Comment on the FAR greenhouse gas disclosure rule — with SBAGC
FILED 2023-02-13 · DOCKET FAR-2021-0015 · PUBLIC COMMENT
In late 2022 the FAR Council proposed requiring major federal suppliers to disclose greenhouse gas emissions and climate-related financial risk, implementing Executive Order 14030. The American Small Business Chamber of Commerce™ commented on the proposed rule jointly with the Small Business Alliance of Government Contractors — the joint supplier council of ASBCC and the U.S. Women's Chamber of Commerce — posted to the docket on 14 February 2023.
This is ASBCC's earliest comment on the federal record: the beginning of the filing history that now spans three proceedings.
What the comment said
The comment addressed the rule as it bears on small federal contractors, on both sides of the ledger.
On the rule's design: contractors below $7.5 million in annual contract obligations are exempt entirely, and a further exception excludes small businesses under their primary NAICS code from the most demanding reporting requirements — protections the comment identified as meaningful for the smallest firms, while noting that reporting obligations below that threshold would impose an undue burden.
On the underlying risk, the comment was direct: the greater risk to small business would be ignoring the threat of climate-related financial risk, citing evidence that operational impacts were already reaching a substantial share of businesses.
What we asked for
- Target the criteria — focus reporting requirements on the industries producing the bulk of emissions, rather than sweeping in small contractors whose data adds burden without accountability.
- Fund education — small businesses need to understand new requirements, and the resources to learn them should come with the rule.
- Provide lead time — time to prepare before compliance begins.
- Offset the cost — financial incentives and assistance for the small businesses that need them.
The record
Received 13 February 2023, Docket FAR-2021-0015 — the proposed rule at FR Doc. 2022-27884 — and posted 14 February 2023 as comment FAR-2021-0015-0164 · tracking le3-06mo-z474. Signed by Margot Dorfman, President. The filed record copy is attached on the docket under its regulations.gov document name.