CRS Comments on the Climate Corporate Data Accountability Act (SB253) Scope 1 and Scope 2 Emissions Draft Reporting Template

CRS recommends several improvements to California’s SB 253 Draft Reporting Template for greenhouse gas emissions in the submitted comments. The comments call for clearer definitions and structure, including explicit totals for both market-based and location-based Scope 2 emissions, as well as a dedicated row for electricity totals within Scope 2. Clarification is requested regarding the “emission reduction” fields and inclusion of all relevant procurement types—not just direct contracts—to align with best practices. CRS’s recommendations strongly support the use of market-based accounting across all emissions scopes, not just Scope 2, and continues to support CARB’s requirement for third-party verification for emissions reporting. Additionally, CRS recommends that hourly reporting for Scope 2 emissions should only become mandatory once all U.S. renewable energy tracking systems can reliably support hourly tracking.