GSA MV-21-10 Acquisition Innovation Initiative

The General Services Administration which is responsible for real property, services, and supplies for the U.S. federal government recently updated the acquisition manual (GSAM) to address sustainability. To support this change GSA has also called for innovation in the area of climate action.  An acquisition letter was released in October 2021, that encourages the use of innovative contracting solutions that address environmental issues, beyond merely looking at the attributes of a product being purchased alone. It also provides guidance on existing flexibilities within acquisition to support better environmental outcomes.  

The acquisition innovation initiative asks GSA’s contracting officers and acquisition staff to be creative in finding the best solutions to achieve the most sustainable outcomes. This initiative is not limited, so a contracting officer could focus purely on the consumption of a product or ask questions about the production of a product as well. There are suggested goals for the acquisition staff to consider, which correlate with goals that are identified in executive orders 14008 and 14030.

Goal examples for the contracting officers to consider include climate supply chain risk management, total life cycle cost, environmental evaluation factors, review of contractor corporate policies, regional resourcing, and mutual learning opportunities with industry.

Climate supply chain risk management could include analyzing supply chain risk related to climate change (e.g., power disruption, flooding, tornados, fires) as well as supply chain management opportunities (e.g., innovative technology within the market, promotion of new businesses entering the market). GSA contracting officers are asked to focus on supply chains that are included in GSAs vulnerability list. The list includes: products that are most vulnerable such as real property, information and communications technology, water and waste utilities, transit access, and products and services vulnerable to the global supply chain.

Innovative ideas for proposal evaluation include total life cycle cost assessment, as well as exploring the use of environmental factors. Environmental evaluation factors can be used for making award decisions. Language could include asking contractors to highlight environmental objectives in their offers such as waste reduction, source reduction, or recycled content. Anticipated holistic outcomes from utilizing alternative solutions (or combinations of solutions) will be documented.

Contractor corporate policies could also be reviewed as part of proposal evaluations. Assessing contractor’s policies such as a company’s greenhouse gas emission statement, or their overall company environmental, social, and governance strategy or plan. This could be addressed when planning for services (to include professional services and information technology services) and supplies acquisitions. For example, a business policy that allows for remote work and cloud-based solutions could reduce the travel needed to commute and lessen climate impact. 

Regional resourcing is a goal that would allow the Government to maximize the opportunity to expand upon the availability of sustainable goods and services, contracting officers participating in this innovation initiative could consider, if appropriate, evaluation factors or requirements that consider the availability of regionally-sourced supplies and services for contract performance; meaning as geographically close to the place of delivery or performance as allowable. Regional resourcing may promote the Government’s goals of building local economies by supporting small businesses and supporting environmental justice initiatives. To do this GSA would utilize local area preferences that are consistent with available authorities (e.g., AbilityOne, Federal Prison Industries) if regional resourcing provides a significant advantage to the Government, then the regional area (or locality) could be considered when defining contract requirements and evaluation factors.

Regional resourcing also allows the Government to consider externalities as a potential evaluation factor. An externality can be viewed as the ripple effect from what is being procured. An example of an externality is a city procures a public transportation system with the intent of reducing traffic. The externalities would be improved air quality, which could lead to reduction in healthcare costs. Allow the contractor to briefly explain any externality in its offer. The externalities would be evaluated similarly to how the Government examines socioeconomic considerations in other acquisitions.

Lastly this acquisition letter looks at opportunities at post award for mutual learning between the Government and industry partners. Incorporate performance requirement for industry to provide data that will benefit both parties. By learning where the opportunities may lie for a more environmentally preferable solution, the Government can better manage how to adapt to climate change, and industry can learn how to better compete in their market. One example of this is commercial airline carriers agreeing to include greenhouse gas monitors on their commercial aircraft for the Government to collect real time data. This action benefits both the airline industry as well as Government emission monitoring programs, with the long-term solution being to identify how commercial flights can be less harmful to the environment.