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On January 13, APGA submitted a brief comment letter in response to a notice requesting feedback on how the federal government can minimize the risk of climate change in its acquisitions. Through the letter, APGA noted concerns with the proposed use of the social cost of greenhouse gases (SC-GHG) in federal purchasing decisions.

The notice, which was issued jointly by the U.S. Department of Defense, General Services Administration, and National Aeronautics and Space Administration, indicated that the federal government must lead by example and manage climate-related financial risk within its own procurement activity. The SC-GHG, which include the social cost of carbon, methane, and nitrous oxide, are monetary cost estimates associated with the release of a ton of each gas. APGA’s comments explain that the estimates were developed for regulatory impact analyses, and due to their imprecise nature, should not be used outside of their intended scope. The comment letter also brought to DOE’s attention several outstanding concerns with the interim SC-GHG values currently available by citing to a coalition comment letter APGA joined in 2021 that outlines the various issues.

A copy of the comment letter is available here.

For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.