Organizations Involved: Institute for Policy Integrity
Source: Institute for Policy Integrity
Abstract
In October 2023, California enacted two laws (SB 253 and SB 261) that require large, U.S.-based companies doing business in California to disclose their climate-related financial risks and greenhouse gas emissions. The California Air Resources Board (CARB) published an information solicitation in December 2024 to inform its implementation of those laws. In response to CARB’s information solicitation, Policy Integrity offered the following recommendations: (1) In considering costs, CARB should set a baseline that includes existing disclosure practices and should consider only the incremental costs of its regulations; and (2) CARB should examine the cost-estimation resources provided to the SEC during its rulemaking process on its proposed climate disclosures, as well as the SEC’s final cost estimates for that rulemaking, but it should ensure that its own estimates reflect current baseline disclosure practices.
