Upcoming Toolkit and Regulatory Updates from CARB
TOOLKIT INCOMING: EPA Endangerment Finding Comment Letters
The EPA comment period for its proposed rule on rescinding the 2009 Endangerment Finding ends on September 22, 2025.
Letters from investors are highly regarded and important in the rulemaking process. US SIF is in the process of creating a toolkit for our members that will give some background on the rulemaking and offer framing and talking points to help investors construct their own individual letters to the EPA.
US SIF aims to distribute the member toolkit by September 5. US SIF will also be submitting our own institutional comment.
Please reach out if you have any questions or would like to discuss the rulemaking in more detail.
CARB Update from Public Workshop
The California Air Resources Board (CARB) hosted its second public workshop last week, providing updates and seeking feedback on its guidance on the implementation of CA’s climate disclosure laws.
Key takeaways from the workshop:
Who qualifies: CARB proposed a second option to define “revenue,” following stakeholder feedback that the tax code definition which calculated revenue by “gross receipts” was too broad and cumbersome. CARB approximates that 4,160 companies will qualify for SB 261 and 2,596 companies for SB 253. CARB will release a list of expected qualifying companies in the coming weeks.
Exemptions: CARB denoted exempt categories for qualifying reporting entities: non-profits, companies who only business in CA was the presence of teleworking employees, government entities, and CA Independent System Operator (CAISO) or business entities who only engaged in wholesale electricity transactions. CARB is currently evaluating how to deal with utilities.
Fee structure: CARB also announced its plan for the annual fee that will cover administrative and implementation costs for the new laws. CARB proposes a flat fee structure that will apply to all subsidiaries that qualify. CARB estimates fees to be $3,106 for SB 253 and $1,403 for SB 261.
Expected rulemaking: CARB expects to release a proposed rulemaking by October 14 and is currently accepting public comment on its fee structure proposition until September 11.
View the slides from the workshop here. Read more about the process here.