On Feb. 13, ABC submitted comments to the Federal Acquisition Regulatory Council regarding a proposed rule to amend the Federal Acquisition Regulation to require certain federal contractors to disclose their greenhouse gas emissions and set GHG emissions reduction targets. ABC’s comments opposed the proposal’s overly burdensome, costly and punitive approach to regulating GHG emissions of federal contractors. While ABC understands the need for sensible environmental policies that balance the protection of the environment with the costs that compliance with these regulations requires, the comments outline how the proposed rule fails to strike that balance. ABC also joined industry stakeholders in a coalition letter expressing similar concerns regarding the proposed rule. The law firm DLA Piper has provided a summary of all 259 publicly posted comments on the proposed rule. Under the proposed rule, federal contractors who qualify as significant contractors (those receiving between $7.5 million and $50 million in federal contracting obligations in the prior fiscal year) would be required to inventory their annual GHG emissions and disclose this information to the federal government. Major contractors (receiving over $50 million in contracting obligations) would also be required to make publicly available CDP climate disclosures and set targets for reducing GHG emissions. Contractors that fail to comply with these requirements would be deemed nonresponsible and ineligible for federal awards.