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.
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).
The image below is from the most recent SAM Questionnaire for Representations and Certifications (Reps and Certs user guide) (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 firstname.lastname@example.org.
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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.
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.
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).
Hi. I'm Colleen, Corporate Sustainability Advisor's founder and owner. Blogging about corporate sustainability trends, benefits, and best practices.