DHC is pleased to provide comments in CARB's invitation. The attached file addresses each item. The most critical comments:

Specify GHG Protocol for all parameters where applicable; ISSB S-2 where GHG Protocol does not address the topic.

Use CDP as the disclosure portal, and NOT a separate submittal to CARB. Provide guidance annually on what fields of the CDP questionnaire fulfill the Calif. disclosure requirements.

Do not specify what type of firm should perform assurance. Allow technical firms to conduct assurance. The assurance providers should indicate what standards they used in their report.

Change the reporting deadline to reflect the reality of obtaining data, resource limitations at regulated and otherwise affected entities (e.g., business partners), and convention established by other laws (Dodd-Frank Conflict Minerals) and disclosure portals (CDP).

Respectfully submitted, Douglas Hileman, FSA, CRMA, CPEA

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Douglas Hileman guest speaker at Loyola Marymount University graduate Finance class.  Introduction to Sustainability reporting standards and frameworks.  Great launch pad for the newbie, or reminder for the pro.
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Doug presents at the 2025 West District conference of the Institute of Internal Auditors (www.theiia.org).  Some think the pendulum has swung back on Sustainability/ ESG.  If there’s no SEC Climate Disclosure Rule, does everything “climate” go away? Do privacy concerns evaporate?  Must customers be blocked from information they need for their decisions? Doug challenges Internal Auditors to apply core competencies:  objectivity; risk; opportunity to tailor efforts and add value to their organizations.   
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