Regulatory Submissions

In February, APGA provided comments on proposed amendments to the Federal Acquisition Regulation (FAR) pertaining to Greenhouse Gas Emissions and Climate-Related Financial Risk Disclosures. This proposal was issued by the Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA).  

APGA members could potentially be directly affected by the proposed amendments, which would require select federal contractors to report climate-related financial risk and greenhouse gas emissions annually, as well as set targets to reduce emissions. The proposed amendment relies heavily on private entities, such as the CDP (formerly Carbon Disclosure Project) and Science Based Targets Initiative (SBTI), to set procurement standards. In the feedback submitted, APGA urged DOD, GSA, and NASA to avoid delegation of such impactful responsibilities to private entities, without appropriate checks and balances.  

APGA also asked DOD, GSA, and NASA to significantly modify the proposal with the following considerations in mind or abandon the proposal entirely. First, high reporting burdens would be a pass-through cost, negatively impacting American families and business-owners who utilize community-owned natural gas utilities. Second, America’s public gas utilities can help meet the need for military readiness and national security because they operate safe and secure pipeline systems. DOD, GSA, and NASA should embrace the resiliency and reliability inherent in the systems public gas utilities operate, not limit the use to achieve a poorly developed emissions disclosure requirement. Third, APGA requests the agencies recognize that all facilities, not just some, should have access to resilient and reliable natural gas.