When Carbon Accounting Becomes Law: SB 253, Material Disclosure & Heavy-Duty Scope 3 | Chris Perzan

When does SB 253 compliance cross into materially misleading disclosure? Chris Perzan, founder of Kyndenos LLC and former Vice President of Environment and Sustainability and Chief Environmental Counsel at Navistar (now International Motors), spent 16 years holding both the legal and the sustainability seat at a heavy-duty vehicle manufacturer. In this episode, he joins Aaron Stainthorp to unpack what changes when carbon accounting moves from voluntary practice to mandatory law. Topics covered: • Running environmental counsel and sustainability under one title, and what that dual role teaches that neither role alone does • Leading decarbonization at a heavy-duty vehicle manufacturer, from EPA greenhouse gas rules to electrification's infrastructure constraints • Why the SEC's 2010 climate risk disclosure guidance is still in effect, even as the agency rolls back its scope 1 and 2 disclosure rules • Chris's comment to CARB on SB 253's scope 3 rulemaking, and the risk that pre-approved spend-based databases disincentivize more accurate product-level accounting • The tradeoff regulators face between flexible rules and enforceable ones, and why litigation over SB 253 is all but certain • CARB's scope 3 category phase-in, and why heavy-duty manufacturers' Category 11 (use of sold products) is the one category left off the mandatory list • When SB 253 compliance becomes materially misleading disclosure, and how companies should evaluate that risk • Why Chris left in-house sustainability leadership to build a law practice instead of a consulting practice Learn more about Chris Perzan and Kyndenos LLC: https://www.kyndenos.com Sponsored by North Star Carbon & Impact, the carbon and sustainability management platform built by sustainability professionals for sustainability professionals. Learn more or request a demo at https://www.northstarcarbon.com.