Emissions & resilience reporting for federal contractors

Paula - thanks for posting about this. Are we aware of how they're classifying ‘major’ vs ‘significant’ contractors?
Referencing table here as contractors receiving more than $7.5m are also required to report (scope 1 & 2 emissions): Federal Supplier Climate Risks and Resilience Proposed Rule | Office of the Federal Chief Sustainability Officer

...This is a big deal. Mostly for construction companies. (And defense contractors.) A single project with the General Services Administration - which most know is not bound by geography - would likely push many contractors into the $7.5M threshold and require them to track and disclose Scope 1 and 2. Tracking Scope 1 and 2 is not hard, but it would have to be done following the CDP, not just scribbled on a napkin after sticking a thumb in the air. One or two large projects in any given year could also put any contractor into the $50M threshold where things get really interesting. Then you have to track Scope 3, and have (*verified*) science-based reductions for your company, and have all this publicly disclosed. My company Consigli was just awarded a project at the Lincoln Memorial in excess of $50M, which shows that a single project could immediately push a company into needing to track, disclose, and set verified emissions reductions. A nuance here is that project is with the National Park Service, and this Federal Acquisition Rule is currently written on behalf of D.o.D., GSA, and NASA, so I think we would be exempt for the moment. But, you can see what's looming. Some of this may be happening anyway depending on how the proposed SEC rules end up getting implemented and what pressures may be put on construction companies to help others define their scope 3 emissions, but if this proposed rule change gets adopted, will the construction industry end up having the largest collection of private companies that track and disclose carbon emissions? That's hard to imagine, but anything is possible. Interestingly, companies who are signatories to the Contractor's Commitment will already be ahead of the curve, as the C.C. already requires tracking of emissions. (Another good reason to help promote the C.C. to the contractors you work with if you needed one.) This is still a proposed rule change. Public comments are open until January 13th : https://www.federalregister.gov/documents/2022/11/14/2022-24569/federal-acquisition-regulation-disclosure-of-greenhouse-gas-emissions-and-climate-related-financial Steven Burke. LEED & WELL Faculty Director Of Sustainability m: 774.462.2044 consigli.com

I've attempted to read through some of this language but I remain confused about how the accounting works for the federal contracts thresholds. Is it gross fee or our firm's net fee? Does the whole fee count for the fiscal year in which it was awarded, or does the fee get divided up over the years it is paid out (most of our federal projects last for several years or more). Can anyone point me to where they clarify how the "annual federal obligation" amount (from the table Marisa linked above) is defined? Thank you!

I think it is refering to the contracted amount in the year that it was contracted, not the amount spread over the project life. At least that is how I interpret the language.

I agree this will be a very big deal if it is implemented with the current major components in place. As an employee-owned company, this may be the first regulation that would force us to comply since the SEC rules would not apply directly to a non-publicly traded company. However, the SEC rule would also impact us since our clients would be reaching down to us for data as a supplier.