As noted in our COP27 recap, this year's climate summit in Sharm el-Sheik involved both the historic creation of a fund to compensate countries most impacted by climate change, as well as lost opportunities to adopt more ambitious and accelerated climate mitigation commitments. Perhaps hidden between these headlines, President Biden announced an initiative with significant implications for federal contractors.Under this proposal, the United States would become the first country to require major government suppliers and contractors to set science-based emissions reduction targets aligned with the Paris Agreement. It would also require contractors to disclose their greenhouse gas (GHG) emissions and climate risks.
This initiative—the proposed Federal Supplier Climate Risks and Resilience Rule—would have wide-reaching impacts if ultimately finalized. Collectively, the proposed rule would cover about 86 percent of the federal government's supply chain GHG impacts and 86 percent of federal annual spending. To put this in perspective, in the last fiscal year alone the United States purchased $630 billion in goods and services.
The comment period for the proposed Federal Supplier Climate Risks and Resilience Rule closes on January 13, 2023.大型承包商的拟议守法要求自发布最后规则两年后启动,如果发布,可按拜顿政府为联邦承包商规定的COVID-19疫苗任务向法庭质疑该规则
spanid表示'More-8294'/span>gsa.gov/policy-structions/federal-cap-control-far#:~text=%20Federal%20Actition%20最大联邦提供商-即接受5千万美元以上年度合同的majectors-a和(3)设置科学排减目标The first and second requirements would be fulfilled through an annual climate disclosure report. Contractors receiving between $7.5 million and $50 million in annual contracts would only be required to report Scope 1 and Scope 2 emissions, and all other federal contractors would be exempt from disclosures. The proposed rule does not discuss what enforcement mechanisms—if any—could be deployed against a contractor that fails to meet its emissions reduction target.Certain entities would be exempt from the proposal irrespective of the size of their annual contracts. For instance, tribally owned entities, higher education institutions, nonprofit research entities, state and local governments, and certain management and operating contracts figure to be exempt from the proposed emissions disclosures and science-based target requirements. Additionally, if a major contractor is considered a "small business" according to the North American Industry Classification System (NAICS) code in its System for Award Management (SAM) registration, or if it is a nonprofit organization, then it would not be required to complete an annual climate disclosure or to set science-based targets.
拟议规则将利用现有第三方标准和系统,包括与气候有关的财务披露建议工作队、CDP报告系统(原碳披露项目)和科学目标倡议标准下图概述(1)温室气体清单需求2) 年度气候披露报告和 3 基于科学目标需求.
清单将在连续12个月期间编目排放,结束时间不超过清单编全前12个月实体可使用环境保护局简化排量 万博体育app手机登录信息披露必须同TCFD建议保持一致,除范围1和2外,还必须包括CLE3排放清单。报告还必须描述实体的气候风险评估过程和通过该过程识别的任何风险。建议规则目前设想承包商通过完成CDP
As noted above, major contractors would be required to develop science-based targets. The Federal Register notice for the proposed rule defines a science-based target as "a target for reducing GHG emissions that is in line with reductions that the latest climate science deems necessary to meet the goals of the Paris Agreement to limit global warming to well below 2 °C above pre-industrial levels and pursue efforts to limit warming to 1.5 °C." According to the proposed rule, these targets must be validated by SBTi and be made publicly available. Though only applying to major contractors, it is estimated that these targets would address 64 percent of federal government spending and approximately 69 percent of supply chain GHG impacts.
II.Related Federal Sustainability Initiatives
The proposed rule fits within two larger Biden Administration initiatives. The first is the President's Federal Sustainability Plan, which we previously summarized in another blog entry. That plan sets a number of goals, including: 100% carbon-free electricity by 2030, and net-zero emissions in federal government procurements by 2050. To achieve the net-zero-emissions procurement goal, the government previously announced a "Buy Clean Task Force" to prioritize the procurement of low-carbon building materials, such as steel and concrete. The proposed Federal Supplier Climate Risks and Resilience Rule furthers net-zero procurement by requiring 85 percent of the emissions associated with the Federal supply chain to set net-zero targets and disclose their emissions.
The second initiative is a "comprehensive, government-wide strategy to measure, disclose, manage, and mitigate the systemic risks" of climate change. Within this bucket, the Biden Administration points to the Department of Labor's proposal to remove barriers to the consideration of climate risks and other environmental, social and governance factors by ERISA plan fiduciaries!证券交易委员会待定study climate-related risks to the financial system.
[1] Scope 1 emissions include GHG emissions from sources that are owned or controlled by the reporting company.
[2] Scope 2 emissions include GHG emissions associated with the generation of electricity, heating and cooling, or steam, when these are purchased or acquired for the reporting company's own consumption but occur at sources owned or controlled by another entity.
[3] Scope 3 emissions are a consequence of the operations of the reporting entity but occur at sources other than those owned or controlled by the entity.