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Interact Question #12 – Sustainability Management

All Federal agencies purchase goods and services, operate buildings, own or lease fleet vehicles, and use IT equipment. These four activities create significant environmental and energy impacts -- impacts that can be mitigated by our purchasing decisions.

In 2013, concentrations of greenhouse gases (GHGs) in the atmosphere reached historic levels, according to the World Meteorological Organization. The United States and its businesses have been feeling the effects of related climate change, from temperature extremes, to rising sea levels affecting our coastal operations, to economic costs from damage to infrastructure and supply chains. The annual Western wildfires alone cost the U.S. an estimated $3 billion annually. The Office of Management and Budget estimates that, over the next 15 years, the average annual cost of coastal storms is expected to increase to $35 billion.

President Obama’s Executive Order 13514, Federal Leadership in Environmental, Energy, and Economic Performance, directed Federal agencies to take actions to achieve a clean energy economy. As part of this effort, Federal agencies have been inventorying and reporting their GHG emissions, setting GHG emission reduction goals, making their buildings and fleets more energy efficient, increasing their use of renewable energy, increasing data center efficiency, moving IT operations to the cloud, and looking to reduce the GHG emissions from their supply chains.

GSA believes that existing and ever expanding Contractor use of sustainability management practices - including energy efficiency, carbon footprint tracking, and climate change risk management - and incorporating those practices into the GWACs can benefit clients for several reasons:

✔Will drive down contractor energy costs and price risks.

✔Will improve productivity and efficiency.

✔Will improve employee and public health.

✔Will enhance continuity of operations during extreme weather and climate-related emergencies.

Based on the publicly reported practices of several well-known IT service providers, including several of the existing GWAC Contractors, the GSA GWAC Program is proposing to incorporate into the Alliant 2 solicitation, the requirement to report a Contractor’s sustainability management practices and use of third-party systems for the Contract Holders to use in reporting progress towards meeting sustainability milestones.

The proposed milestones might be:

·   Within xx Days/Months/Years - Propose that contractors begin publishing publicly-available annual disclosures of sustainability information, including status of efforts toward creating a corporate greenhouse gas (GHG) inventory and a description of climate change risk management activities.

·   Within xx Days/Months/Years - Propose that contractors begin annual public disclosures to include a complete GHG inventory.

·   Within xx Days/Months/Years - Propose that contractors begin annual public disclosures to include a GHG reduction target (either for reduction of total carbon footprint, or for reduction of “carbon intensity” -- i.e., carbon footprint per activity measure such as sales, number of employees, or square feet of facilities).

·   Within xx Days/Months/Years- Propose that contractors begin annual public disclosures to begin reporting progress towards meeting the GHG reduction target.

The proposed third-party reporting systems for submitting these disclosures might be:

·   Carbon Disclosure Project (CDP) annual “Climate Change” survey (preference for Investor and/or Supply Chain version TBD);

·   Global Reporting Initiative (GRI) sustainability reporting framework, and/or

·   B Impact Assessment (proposed for use by small businesses only).

Use of these systems and their online reporting portals provides efficient means for the Contract Holders to share information on energy efficiency, carbon footprint, and related practices with GSA and, if desired, with other interested customers, and other stakeholders. Use of these systems also reduces redundant reporting requirements.

The GSA GWAC Program’s suggestion of these proposed milestones and reporting systems was driven by several objectives, including:

·   Promoting the reduction of GHG emissions associated with Federal procurement, in accordance with Executive Order 13514 and the President’s Climate Action Plan.

·   Ability for Contractors, GSA, and customer agencies to easily and uniformly track Contractor progress toward inventorying and reducing corporate GHG emissions.

·   Use of proven practices and systems which are already in broad use globally among potential Contractors, investors, and major companies.

·   Minimizes reporting effort and “survey fatigue” if imposed at the Task Order level.

The GSA GWAC Program is soliciting feedback to the above approach to ensure achievement of these objectives for the Alliant 2 GWAC. We are interested in your feedback to the following questions:

1.    Are the sustainability objectives clear, and/or any other objectives that should be stated?

2.    Do you believe these milestones are effective to achieving the desired result?

3.    Should the milestones be staggered and what is recommended length of time for each milestone?

4.    Are there other third-party reporting systems that we should consider?

5.    Are there measurable metrics within your firm that we should consider applying to the GWAC that will help address sustainability and climate change?

Thank you for your valuable feedback.

 

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Comments

annahogan
<p><span style="display: none;">&nbsp;</span></p><p>SRA International, Inc, is pleased to provide feedback to your questions&nbsp;about the draft sustainability objectives and proposed milestones for the Alliant 2 GWAC.&nbsp;</p><p>1.&nbsp;&nbsp;&nbsp; Are the sustainability objectives clear, and/or any other objectives that should be stated?</p><p>In general, the objectives are clear and appropriate. We suggest the following to make the objectives even more clear:</p><ul><li>The objectives are focused on GHG emissions rather than broader sustainability metrics. We suggest it would be more clear and consistent to specify that the objectives are GHG-centric rather than describing them with a general term (i.e., &ldquo;sustainability objectives&rdquo;)&nbsp;&nbsp;</li><li>We suggest you could include additional information (e.g., from the October 20, 2014, Webinar and/or EO 13514) that better describes and makes the connection between:<ul><li>GHG emissions and &ldquo;sustainability&rdquo;</li><li>A contractor&rsquo;s GHG emissions&rsquo; as they relate to the federal government&rsquo;s Scope 3 emissions</li><li>Why a contractor&rsquo;s GHG emissions are relevant to the procurement process.&nbsp;</li></ul></li></ul><p>This will be especially helpful for companies that do not yet have mature sustainability programs or an understanding of the federal government&rsquo;s sustainability goals and efforts.</p><ul><li>We concur with the difficulty in reporting and tracking GHG emissions or sustainability at the task order level.&nbsp; To remove any potential uncertainty, we suggest modifying the language to re-iterate that the milestones will be measured at a corporate level (i.e., not at a contract or task order level).</li></ul><p>2.&nbsp;&nbsp;&nbsp; Do you believe these milestones are effective to achieving the desired result?</p><p>Incorporating milestones such as these into the procurement process conveys to the contractor community the importance of measuring and reporting their GHG emissions. This message should increase the number of companies that conduct GHG inventories and set emissions reduction goals.&nbsp; Since what gets measured usually gets managed, procurement/contract related milestones such as these will likely aid in GHG reductions across the contractor community. To the extent the government describes the milestones as mandatory versus optional will further impact progress towards the objectives.&nbsp; Even if mandatory, however, they have substantial limitations with regard to actually being able to aid the calculation of the federal government&rsquo;s Scope 3 GHG emissions inventory and/or ensure the reduction of the government&rsquo;s Scope 3 emissions. This would likely require at least contract level reporting and mandatory reduction goals, neither of which may be currently feasible across the contractor community (especially for small businesses).</p><p>We think it would be helpful to provide additional clarification about the extent of the inventory and reduction goals for some or all of the milestones. For example:</p><ul><li>Are you encouraging/requiring that the inventories apply to Scope 1, 2, and 3 GHG emissions?&nbsp;</li><li>Are you seeking mandatory targets for Scope 1 and 2 and optional targets for Scope 3?</li></ul><p>Additionally, with regard to the first proposed milestone, we think the phrases &ldquo;disclosures of sustainability information&rdquo; and &ldquo;a description of climate change risk management activities&rdquo; are ambiguous. If possible, please include additional explanation of what these might entail (e.g., scope, frequency).&nbsp;</p><p>We think it is important to acknowledge and accommodate the wide range of companies supporting the federal government &ndash; from professional services companies to product vendors and manufacturers, as well as variety in company size.&nbsp; The sustainability/climate risk measures and disclosures will vary widely by company type and size.&nbsp; What is material for a manufacturer may not be material for a professional services firm.&nbsp;</p><p>3.&nbsp;&nbsp;&nbsp; Should the milestones be staggered and what is recommended length of time for each milestone?</p><p>To ensure fair competition especially for small businesses, it seems reasonable to stagger these milestones. We suggest that each be phased in 1 year apart, at a minimum.&nbsp; Shorter stages may add unnecessary complications to other corporate fiscal year planning and reporting.</p><p>4.&nbsp;&nbsp;&nbsp; Are there other third-party reporting systems that we should consider?</p><p>No additional recommendations.</p><p>5.&nbsp;&nbsp;&nbsp; Are there measurable metrics within your firm that we should consider applying to the GWAC that will help address sustainability and climate change?</p><p>SRA has been working to incorporate many of the metrics being tracked and reduced by the federal agencies under its sustainability programs (e.g., EO 13514, EISA) as reported in their annual scorecards and SSPPs.&nbsp; Because of our size and the nature of our business not all of the federal agency metrics are applicable (e.g., fleet management). We have created others that are more relevant to the material environmental impacts created by our business operations, but not specifically required by the federal agencies (e.g., reduction in paper use). Given the diverse range of businesses supporting the federal government it may be difficult to impose all of these metrics, but GSA could suggest that companies seek to replicate, but adapt as warranted, the goals stated in EO 13514 (and other requirements &ndash; e.g., EISA).</p>
kent.bartlett
<p>Requiring small companies to conduct sustainability management reporting will just add cost with no measureable benefit. SB will have to hire an employee or consultant that understands the program, can define and measure to the requirements and develop the reports. This cost will be added as indirect cost to any subsequent contract.&nbsp; SB are already under extreme cost pressure due to the LPTA environment and will be able absorb more costs that do not provide any value add to the customer.&nbsp; SB are already encouraging recycling and ride sharing and looking at ways to reduce energy usage. Most SB could shut off the power and lay off workers and not move the needle on sustainability.&nbsp; This is another burdensome requirement that will add significant cost with no benefit and should be removed.</p>
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