a sector with a clear and direct connection to growing climate risk that is threatening the state.

The public deserves transparency about the insurance sector’s climate harms. This exemption would weaken the rule and undermine public confidence in the climate disclosure program. The regulation should be finalized without delay and applied consistently to all covered corporations, including insurance companies, which clearly meet the criteria of SB 253.

Sincerely,"

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Comment From: EnergyTag (Alex Piper)

2/09/26 @ 1:23 PM

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Comment From: Center for Resource Solutions (Lucas Grimes)

2/09/26 @ 1:08 PM

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Comment From: Dairy Institute of California (Katie Davey)

2/09/26 @ 1:07 PM

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Comment From: Natural Resources Defense Coun... (Elizabeth Derbes)

2/09/26 @ 1:04 PM

Please see attachment.

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Comment From: Adarsh Srinivasan

2/09/26 @ 1:00 PM

On behalf of IETA's 300+ member organizations, we appreciate this opportunity to provide feedback to CARB on the proposed initial regulation to support the Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure programs.

Pl...↓

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Comment From: California ISO (Andrew Ulmer)

2/09/26 @ 12:52 PM

Please see attached comments.

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Comment From: Public Citizen, Americans for ... (Clara Vondrich)

2/09/26 @ 12:43 PM

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Comment From: Christopher Lish

2/09/26 @ 12:36 PM

Monday, February 9, 2026

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

Subject: Don't exempt insurance companies from reporting emissions under law -- Proposed California Corporate Greenhouse Gas Reporting...↓

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Comment From: WattTime (Chandni Sinha Das)

2/09/26 @ 11:56 AM

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Comment From: Ceres (Jake Rascoff)

2/09/26 @ 11:41 AM

Please see the attached PDF for Ceres' comment letter on the initial proposed regulation.

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Comment From: Clean Energy Buyers Associatio... (Lindsay Battenberg)

2/09/26 @ 11:30 AM

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Comment From: Beveridge & Diamond P.C. (Eric Christensen)

2/09/26 @ 11:01 AM

Public comment on CARB's Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure initial regulation.

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Comment From: As You Sow (Mary Zuccarello)

2/09/26 @ 10:36 AM

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Comment From: John Bode

2/09/26 @ 10:28 AM

Please see attached for Corn Refiners Association comments.

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Comment From: XBRL US (Campbell Pryde)

2/09/26 @ 9:55 AM

Please accept this comment letter from XBRL US in regards to the California Air Resources Board Notice of Public Hearing to Consider the Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Discloure Initial Regul...↓

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Comment From: RSM US LLP (Scott Wilgenbusch)

2/09/26 @ 8:40 AM

RSM US LLP (RSM, we) values the opportunity to offer our comments on the California Air Resources Board's (CARB) Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation (the Proposed Reg...↓

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Comment From: Sam Riley (Samantha Riley)

2/09/26 @ 5:49 AM

Please see attached our letter on the Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation.

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Comment From: Kymm Wilson (Kymm Wilson)

2/07/26 @ 1:36 AM

> Everybodys Cool International (Entity #6350466) hereby submits this comment in support of the initial regulatory framework for SB 253. While we fall below the mandatory reporting threshold, we have officially adopted the "ATB Framework" which manda...↓

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Comment From: Seren Taylor

2/06/26 @ 4:47 PM

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Comment From: Evergreen Renewables Inc (Michael Leggett)

2/06/26 @ 4:42 PM

We appreciate CARB's engagement with stakeholders as it implements SB 253 and respectfully offer a few high-level recommendations as GHG reporting rules are finalized.

1. Maintain stable Scope 2 accounting through the initial implementation period. ...↓

We encourage CARB to provide certainty by allowing companies to continue using the GHG Protocol's current Scope 2 Guidance (2015) through at least 2033. This guidance was in effect when SB 253 was enacted and remains the foundation of corporate clean electricity procurement today. Companies have made long-term investments and contractual commitments based on these rules that enable clean energy projects. Introducing uncertainty about Scope 2 accounting during the early years of SB 253 risks disrupting procurement and slowing progress at a time when accelerating clean electricity deployment is critical.

Policy stability is particularly important because the most impactful procurement strategies rely on long-term contracts. Multi-year power purchase agreements, long-term REC contracts, and similar instruments provide the predictable revenue that enables new renewable energy projects to secure financing. Sudden changes to accounting rules can undermine confidence in these contracts and reduce the willingness of companies to enter into new long-term agreements.

2. Avoid automatic adoption of future GHG Protocol revisions and ensure a deliberate transition.

CARB should not automatically incorporate future changes to the GHG Protocol. If CARB considers alternative approaches after 2033, we encourage a transparent process that evaluates how any new accounting framework would affect clean electricity procurement and real-world emissions reductions.

In particular, CARB should ensure that companies are not penalized for long-term clean electricity contracts executed prior to any rule changes. Transition provisions, including legacy treatment for existing agreements, will be essential to preserve market confidence and avoid stranding investments that were made in good faith under existing guidance.

3. Consider the market impacts of more granular matching requirements.

Emerging proposals that emphasize increasingly granular temporal or geographic matching should be evaluated carefully in the context of SB 253. While improved data and transparency can be valuable, overly restrictive matching requirements risk increasing cost and complexity in ways that reduce participation and weaken demand for new clean energy.

The clean electricity market has scaled largely because annual, certificate-based accounting enabled broad participation and supported long-term contracting that enabled new projects. Policies that make procurement significantly more complex or restrictive could unintentionally slow the pace of new project development by reducing the pool of participating buyers and undermining long-term revenue certainty.

For SB 253 to succeed, the reporting framework should reinforce the conditions that have enabled rapid renewable energy deployment: stable rules, scalable participation, and strong incentives for long-term contracting.

We appreciate CARB's leadership and the opportunity to provide input.

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Comment From: California Bankers Association (Chris Shultz )

2/06/26 @ 4:24 PM

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Comment From: California Bankers Association (Chris Schultz)

2/06/26 @ 4:22 PM

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Comment From: Schneider Electric (Amy Mmagu)

2/06/26 @ 3:31 PM

Please see attached comments

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Comment From: Bonneville Power Administratio... (Alisa Kaseweter)

2/06/26 @ 12:37 PM

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Comment From: Society for Corporate Governan... (Randi Morrison)

2/06/26 @ 12:17 PM

Dear Ladies & Gentlemen,

Please see attached letter on behalf of the Society for Corporate Governance.

Kind regards,

Randi Val Morrison
General Counsel & Chief Knowledge Officer

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Comment From: Mequela Moreno (Mequela Moreno)

2/06/26 @ 11:33 AM

I appreciate the opportunity to provide public comment on CARB's implementation of SB 253, the Climate Corporate Data Accountability Act. I am submitting this comment on behalf of ECOncrete, a company that works in coastal and marine infrastructure w...↓here both greenhouse gas emissions and ecological outcomes are material considerations.

SB 253 is a critical step toward transparency in corporate climate reporting, particularly for Scope 3 emissions associated with capital goods and construction activities. For infrastructure-intensive sectors such as ports, transportation, energy, and coastal development, embodied emissions from construction materials represent a significant portion of Scope 3 emissions. However, these same infrastructure assets also interact directly with California's coastal and marine ecosystems for decades.

As CARB develops Scope 3 reporting guidance, I urge the Board to explicitly recognize habitat creation and ecological performance as relevant contextual information for long-lived infrastructure assets. While habitat creation does not replace greenhouse gas accounting or emissions disclosure, it is a meaningful component of value-chain impact and climate risk assessment. Infrastructure materials deployed in marine environments can either degrade ecosystems or actively support habitat formation, biodiversity, and ecological resilience.

Manufacturers and project developers increasingly generate quantitative data on biological colonization, habitat complexity, and ecological performance associated with infrastructure materials. Allowing companies to reference this information alongside Scope 3 emissions disclosures would improve the quality and completeness of climate-related reporting, particularly for assets located in climate-vulnerable coastal zones. This approach aligns with California's broader climate, biodiversity, and resilience goals and reflects the reality that emissions impacts and ecological outcomes are interconnected for coastal infrastructure.

I encourage CARB to provide guidance that enables companies to disclose embodied emissions while also transparently describing habitat creation and ecological performance associated with long-lived capital goods. Doing so will strengthen SB 253 implementation by ensuring disclosures reflect not only emissions quantities, but the real-world environmental consequences of infrastructure investment decisions.

Thank you for the opportunity to comment and for CARB's continued leadership in advancing climate accountability and environmental stewardship.

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Comment From: The Climate Registry (Amy Holm)

2/05/26 @ 6:26 PM

Please find attached for The Climate Registry's (TCR) comments in response to the Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation. Thank you very much for your consideration.

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Comment From: Sabin Center for Climate Chang... (Andy Fitch)

2/05/26 @ 5:45 PM

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Comment From: Watershed (Rob Chesnut)

2/05/26 @ 5:24 PM

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Comment From: TransAlta Energy Marketing U.S... (Denelle Peacey)

2/05/26 @ 4:49 PM

TransAlta Energy Marketing U.S. (TEMUS) appreciates the opportunity to submit comments on the California Air Resources Board's (CARB) Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation as proposed on D...↓

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Comment From: California Public Employees' R... (Marcie Frost)

2/05/26 @ 2:38 PM

See attached

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Comment From: Jacqueline Moore (Jacqueline Moore)

2/05/26 @ 10:51 AM

On behalf of the members of the Pacific Merchant Shipping Association (PMSA), we submit the attached comments in response to the request for public feedback on California Air Resources Board's (CARB) proposed California Corporate Greenhouse Gas Repor...↓

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Comment From: Neste (Oscar Garcia)

2/03/26 @ 4:00 PM

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Comment From: American Waterways Operators (Lillie Wightman)

2/03/26 @ 12:05 PM

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Comment From: Vincent Caboara

2/01/26 @ 4:01 PM

ADDENDUM: Formal Legal Entity Clarification for ACS

Please note that previous submissions under the name 'ACS' refer to the legal entity Arboreum Commercial Solutions, LLC. All technical feasibility data remains as filed on 12/17/25.

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Comment From: Vincent Caboara

2/01/26 @ 2:48 PM

This comment is submitted to provide evidence of a viable technical solution for Scope 3 compliance within the pulp, paper, and energy sectors. Arboreum Commercial Solutions (ACS) has established a standard for replacing virgin timber feedstock with ...↓

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Comment From: David Hagen

1/31/26 @ 8:17 AM

Prof. Demetris Koutsoyiannis has quantified how the Temperature Hen PRECEDES the CO2 Egg in numerous scientific publications posted at most of his 79 publications with the ITIA group at the National Technical University of Athens as posted at
https:...↓

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Comment From: California Fuels and Convenien... (Alessandra Magnasco)

1/28/26 @ 3:03 PM

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Comment From: Sempra (Allison Snell)

1/27/26 @ 2:16 PM

Comments of Sempra on proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation

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Comment From: Thomas Maletta

1/12/26 @ 9:43 AM

I am writing to provide feedback on the proposed regulations for Senate Bills 253 and 261 within the Code of Regulations, Title 17. Specifically, I wish to address a significant omission in Section 96201, which currently excludes business entities su...↓bject to regulation by the Department of Insurance or those engaged in the business of insurance in other jurisdictions.
Excluding the insurance industry—a primary facilitator of economic activity and a significant stakeholder in climate risk management—undermines the efficacy of these disclosures. While the California Department of Insurance may pursue similar requirements, relying on disparate state-level regulators risks creating a fragmented reporting landscape. For companies headquartered outside of California, a lack of standardized mandates at the state level may lead to inconsistent data, hampering the ability of stakeholders to assess climate risk accurately. Removing this exclusion is essential to align the insurance industry with global reporting standards, provide investors with decision-useful data, and foster a robust internal control and reporting environment.
SB 253 and 261 represent a landmark shift in U.S. business reporting, bringing domestic climate-related disclosures into alignment with international frameworks. The mandate for Scope 1, 2, and 3 emissions is critical for ensuring comparability across industries and borders. The specific exclusion of insurance entities creates a significant data gap in a sector that is deeply integrated into the broader financial system. Leaving oversight to individual state insurance commissioners will inevitably result in a "patchwork" of requirements, rendering cross-jurisdictional comparability nearly impossible. In the absence of final SEC climate rules, it is imperative that California demonstrates leadership by ensuring these requirements apply broadly across all high-impact industries.
Standardized disclosures improve market efficiency by allowing for more competitive and informed capital allocation. In the insurance sector, where products are often highly commoditized, climate disclosures provide a vital point of differentiation for investors. These metrics offer insight into a carrier's underwriting philosophy, investment strategies, and long-term risk management. Inclusion in these rules will provide the transparency necessary for investors to understand the full scope of a company's operational and financed emissions.
The implementation of these regulations will necessitate rigorous improvements in corporate governance and internal controls. Establishing a clear chain of command for climate data—information that has historically been siloed or unmonitored—requires direct engagement from boards and executive leadership. This integration will modernize reporting systems and foster a culture of accountability. While the transition to tracking new data sets may be complex, the resulting evolution in control frameworks will ensure that insurance companies remain resilient in an era of rapid technological and environmental change.
While calculating Scope 3 emissions for financial institutions is complex, established methodologies already exist to facilitate this transition. The Partnership for Carbon Accounting Financials provides robust guidelines tailored specifically to the insurance industry that align with the GHG Protocol. These guidelines offer clear boundaries for measuring emissions across diverse portfolios, from commercial lines to personal auto and investment holdings. By leveraging these existing standards, insurance carriers can provide clear, comparable, and reliable disclosures that meet the expectations of the global market.
The inclusion of insurance companies in the final regulations is vital to the integrity of California's disclosure framework. Insurance companies hold a unique and critical position in the global effort to mitigate climate change. As the primary backer of property and casualty risks, particularly in disaster-prone regions like California, carriers are on the front lines of observing the increasing frequency and severity of natural disasters. However, their responsibility extends beyond mere measurement; it requires active stewardship of their own carbon footprints and, more importantly, their massive investment portfolios. By prioritizing Environmental, Social, and Governance principles alongside financial returns, insurance companies can leverage their capital to foster a sustainable future, ensuring that the world they protect remains insurable for generations to come. By removing the current exclusion, CARB will enhance investor confidence, promote industry-wide consistency, and ensure that the insurance sector remains a resilient and transparent participant in the transition to a low-carbon economy.

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Comment From: Republic Services (Tony Fritz)

1/06/26 @ 4:12 PM

Pages 5 & 6 of the regulatory text outline the payment and collection processes, stating that the Executive Officer will provide written fee determination notice on or by September 10th each year, that payment is due within 60 days, and that late pay...↓

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Comment From: William Mancilla

12/26/25 @ 8:38 AM

Make government entities also have to report but make it less restrictive for them. Every organization should be held accountable for the environmental harm they pose to communities. If an organization does not want to change the way they handle thei...↓

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