THE EPA’S GROWING ROLE IN FEDERAL CONTRACTING

Greenhouse Gas (GHG) emissions tracking and remediation is, apparently, just the start in terms of how the Environmental Protection Agency (EPA) plans to make doing business with the federal government more expensive.  The agency has either already rolled out, or plans to roll out, such items as a federal contractor climate score card, rules requiring companies to disclose potential climate-related financial risks and promoting sustainable practices, and efforts to increase oversight on how everything from solar panels to IT equipment is manufactured to reduce a company’s carbon footprint.  There’s even a Sustainability Working Group that is now part of the federal CIO Council.  While contractors like clean air and water as much as the next person, they must ask the question “Who’s going to pay for all of this?”  The answer is likely to be that industry will foot much of the bill.  Contractors should keep a careful eye on both direct and indirect costs associated with climate change rules and plan their pricing accordingly.  Direct expenses may be easier to evaluate, but no one should discount the market pressure exerted on a company with less than “straight A’s” on the climate report card, either.  Also, judging by recent EPA official comments, it seems like no cost is too great to ensure that federal agencies do business with contractors that are compliant with the full range of green mandates.  Where’s a contractor to begin?  EPA officials recommend looking at something called the Green Procurement Compilation, which would have been a great name for a late ‘60’s rock group, but is, in fact, “a comprehensive green purchasing resource designed for federal contracting personnel and program managers.”  Industry-focused information is also available on the site that can be found here:  https://sftool.gov/greenprocurement.  Government contractors must be aware of all of the factors that impact their approach to federal business.  This increasingly includes tracking and complying with a host of environmental rules.  Plan accordingly.