Photo of Peter J. EyrePhoto of Paul FreemanPhoto of Ellie DawsonPhoto of Issac Schabes

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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Photo of Peter J. Eyre Peter J. Eyre

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and…

Peter J. Eyre is a partner and co-chair of Crowell & Moring’s Government Contracts Group. He is also a member of the firm’s Management Board. Peter was named to BTI Consulting Group’s list of “Client Service All-Stars” in 2016, 2017, and 2019 and has been named an Acritas Star, Acritas Stars Independently Rated Lawyers (2016, 2017, 2019). He is nationally ranked by Chambers USA in Government Contracts since 2014, and by Super Lawyers since 2017.

Photo of Paul Freeman Paul Freeman

Paul Freeman is a partner in Crowell & Moring’s New York office and a member of the firm’s Environment & Natural Resources and Government Contracts groups. He brings two decades of diverse experience advising clients in the energy, maritime, and aerospace and defense…

Paul Freeman is a partner in Crowell & Moring’s New York office and a member of the firm’s Environment & Natural Resources and Government Contracts groups. He brings two decades of diverse experience advising clients in the energy, maritime, and aerospace and defense industries on a range of issues, with a primary emphasis on matters involving enforcement defense, litigation, and risk management.

Paul routinely advises clients in response to investigations by, or inquiries from, a range of regulators, primarily the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (DOJ), and also including the U.S. Securities and Exchange Commission, the Internal Revenue Service, the U.S. Department of Defense Inspector General, the Federal Bureau of Investigation, the U.S. Commodity Futures Trading Commission, and state attorneys general.

Photo of Ellie Dawson Ellie Dawson

Elizabeth (Ellie) B. Dawson is a counsel in the Environment & Natural Resources Group in Crowell & Moring’s Washington, D.C. office and a leader of the firm’s global ESG Advisory Team. She advocates for her clients’ interests in everything from agency rulemaking petitions…

Elizabeth (Ellie) B. Dawson is a counsel in the Environment & Natural Resources Group in Crowell & Moring’s Washington, D.C. office and a leader of the firm’s global ESG Advisory Team. She advocates for her clients’ interests in everything from agency rulemaking petitions under the Clean Air Act to Superfund liability and allocation disputes, everywhere from the U.S. Court of Appeals for the D.C. Circuit to the Western District of Washington.

Photo of Issac Schabes Issac Schabes

Issac D. Schabes is an associate in the firm’s Washington, D.C. office, where he is a member of the Government Contracts Group.

Prior to joining the firm, Issac clerked for the Honorable Matthew H. Solomson on the U.S. Court of Federal Claims and…

Issac D. Schabes is an associate in the firm’s Washington, D.C. office, where he is a member of the Government Contracts Group.

Prior to joining the firm, Issac clerked for the Honorable Matthew H. Solomson on the U.S. Court of Federal Claims and the Honorable Robert N. McDonald on the Maryland Court of Appeals. Issac received his J.D., magna cum laude, from the University of Maryland Carey School of Law, where he graduated Order of the Coif and served as an executive editor for the Maryland Law Review. He received numerous awards, including the Judge Simon E. Sobeloff Prize for Excellence in Constitutional Law. During law school, Issac was a member of a low-income taxpayer clinic team that successfully appealed an IRS assessment resulting in a substantial tax liability reduction, and also interned for the Honorable Beryl A. Howell, Chief Judge, on the U.S. District Court for the District of Columbia and the Honorable Marvin J. Garbis on the U.S. District Court for the District of Maryland.