Biden-Harris Administration Proposes Plan to Protect Federal Supply Chain from Climate-Related Risks
The United States administration has issued a proposed rule “to improve efficiency and reduce financial risks from climate change”. Part of this initiative is to do with protecting the federal supply chain from climate-related risks.
Introduction to the Proposed Rule
The proposed rule1 starts as follows,
Today, the Biden-Harris Administration is taking historic action to address greenhouse gas emissions and protect the Federal Government’s supply chains from climate-related financial risks. In support of President Biden’s Executive Orders on Climate-Related Financial Risk and Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, the Administration is proposing the Federal Supplier Climate Risks and Resilience Rule, which would require major Federal contractors to publicly disclose their greenhouse gas emissions and climate-related financial risks and set science-based emissions reduction targets.
President Biden is highlighting this proposed action at the 27th Conference of the Parties to the U.N. Framework Convention on Climate Change (COP27) in Sharm El Sheikh, Egypt. Through this action, the United States would become the first national government to strengthen its supply chain by requiring major suppliers to set Paris Agreement-aligned emissions reduction goals.
As the world’s single largest buyer of goods and services—purchasing over $630 billion in the last fiscal year alone—the Federal Government faces significant financial risks from climate change. Supply chain disruptions over the past year have impacted every sector, including the Federal Government and its critical contractors and subcontractors. The new Federal Supplier Climate Risks and Resilience Rule would strengthen the resilience of vulnerable Federal supply chains, resulting in greater efficiencies and reduced climate risk.
The proposal references the Federal Sustainability Plan2 which,
. . . sets out a range of ambitious goals to deliver an emissions reduction pathway consistent with President Biden's goal of reducing U.S. greenhouse gas emission by 50–52 percent from 2005 levels by 2030 and limiting global warming to 1.5 degrees Celsius, as the science demands.
The goals of the sustainability plan are summarized in this sketch.
Public Comment Period
The 60-day public comment period for this proposed rule is scheduled to close on January 13th, 2023 (FAC/FAR Case/Docket No. 2021-015)3.
I submitted the following comment,
Given the urgency of this proposal, it is suggested that Scope 3 emissions be omitted from required reporting. As the Environmental Protection Agency has said, “Scope 3 emissions are someone else’s Scope 1 and Scope 2 emissions”. Focusing on Scopes 1 and 2 would materially reduce the amount of analysis and reporting required.
https://www.whitehouse.gov/briefing-room/statements-releases/2022/11/10/fact-sheet-biden-harris-administration-proposes-plan-to-protect-federal-supply-chain-from-climate-related-risks/
https://www.sustainability.gov/federalsustainabilityplan/index.html
https://www.federalregister.gov/documents/2022/11/14/2022-24569/federal-acquisition-regulation-disclosure-of-greenhouse-gas-emissions-and-climate-related-financial