On December 23, 2022, the Department of Defense ("DoD"), General Services Administration ("GSA"), and National Aeronautics and Space Administration ("NASA") extended the comment period on the proposed rule, "Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk," from January 13, 2023 to February 13, 2023. As we summarized previously, the proposed rule would, if finalized, require thousands of federal contractors to inventory and publicly disclose their Scope 1 and Scope 2 greenhouse gas ("GHG") emissions, while further requiring "major" contractors to also establish and validate GHG emission-reduction targets tailored to the goals of the Paris Agreement.
The 30-day extension should be a welcome surprise to a wide range of contractors still attempting to unwrap the impact of this largely unprecedented proposal. Crowell's team stands ready to assist in evaluating the implications and identifying issues worthy of comment.
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