DOD seeks comment on new climate change proposal aimed at contractors

By Tony Bertuca  / October 15, 2021

The Defense Department is seeking public comment on a proposed acquisition regulation that would require major federal suppliers to publicly disclose greenhouse gas emissions and “climate-related financial risk,” while also mandating “science-based reduction targets.”

“The Federal Acquisition Regulatory Council is considering amending the Federal Acquisition Regulation (FAR) to ensure that major Federal agency procurements minimize the risk of climate change,” according to a Federal Register notice announcing that public comment will be sought until Dec. 14.

The proposed regulation comes from an executive order President Biden signed earlier this year requiring “consideration of a FAR amendment to require major federal suppliers to publicly disclose greenhouse gas emissions and climate-related financial risk and to set science-based reduction targets,” the notice states.

Respondents are being encouraged to provide feedback on questions like: “How can greenhouse gas emissions, including the social cost of greenhouse gases, best be qualitatively and quantitatively considered in federal procurement decisions, both domestic and overseas?” and “how can procurement and program officials of major Federal agency procurements better incorporate and mitigate climate-related financial risk?”

Meanwhile, DOD has released a new Climate Change Adaptation Plan poised to have significant impacts on the defense budget and acquisition process.

“This plan will help the Department of Defense integrate climate considerations into our operations, our planning, and our business and decision-making processes,” Defense Secretary Lloyd Austin said in an Oct. 7 statement.

The plan states DOD will use its position as the “single largest buyer of goods and services” to drive transparency within and across its supply chain; expecting major suppliers to fully disclose” greenhouse gas emissions and environmental performance.

Richard Kidd, the deputy assistant secretary of defense for environment and energy resilience, said last week DOD intends to leverage its “procurement power” to address climate change.

“No entity can opt out of the effects of climate change -- climate change is going to be the context of the world that we live in from now on,” he said.

Some DOD contractors, Kidd said, are “leaders” when it comes to disclosing and reducing greenhouse gas emissions, with “very aggressive” reduction goals.

“Other contractors are not quite there yet,” he said. “Our goal is to bring all the contractors up to what is best practice.”