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A misguided emissions rule could expose sensitive work by our military and scientific institutions

AP Photo/Patrick Semansky
President Joe Biden speaks during a cabinet meeting at the White House on Jan. 5, 2023. From left, Biden, Secretary of Defense Lloyd Austin, and Commerce Secretary Gina Raimondo.

The U.S. government is doing it again: prioritizing climate regulations and bean-counting carbon emissions by agencies with no climate regulatory authority over the well-being of the country. The new initiative — under the guise of an onerous carbon emissions disclosure regulation for military and NASA vendors — would do nothing to improve the environment while potentially putting our national security and scientific preeminence at risk. 

The proposed rule not only would require major suppliers to the Department of Defense (DOD) and NASA to disclose their greenhouse gas (GHG) emissions and related financial risks, but also would require them to report the GHG emissions of their customers — called Scope 3 emissions — according to guidelines established not by the United States but by an international environmental nonprofit organization. Scope 3 emissions are essentially impossible to accurately assess, so inventory provided by a business seeking a military or scientific contract would be inaccurate or a guess, at best. It should not be used for any type of assessment. 

Scope 3 concerns “emissions that are a consequence of the operations of the reporting entity but occur at sources other than those owned or controlled by the entity.” In other words, the proposed rule requires major contractors to report a greenhouse gas inventory of emissions created by that company’s direct and indirect suppliers and customers. As with a rule proposed by the Securities and Exchange Commission last summer, the DOD and NASA have not indicated how a vendor is supposed to take on the responsibility for reporting Scope 3 emissions. As a Harvard Business Review study stated, “Most companies know only a few of their non-tier-1 suppliers and customers well enough to get meaningful data from them.” The task of Scope 3 accounting is essentially a “near impossibility.”

Of even greater concern to Americans should be the decision to attach this rule to vendors and contractors for the DOD and NASA. These agencies are the least fit to such nitpicking. First, it is almost impossible to reliably estimate the Scope 1, Scope 2 and Scope 3 emissions for the types of specialized, expensive and emissions-heavy products the contractors for these agencies produce. When academics have attempted to estimate the emissions of our military, they have found this exercise nearly impossible. 

According to a Boston University professor, for example, an F-35 uses about 2.37 gallons of jet fuel per mile flown, but that is merely the tip of the iceberg for the emissions accounting required by this proposed regulation. The company constructing the F-35 would have to provide data on the emissions produced while constructing the jet; while manufacturing the parts used to construct the jet and transporting those parts; maintaining the jet; the emissions that the jet is expected to generate during its use by the military; and so on. 

Perhaps the most disconcerting part of this proposed rule is that it delegates input on our national defense and science exploration to international environmental organizations. The proposed regulation says, “The major contractor (itself or through its immediate owner or highest-level owner) is also required to develop science-based targets and have the targets validated by SBTi.” SBTi, or the science-based targets initiative, is described as “a partnership between CDP, the United Nations Global Compact (UNGC), the World Resources Institute (WRI), and the World Wide Fund for Nature (WWF, also known as the World Wildlife Fund).” In other words, the DOD and NASA will defer to a partnership between a UN agreement, a D.C.-based NGO and a Swiss-based NGO to procure what is necessary to defend the country and to pursue the most significant and risky scientific research.

Through this proposed rule, the U.S. government would allow third parties, some of them foreign entities, to have input into the vital defense and science matters of our country. This is reckless and irresponsible. It is irrational for an international NGO to determine the qualifications of an American business as a supplier for the American military or the greatest scientific research agency in the world. This appears to be a way to relinquish control of our defense and our search for scientific knowledge to others, and a way to relinquish our priorities for national defense to a group of organizations dedicated to an altogether different cause.

For that matter, the proposed regulation is wrong to put so much faith and trust in SBTi alone, setting just one standard for science-based climate methodology. These major contractors — many of which are at the top of scientific and engineering ingenuity themselves — would be beholden to SBTi’s one standard alone, with no opportunity to use other standards or their own innovation to pursue our national goals while preserving the environment. This is a myopic way to look at a problem and potential solutions. 

Rather than harnessing the great minds at DOD’s and NASA’s contractors, the proposed regulation would compel them to follow the rigid standards and accounting requirements of the managers at the United Nations and NGOs. The DOD, NASA and the General Services Administration should reconsider this deeply misguided proposed regulation.

Ellen R. Wald is a senior fellow at the Atlantic Council’s Global Energy Center, and president of Transversal Consulting, a global energy and geopolitics consultancy. She is the author of “Saudi, Inc.,” a history of Aramco and how the Saudi royal family controls this multitrillion-dollar enterprise. Follow her on Twitter @EnergzdEconomy.

Tags Department of Defense emissions greenhouse gases NASA Securities and Exchange Commission

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