On November 14, 2022, the U.S. Department of Defense, the General Services Administration, and the National Aeronautics and Space Administration proposed to require certain federal contractors to disclose their greenhouse gas emissions and climate-related financial risks and set science-based targets to reduce their greenhouse gas emissions. The Center for American Progress submitted a comment letter on February 13, 2023, strongly supporting the proposal and making recommendations for strengthening it.
CAP’s comments point out that climate impacts are an important concern for federal procurement, given the federal government’s policies regarding climate change, the significant potential impacts of climate change on the federal supply chain, and the federal government’s responsibility to deliver value for taxpayers’ money. Uniform rules around climate risks and emissions are also cost-efficient for government, offerors, and taxpayers.
At the same time, CAP recommends that climate-related definitions and goals in the rule be more explicitly integrated into the definitions and principles of the Federal Acquisition Regulation and that waivers proposed in the rule be scaled back or eliminated. CAP further recognizes that integrating climate risk considerations into federal procurement is a process that began before the recent proposal and should continue improving through timely periodic review of these provisions.
Click here to read CAP’s comment letter.