We need companies to reveal their growing risks from climate change.

As a concerned consumer and investor, I am writing to encourage the California Air Resources Board (CARB) to require transparency from large companies regarding their Scopes 1, 2, and 3 greenhouse gas emissions.   

CARB’s implementation must ensure that the Greenhouse Gas (GHG) emissions data and climate risk information reported by companies is easily accessible and allows the public to develop knowledge and insights that can empower them as consumers, investors, and market actors.  

Please ensure that all companies subject to the regulations engage in: 

• Mandatory reporting of all climate emissions in a standardized format.  This is important to all parties and will help prevent greenwashing. Reporting of Scope 3 emissions from companies’ supply chains must be included, since this is the source of 90 percent of emissions for many companies. 

• Reporting through the GHG Protocol, which is in use by 97% of disclosing S&P 500 companies and is widely recognized as the gold standard for GHG emission reporting. 

• Report financial-related disclosures through the International Sustainability Standards Board (ISSB) framework, which is used by 1,000 companies and 30 jurisdictions. 

Thank you again for the opportunity to comment on the implementation of California’s landmark climate disclosure legislation.