California Air Resources Board to Hold Another Public Workshop – Third Time’s the Charm?

Yesterday afternoon, the California Air Resources Board announced that it will be holding another virtual public workshop on its greenhouse gas emissions (SB 253) and climate risk reporting (SB 261) mandates. This will be the third workshop this year. In this post, we discuss what companies need to know about the workshop.

When

The workshop will be on Tuesday, November 18. It will be held from 9:30 am to 12:30 pm, Pacific Time. At the last two workshops, CARB presented for roughly the first hour, with the rest of the time allocated to attendee questions and comments.

Where/How

The workshop will be virtual. The registration page is here.

What

The workshop announcement indicates the following agenda:

• CARB staff will provide an update on the development of the programs under SB 253 and SB 261.

• The discussion will include the preliminary list of covered/reporting entities published on September 24 and efforts to refine this list to inform development of the initial regulation. The preliminary list is further discussed in this Ropes & Gray post.

• CARB staff will present proposed updates to definitions and exemptions. See this Ropes & Gray post for a discussion of the definitions and exemptions discussed at the last workshop in August.

• The staff will discuss the scope of the initial regulation, which is limited to establishing the fee component and associated definitions (such as revenues and doing business in California), and the first reporting deadline for SB 253. 

• Staff also will take verbal feedback during the workshop. 

Supporting Materials

Workshop materials will be posted on November 17, the day before the workshop.

SB 261 Compliance Deadline Reiterated

The workshop announcement notes that CARB’s initial rulemaking does not affect the January 1, 2026 reporting deadline under SB 261. The announcement stresses that, because this deadline is established by statute, it can only be changed by legislation.

Additional Resources for Compliance

Additional Ropes & Gray resources for compliance with SB 253 and SB 261 are available through the links below:

• California Air Resources Board Publishes List of Companies That May Have Climate Reporting Obligations
• California Air Resources Board Publishes Draft SB 261 Guidance
• California Air Resources Board Addresses the Who, What, How and When of California’s Corporate Climate Disclosure Laws at August 21 Workshop
• Five Takeaways from CARB’s July 9 FAQs on California’s New Corporate Climate Disclosure Requirements
• California Issues Important Enforcement Guidance for its New GHG Emissions Disclosure Requirements – Provides Additional Compliance Flexibility

About our Practice 

Ropes & Gray has a leading ESG, CSR and business and human rights compliance practice. We offer clients a comprehensive approach in these subject areas through a global team with members in the United States, Europe and Asia. Senior members of the practice have advised on these matters for more than 30 years, enabling us to provide a long-term perspective and depth and breadth of experience that few firms can match. 

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