Sustainability Trend Spotting by Corporate Sustainability Advisors

GHG Reporting in SAM

6/7/2017

Federal contractors - have you recently updated your reps and certs in SAM?

If you've recently been in GSA's System for Awards Management, you've run into the new FAR requirement for certain contractors to make representations about their public disclosure of greenhouse gas (GHG) emissions inventories and goals. For more background on the rule, check out our prior blog posts here and here.

If you haven't recently updated your reps and certs, the new representations are required for most contractors under FAR provisions 52.204-7 and 52.223-22 (and an equivalent at 52.212-3 for commercial/COTS items).

The trigger is simple: If your company received $7.5+ million in Federal contracts during the prior Federal fiscal year, you are required to make the representations. If your company was below $7.5 million in FY16, you may voluntarily choose to report on your public GHG disclosures but are not required do to so.

FAR 52.223-22 Public Disclosure of GHG Emissions and Goals. Representation Required by Federal Contractors. Corporate Sustainability Advisors, LLC

Federal Acquisition Regulation 52.223-22 Public Disclosure of Greenhouse Gas Emissions and Reduction Goals-Representation

The GHG reps appear in Question 32 (FAR response page 4). The image below is a screen shot from the SAM reps section, after selecting "yes" for the first value (i.e., the company received $7.5+ million in Federal contracts during the prior Federal fiscal year).

GHG Emissions Disclosure Representations Required by Federal Government Contractors in SAM Question 32, Corporate Sustainability Advisors, LLC can help.

Question 32 in SAM | Representations About GHG Emissions Inventories/Reduction Goals Public Disclosure

The image below is from the most recent SAM Questionnaire for Representations and Certifications (Reps and Certs user guide) (February 24, 2017).

SAM Users Guide for GHG Emissions Representations. Corporate Sustainability Advisors, LLC.

SAM Reps & Certs Questionnaire Users Guide, FAR Responses Question 32. (February 24, 2017)

There is a noted departure between the final FAR rule and how the representation is stated in SAM. The SAM language implies that GHG emissions inventories and goals must be publicly disclosed (for those with $7.5+M the prior Federal fiscal year). In the final rule making, however, the FAR Council was very clear that they are only seeking information about whether companies are making public GHG disclosures. So, the FAR just requires you to report whether or not you publicly disclose GHG emissions inventories/reduction goals. If you already publicly disclose either an emissions inventory and/or reduction goals, you are required to provide a link to the publicly accessible web site where the disclosure(s) have been made.

If you're new to GHG emissions reporting or goal setting, we can help you navigate these new representations. Give us a call at (888) 807-5237 or email us at info@corporatesustainabilityadvisors.com.

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Take Action on Climate Change | 5 Things a Small Business Owner Can Do

6/6/2017

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With so many climate change stories in the news these days, what's an owner of a medium-size or small business to do? There's a lot of talk about what governments and large, global companies are doing to climate-ready their businesses, but fewer tips for smaller businesses.

Owners of smaller businesses face similar risks (and may also have opportunities) from climate-related impacts:

physical hazards such as increased temperatures, storm events or sea level rise;
regulatory changes such as voluntary or mandatory CO2 emissions reporting or green building standards; and
market changes including energy and other resource cost increases, new provisions to "green" your lease terms, or shifts in workforce and consumer valuation of sustainability practices.

While the scale of these risks is certainly smaller in terms of overall costs/revenue/GDP, the relative risk to each business can be significant, even making the difference between thriving or going under.

Here are 5 things any business owner or leader can do to take action on climate change and make their business more resilient.

Know your climate impacts: How much energy do you use to run your business? How much do you pay for your energy? How climate-intensive are your other business purchases and operations?
Assess your climate risks: How might climate-related physical, regulatory or market changes impact your supply chain, employees, sales, delivery and other business operations?
Make a plan to reduce the impacts and mitigate the risks: Tackle the low-hanging fruit first before moving onto the bigger challenges. Increase energy efficiency, integrate more climate-friendly supplies and process improvements, and explore using cleaner energy sources.
Measure your climate emissions reductions and cost savings: Be sure to measure both the environmental reductions and associated costs and savings. Allocate some of the costs savings for longer-term investments to make your business more sustainable and climate adaptive.
Communicate with your employees, customers, investors, vendors and community about #1-4. It's important to talk with all your key stakeholders about what you're doing (and why) to make your business more resilient.

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