Two federal agencies recently released a joint Request for Information (“RFI”) in the latest in a series of concrete steps to meet the Biden Administration’s goal to achieve 100 percent carbon pollution-free electricity (CFE) in federal operations by 2030. The RFI, issued by DLA-Energy and GSA, offers industry a chance to shape future federal CFE procurements by providing information on carbon-free electricity supplied in competitive retail markets. Although not itself a procurement opportunity, the information submitted under the RFI will inform the parameters and conditions of CFE competitions that the federal government expects to begin as soon as this year, with contract deliveries starting in 2023.
President Biden’s Executive Order 14057 sets out a series of government-wide goals to reduce greenhouse gas emissions and promote sustainability in federal operations. (Our discussion of the EO is available here.) As the EO recognizes, the Government is a significant consumer of electricity, and the Administration’s emphasis on more sustainable energy policies – and accompanying CFE procurements – presents an immense opportunity for the clean energy industry. DOD alone spent $551 million on electric power, transmission, and distribution services in FY21, and that figure likely will grow while the Administration develops its whole-of-government approach to implementing CFE.
To achieve the desired economies of scale to meet the Administration’s goal to transition to 100 percent CFE on a net annual basis by 2030, the Government has signaled that it is willing to combine CFE procurements across multiple agencies, and to extend contract timelines up to 10 years, where appropriate. The RFI seeks to collect the information to support the solicitation process, and, in terms of content, focuses on collecting information on retail electricity supplied CFE in identified competitive retail markets (specifically PJM, ERCOT, ISO-NE, MISO, and NYISO). Respondents are encouraged to provide the following details for each market:
- proposed or recommended approach to meet the Government’s CFE goals,
- annual price for retail electricity supplied CFE in a specific market for a range of supply quantities,
- baseline hourly matching percentage for the CFE supply proposed under category 1, and
- portfolio adjustments necessary to increase the percentage CFE match on an hourly (24/7) basis, as proposed under category 3.
In soliciting this information, the RFI includes a series of tables in which interested respondents are invited to insert information about projected supply, storage, and pricing of CFE, though respondents also may choose to submit information in a narrative format. The RFI also invites respondents to address their management of Renewable Energy Certificates (RECs) and other CFE accounting mechanisms, as well as the associated price of this tracking and certification process.
Interested respondents have the opportunity to submit questions about the RFI by February 25, and the deadline for responses is currently March 7, 2022.
 Carbon pollution-free electricity means “electrical energy produced from resources that generate no carbon emissions, including marine energy, solar, wind, hydrokinetic (including tidal, wave, current, and thermal), geothermal, hydroelectric, nuclear, renewably sourced hydrogen, and electrical energy generation from fossil resources to the extent there is active capture and storage of carbon dioxide emissions that meets EPA requirements.” E.O. 14057, 86 Fed. Reg. 70935, 70942 (Dec. 13, 2021).
 PJM (includes 13 states and D.C.), Electric Reliability Council of Texas (ERCOT), Independent System Operator New England (ISO-NE), Midcontinent ISO (MISO), and New York ISO (NYISO).