(15-Day) Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation

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Comment From: California Chamber of Commerce (Jonathan Kendrick)

8/11/26 @ 11:18 PM 15-1
Attached please find the California Chamber of Commerce's comments on the July 27, 2026, Notice of Public Availability of Modified Text and 15-Day Proposed Regulation Text.
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Comment From: Edgar & Associates, Inc. (Evan Edgar)

8/11/26 @ 9:13 PM 15-1
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Comment From: American Coatings Association (Annebelle Klein)

8/11/26 @ 5:02 PM 15-1
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Comment From: NRDC (Arohi Sharma)

8/11/26 @ 5:02 PM 15-1
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Comment From: California Council for Environ... (Kirstin Kolpitcke)

8/11/26 @ 3:53 PM 15-1
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Comment From: California Manufacturers & Tec... (Elizabeth Esquivel)

8/11/26 @ 3:24 PM 15-1
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Comment From: Amy Mmagu

8/11/26 @ 3:21 PM 15-1
Please see attached comments
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Comment From: Western States Petroleum Assoc... (Sophie Ellinghouse)

8/11/26 @ 3:00 PM 15-1
Please see attached.
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Comment From: Erin Potter Sullenger

8/11/26 @ 2:40 PM 15-1
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Comment From: BMW Group (Linda White)

8/11/26 @ 2:30 PM 15-1
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Comment From: California Retailers Associati... (Sarah Pollo Moo)

8/11/26 @ 2:11 PM 15-1
August 11, 2026

Lauren Sanchez
Chairwoman
California Air Resources Board
1001 I St.
Sacramento, CA 95814

Submitted electronically

RE: CRA Comments on C Modified Text and Availability of Additional Documents and/or Information for the Proposed Cali...↓
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Comment From: Public Citizen (Elyse Schupak)

8/11/26 @ 1:29 PM 15-1
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Comment From: International Emissions Tradin... (Adarsh Srinivasan)

8/11/26 @ 1:08 PM 15-1
On behalf of our 300+ member companies, IETA appreciates this opportunity to provide feedback to CARB on the (15-Day) Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation.

Our full r...↓
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Comment From: Neste (Oscar Garcia)

8/11/26 @ 8:37 AM 15-1
Neste is pleased to submit the attached comment letter. Thank you
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Comment From: American Chemistry Council (Charles Franklin)

8/10/26 @ 9:00 PM 15-1
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Comment From: American Waterways Operators (Lillie Wightman)

8/10/26 @ 10:00 AM 15-1
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Comment From: The J.M. Smucker Company (Steve Walker)

8/07/26 @ 6:59 AM 15-1
We ask CARB to consider allowing annual emissions reporting based on the calendar year even if it differs from the reporting entity's fiscal year. This would avoid a duplication of effort for entities that are already reporting their emissions on a c...↓
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Comment From: Cheryl Militello

7/29/26 @ 4:11 PM 15-1 Form Letter 1
State of California
Air Resources Board
Notice of Public Availability of Modified
Text
Proposed California Corporate Greenhouse Gas Reporting
and Climate-Related Financial Risk Disclosure Initial
Regulation
Public Hearing Date: February 26, 2026
Publ...↓
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Comment From: Kevin Walsh

7/27/26 @ 4:37 PM 15-1
We need to restrict greenhouse gas emissions.
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Comment From: Cheryl Militello

7/27/26 @ 1:39 PM 15-1 Form Letter 1
State of California
Air Resources Board
Notice of Public Availability of Modified
Text
Proposed California Corporate Greenhouse Gas Reporting
and Climate-Related Financial Risk Disclosure Initial
Regulation
Public Hearing Date: February 26, 2026
Publ...↓
No attachments

Comment From: Louise Gray

7/27/26 @ 1:20 PM 15-1
Nearly impossible to understand what you write and hopefully you are not purposefully making it complicated —- but DUE TO THE HARMFUL AIR QUALITY IN SACRAMENTO HURTING ME, EVEN MY PET, I MUST PLEAD WITH YOU!!!

I moved to SACRAMENTO 2 1/2 years ...↓
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Comment From: Green America (Cathy Becker)

2/26/26 @ 12:33 PM Day of Board Meeting
Please find our comment attached. Thank you.
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Comment From: Otto Starzmann

2/26/26 @ 10:41 AM Day of Board Meeting
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 Day of Board Meeting
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Comment From: Sandia National Laboratories (Konstantin Parkhomenko)

2/26/26 @ 9:37 AM Day of Board Meeting
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Comment From: U.S. Tire Manufacturers Associ... (Stephanie Schlea)

2/26/26 @ 9:22 AM Day of Board Meeting
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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Download
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Comment From: Leona Hwang

2/09/26 @ 11:06 PM 45-Day

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 45-Day
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: Class of '85 Regulatory Respon... (Yuyan Pu)

2/09/26 @ 9:21 PM 45-Day
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Comment From: Consumer Technology Associatio... (Katie Reilly)

2/09/26 @ 7:14 PM 45-Day
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 45-Day
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 45-Day
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Comment From: Covington & Burling LLP (Jayni Hein)

2/09/26 @ 6:10 PM 45-Day
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 45-Day
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 45-Day
Davis Wright Tremaine LLP provides the attached comments.
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Comment From: Alisa White

2/09/26 @ 5:56 PM 45-Day
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Comment From: The California Retailers Assoc... (Sarah Pollo Moo)

2/09/26 @ 5:45 PM 45-Day
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Comment From: California Chamber of Commerce (Jonathan Kendrick)

2/09/26 @ 5:42 PM 45-Day
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 45-Day
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Comment From: Nixon Peabody LLP (Alison Torbitt)

2/09/26 @ 5:32 PM 45-Day
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Comment From: Supply Chain Federation (Sarah Wiltfong)

2/09/26 @ 5:25 PM 45-Day
Please see the attachment.
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Comment From: Jeremy Weinstein

2/09/26 @ 5:24 PM 45-Day
Please see attached letter.
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Comment From: Environmental Defense Fund (Stephanie Jones)

2/09/26 @ 5:22 PM 45-Day
Please see attached.
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Download
Download

Comment From: California Water Association (Kaitlyn Johnson)

2/09/26 @ 5:10 PM 45-Day
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Comment From: Sequent Energy Management (Erin Sullenger)

2/09/26 @ 4:59 PM 45-Day
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 45-Day
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Comment From: Community Health Group (Ann Warren)

2/09/26 @ 4:52 PM 45-Day
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Comment From: Carbon Accountable (Michael Schmitz)

2/09/26 @ 4:49 PM 45-Day
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 45-Day
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Comment From: Arizona Chamber of Commerce & ... (Grace Appelbe)

2/09/26 @ 4:41 PM 45-Day
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Comment From: California Council for Environ... (Kirstin Kolpitcke)

2/09/26 @ 4:34 PM 45-Day
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Comment From: Association of Independent Cal... (Nick Romo)

2/09/26 @ 4:34 PM 45-Day
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 45-Day
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 45-Day
Please see the attached file.
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Comment From: US Sustainable Investment Foru... (Maria Lettini)

2/09/26 @ 3:14 PM 45-Day
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Comment From: Western States Petroleum Assoc... (Jodie Muller)

2/09/26 @ 3:05 PM 45-Day
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Comment From: American Iron and Steel Instit... (Tyler Hengen)

2/09/26 @ 2:51 PM 45-Day
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 45-Day
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 45-Day
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Comment From: American Forest and Paper Asso... (Julie Landry)

2/09/26 @ 1:48 PM 45-Day
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 45-Day
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Comment From: The Greenlining Institute (Monica Palmeira)

2/09/26 @ 1:42 PM 45-Day
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 45-Day
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 45-Day

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 45-Day
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Comment From: Center for Resource Solutions (Lucas Grimes)

2/09/26 @ 1:08 PM 45-Day
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Comment From: Dairy Institute of California (Katie Davey)

2/09/26 @ 1:07 PM 45-Day
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Comment From: Natural Resources Defense Coun... (Elizabeth Derbes)

2/09/26 @ 1:04 PM 45-Day
Please see attachment.
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Comment From: Adarsh Srinivasan

2/09/26 @ 1:00 PM 45-Day
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 45-Day
Please see attached comments.
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Comment From: Public Citizen, Americans for ... (Clara Vondrich)

2/09/26 @ 12:43 PM 45-Day
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Comment From: Christopher Lish

2/09/26 @ 12:36 PM 45-Day
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 45-Day
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Comment From: Ceres (Jake Rascoff)

2/09/26 @ 11:41 AM 45-Day
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 45-Day
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Comment From: Beveridge & Diamond P.C. (Eric Christensen)

2/09/26 @ 11:01 AM 45-Day
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 45-Day
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Comment From: John Bode

2/09/26 @ 10:28 AM 45-Day
Please see attached for Corn Refiners Association comments.
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Comment From: XBRL US (Campbell Pryde)

2/09/26 @ 9:55 AM 45-Day
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 45-Day
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 45-Day
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 45-Day
> 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 45-Day
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Comment From: Evergreen Renewables Inc (Michael Leggett)

2/06/26 @ 4:42 PM 45-Day
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. ...↓
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Comment From: California Bankers Association (Chris Shultz )

2/06/26 @ 4:24 PM 45-Day
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Comment From: California Bankers Association (Chris Schultz)

2/06/26 @ 4:22 PM 45-Day
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Comment From: Schneider Electric (Amy Mmagu)

2/06/26 @ 3:31 PM 45-Day
Please see attached comments
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Comment From: Bonneville Power Administratio... (Alisa Kaseweter)

2/06/26 @ 12:37 PM 45-Day
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Comment From: Society for Corporate Governan... (Randi Morrison)

2/06/26 @ 12:17 PM 45-Day
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 45-Day
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...↓
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Comment From: The Climate Registry (Amy Holm)

2/05/26 @ 6:26 PM 45-Day
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 45-Day
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Comment From: Watershed (Rob Chesnut)

2/05/26 @ 5:24 PM 45-Day
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Comment From: TransAlta Energy Marketing U.S... (Denelle Peacey)

2/05/26 @ 4:49 PM 45-Day
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 45-Day
See attached
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Comment From: Jacqueline Moore (Jacqueline Moore)

2/05/26 @ 10:51 AM 45-Day
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 45-Day
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Comment From: American Waterways Operators (Lillie Wightman)

2/03/26 @ 12:05 PM 45-Day
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Comment From: Vincent Caboara

2/01/26 @ 4:01 PM 45-Day
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 45-Day
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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