ABA Comment Letter Requesting Comment Period Extension to DOD, GSA and NASA on Federal Climate Disclosures

To Whom It May Concern:

The American Bankers Association is pleased at the opportunity to comment on FAR Case 2021-015 – Federal Acquisition Regulation Disclosure of Greenhouse Gas Emissions and Climate-related Financial Risk (FAR). The FAR proposes to require certain Federal contractors to disclose their greenhouse gas emissions and climate-related financial risks, as well as set science-based targets to reduce their greenhouse gas emissions.

The prescriptive requirements of the disclosures, the generally nascent state of climate risk analysis and measurement, and the nature of government contracting are just a few of the factors that may put into question the usefulness of the disclosures, as well as the anticipated cost of compliance. With this in mind, the proposed FAR was issued with a sixty-day comment period that aligns with several weeks that are normally used for vacation by many in the U.S.

ABA believes that a thoughtful analysis of the requirements of the proposed FASB requires more time. Therefore, we respectfully request that the comment period be extended with sixty
additional days until March 14, 2023.

If you have any questions, please contact me at [email protected] if you would like to discuss this further.