Sharing a couple news items regarding GSA's Alliant 2 GWAC.

1.  GAO recently denied protests.  Evaluations and awards can now proceed. See the January 11th decision here. 

2. GSA issued a revised Information Collection Request (ICR) notice for the greenhouse gas (GHG) emissions information required under Alliant 2's Section G.25.  Based on comments to the first ICR notice, including those of Corporate Sustainability Advisors, GSA has a new burden estimate for the GHG reporting.  Per the new calculation, GSA estimates that the average Alliant 2 awardee will take about 120 hours each year to comply with the G.25 provisions.  This is up from GSA's original estimate of 80 hours. The revised ICR notice is here.  The public comment period closes February 13th. 

E&E Publishing’s ClimateWire ran a story today, September 12, reporting on the draft FAR clause proposed by the DOD, GSA, and NASA in May 2016. As earlier blogged here, the proposed rule is expected to impact some 5,500 federal contractors, including about 2,700 small businesses.
 
As drafted, federal contractors with $7.5+ million annually in federal awards will have to disclose whether they publicly report on their greenhouse gas (GHG) emissions management. The proposed rule also raised the possibility of seeking similar disclosures about whether federal contractors publicly report if they conduct any climate risk analyses. Firms under $7.5 million will be encouraged, but not required, to disclose their GHG reporting.
 
I was pleased to share my thoughts on and support of the proposed rule for the ClimateWire article. Corporate Sustainability Advisors also submitted a comment letter to the government supporting the proposed rule and encouraging the government further address its supply chain emissions. This proposed rule is a small step forward for the federal government to mirror what the private sector has been doing with its supply chain for years.
 
To a large extent, publicly-traded federal contracting companies already disclose their GHG emissions to meet investor expectations. There is a close connection between GHG emissions and energy use. Companies that proactively address their GHG emissions often see reductions in their operational costs compared to business-as-usual scenarios where energy usage and costs are frequently ignored. Transparency about GHG emissions provides vital information to customers, investors, and taxpayers.
 
On a related matter, GSA is seeking public comment on the information collection request (ICR) associated with the GHG and other sustainability reporting that will be required of the new Alliant 2 unrestricted contract winners.  The comment period closes on October 24th. As previously blogged here, section G.25 of the Alliant 2 contract terms requires the awardees to publish a “Sustainable Practices and Impacts Disclosure” or SPID within 12 months of the notice to proceed of the master contract and annually thereafter for the life of the contract. After award, Alliant 2 contractors will have to a complete Scope 1 and 2 GHG inventory 12 months after the first SPID (i.e., 2 years after the notice to proceed). GSA provides another 12 months before the contractors must set and report on their GHG reduction targets. GSA is encouraging, but not requiring Scope 3 GHG reporting. GSA will evaluate compliance for these disclosure requirements via the Contractor Performance Assessment Rating Systems (CPARS) annual review.

​The General Services Administration (GSA) just released the request for proposals (RFP) for the $50 billion Alliant 2 government wide acquisition contract (GWAC) for information technology (IT) services. The Alliant 2 GWAC has been in the news as the future of government IT contracting because of its evaluation process and flexibility to provide leading edge technology solutions.
 
An innovative requirement for the unrestricted contract that hasn’t made the headlines or many bidders radar is Section G.25. This section requires the awardees to publish a “Sustainable Practices and Impacts Disclosure” or SPID within 12 months of award of the master contract and annually thereafter for the life of the contract.
 
In my experience and research, most federal contracting firms do not have sustainability programs, apart from some of the largest companies. And, as indicated by CEQ’s 2015 Federal Supplier Greenhouse Gas (GHG) Management Scorecard, even the majority of the largest federal contracting companies do not have greenhouse gas emission (GHG) reduction goals.
 
GSA and other agencies are giving the contracting community time to build-out their sustainability programs. For example, the Alliant 2 contract doesn’t require its contractors to have a complete Scope 1 and 2 GHG inventory until 12 months after the first SPID. GSA provides another 12 months before the contractors must set and report on their GHG reduction targets.  GSA is encouraging, but not requiring Scope 3 GHG reporting. GSA will evaluate compliance for these disclosure requirements via the Contractor Performance Assessment Rating Systems (CPARS) annual review.
 
These contract mandates mark a big change in the federal market. The feds have been following the lead of large commercial retailers and manufacturers to reduce costs and environmental impacts from their own operations for almost a decade. Now, like Walmart and Nike, the federal government is also working to green its supply chain.
 
In all likelihood this represents the future of federal contracting for most large and mid-sized firms. Even for many small businesses.  As Kevin Kampschroer, GSA’s Chief Sustainability Officer, recently noted, “By disclosing [GHG and other sustainability impacts], GSA’s private sector partners can prepare themselves to do business with us in the future, as the agency continues to incorporate carbon disclosure goals and performance criteria into specific contracts.”
 
For those who think these supply chain greening efforts will only impact firms that support civilian agencies, think again. The DoD, Air Force, and Army have been the three biggest buyers on the Alliant 1 GWAC. In addition, here are three other recent indicators to illustrate the scope of this trend.

1. GSA and the Navy ask their largest contractors to respond to the CDP (formerly Carbon Disclosure Project) Supply Chain survey. This year, the Department of the Navy joined GSA in asking its top 100 contractors to voluntarily respond to this survey. The CDP survey seeks information about GHG management practices and emissions, among other things. In 2015, GSA asked 115 companies to respond to the survey (63 responded). This year, GSA is asking 220 companies to respond.
2. DOD, GSA, and NASA proposed a draft FAR clause last month that is expected to impact some 5,500 companies, including about 2,700 small businesses. As drafted, contractors with $7.5+ million annually in federal awards will have to publicly disclose on their GHG management and climate risk analyses. Firms under $7.5 million will also be encouraged to disclose.
3. The Implementing Instructions for EO 13693 require the 7 largest procuring agencies to begin including contractor GHG management in at least 5 RFPs/contracts annually. The Alliant 2 contract terms and the proposed FAR clause are some of the first actions taken under these directives. Stay tuned for additional requirements.

 
To all future Alliant 2 winners, do not underestimate the time it takes to build a sustainability program robust enough to have GHG reporting and reduction goals. As a significant co-benefit to contractual compliance, however, you’re likely to realize cost savings from reduced energy use. It’s never too soon to start planning (and saving).