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Comments to FAR Council on Considering Climate in Federal Procurement

In October 2021, the Federal Acquisition Regulatory Council (FAR) released an advance notice of proposed rulemaking that requested input on how federal agencies could best account for climate impacts in their procurement decisions. Together with several environmental nonprofits, we filed comments supporting the Council's emphasis on climate-sensitive procurement. We endorse using the social cost of greenhouse gases in procurement decisions and suggest rigorous ways for agencies to incorporate those figures into their analyses of different bids and proposals. We also suggest some ways for agencies to consider climate impacts when emissions data are not readily available.