Investigations, Enforcement, & Compliance Alerts

On September 21, 2023, President Biden directed federal agencies to consider contractors’ greenhouse gas emissions when making procurement decisions. This announcement, along with Executive Order 14030, which directs the Federal Acquisition Regulatory Council (FAR Council) to promulgate rules instructing agencies to consider the environmental impact of their contracts, demonstrates a continued interest by the Biden administration to use government procurement as a vehicle for reducing greenhouse emissions. The administration plans to incentivize government contractors to lower their environmental impact by requiring “significant” and “major” Federal suppliers to publicly disclose their greenhouse gas emissions by (1) mandating that the largest contractors commit to meeting science-based emission reduction goals and (2) creating rules requiring agencies to consider the environmental impact of contractors in the bid process.