BPI and Others Respond to California Corporate Greenhouse Gas Reporting Program March Workshop

Dear Chair Sanchez:

The undersigned organizations write regarding the California Air Resources Board's ("CARB") request for feedback on topics raised during its March 23, 2026, public workshop (the "March Workshop") concerning the development of regulations to implement Senate Bill 253 (as amended and codified in Health & Safety Code § 38532, "SB 253").

On April 3, 2026, the Society for Corporate Governance (the "Society"), joined by the Bank Policy Institute ("BPI"), submitted a letter to CARB expressing concern regarding the April 13 deadline for public comments on the March Workshop and requesting confirmation that CARB will meaningfully consider substantive input submitted after the deadline if it is not significantly extended. We support and join that request and submit this letter to reflect the shared views of the undersigned organizations. A copy of that letter is attached for reference.

The undersigned organizations represent a broad cross-section of companies and stakeholders that are actively engaged in greenhouse gas accounting, disclosure, and assurance practices, including entities with demonstrated leadership in emissions accounting and public disclosure.^[1] Across our respective memberships, there is a shared view that CARB's three-week comment period does not provide sufficient time to gather and prepare robust input on the important, complex, and highly technical topics presented at the March Workshop.

As reflected in the Society and BPI letter, the issues raised-including Scope 1, Scope 2, and Scope 3 reporting approaches, accounting methodologies, assurance frameworks, and cost considerations-are not only complex but also central to CARB's ability to implement SB 253 in a manner that is interoperable and not unnecessarily burdensome, consistent with statutory requirements.

Accordingly, for reasons including the above and those set forth in the Society and BPI letter, we respectfully request CARB's express written confirmation that it will review and meaningfully consider stakeholder input submitted on or before June 1, prior to initiating the formal rulemaking process referenced during the March Workshop.

We note that CARB updated its website on April 6 to state that "informal comments will be received until June 1." However, it is unclear what is meant by "informal comments," whether and how such comments will be considered, or whether they will be incorporated into the rulemaking process. In the absence of clear confirmation, stakeholders remain concerned that input submitted after April 13 may not be fully considered prior to the initiation of formal rulemaking.

We appreciate CARB's ongoing engagement with stakeholders and would welcome the opportunity to further discuss these issues.

Respectfully submitted,

Society for Corporate Governance
Bank Policy Institute
California Bankers Association
California Retailers Association
California Water Association
Securities Industry and Financial Markets Association

[1] "In developing the regulations required pursuant to [SB 253], [CARB] shall consult with […] [r]eporting entities that have demonstrated leadership in full-scope greenhouse gas emissions accounting and public disclosure and greenhouse gas emissions reductions." See CA Health & Safety Code § 38532(c)(5).