Proposed environmental and climate-related requirements for federal contractors – what general counsel need to know

Late last year, the Federal Acquisition Regulatory (FAR) Council published a proposed rule that seeks to place significant environmental and climate-change related requirements on contractors that annually receive more than $7.5 million in federal contract obligations.

The proposed rule would impose costly requirements on contractors. It appears to be just the first step in federal efforts to incorporate environmental and climate-change considerations into the federal procurement process.

Writing for PubK, our lawyers Jeff Salinger, Gwen Keyes Fleming and Tom Daley provide an overview of the FAR Council’s proposed rule, the greenhouse gas inventories that certain contractors will need to perform, the projected timeline for implementation, and the penalties for noncompliance. In addition, they look at the federal government’s broader efforts to increase environmental and climate-change related requirements on federal contractors and identify steps that contractors should consider in anticipation of these changes.

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