Comments in Response to the Proposed Rule on Federal Acquisition Regulation (FAR): Disclosure of GHG Emissions and Climate-Related Financial Risk (Far Case 2021-015)

CRS’s comments pertain to the use of a market-based Scope 2 total for GHG accounting, the use of market-based instruments in Scopes 1 and 3, the proposed exclusive use of the Greenhouse Gas Protocol (GHGP) standard, and verification of GHG inventories.