General Services Administration Acquisition Manual (GSAM) Case 2021-G528, Sustainable Acquisition

The Federal Acquisition Regulation (FAR) currently requires environmental consideration during acquisition planning (see FAR 7.105(b)(17)) as it relates to FAR Part 23, which focuses on energy efficiency, renewable energy technologies, recovered materials, biobased products, environmentally preferable products, and non-ozone depleting products.

Executive Orders (E.O.) 13990, 14008, and 14030 all describe utilizing Federal procurement as a method to move the market towards environmental sustainability. As the largest consumer of supplies and services, the United States Government is able to create demand and encourage private investment in domestic clean energy, electric cars, energy efficient buildings, and other necessary supplies.

The U.S. agency responsible for supplies, services, and real property to the federal government is the General Services Administration (GSA). To successfully change not only market culture, but internal acquisition culture, GSA contracting officers (acquisition officials) need to both view markets as susceptible to climate change and acquisitions as instrumental in changing course.

The General Services Administration Acquisition Manual (GSAM) was amended in change 138 to require that sustainability be addressed during the acquisition planning phase. This change requires GSA contracting officers to include strategies to either mitigate or adapt to climate change. These strategies can be explored during acquisition planning and should be clearly documented within the acquisition plan. This change recognizes that some procurements might be better positioned to address sustainability objectives than others. This change also highlights for the contracting officer that whether it is in the requirements, the statement of work, the method of award, or the contract administration strategy, most acquisitions present opportunities to consider the impact on the environment.

The policy change also impacts how GSA’s requirements are developed. The change instructs that GSA requirements should address embodied carbon, ecolabels, renewable energy opportunities, waste, sourcing, efficiency, and content management

Higher dollar, risk, or higher visibility acquisitions are required to undergo additional reviews. The acquisition review process was also updated by the agency to include subject matter experts in sustainability to share ideas on the best methodology to achieve the most sustainable solution. By utilizing existing resources within the Government, GSA is able to address sustainability, build camaraderie within the agency, and also reduce overall cost to the Government.