EPRI Public Comments on Federal Acquisition Regulation ANOPR: Minimizing the Risk of Climate Change in Federal Acquisitions

On January 13, 2022, EPRI submitted public comments on the Biden Administration’s advance notice of proposed rulemaking (ANOPR) for consid­ering greenhouse gas (GHG) emissions and the social cost of carbon in federal procurement (Federal Acquisition Regulation: Minimizing the Risk of Climate Change in Federal Acquisitions, FAR Case 2021-016). The ANOPR was published by the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA). This publication represents EPRI’s public comments.

EPRI’s comments discuss important technical issues associated with potential procurement consideration of GHGs, including the risk of pricing GHGs more than once and the economic inefficiency of procurement as an emissions reduction policy instrument. The public comments are grounded by EPRI’s research, including its social cost of greenhouse gases (SC-GHG) and climate-related risk research, and touch on a variety of critical issues for industry and society that are relevant beyond the context of the ANOPR, including technically grounded use of SC-GHG estimates, GHG accounting and decision consideration, climate-related risk assessment, and GHG goal setting.