Amendment 0001_1305M426Q0047.pdf

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UNITED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

ACQUISITION AND GRANTS OFFICE

Questions and Answers for NOAA Renewable Energy Certification (RECs)

RFQ: 1305M426Q0047

1. We are a small business considering submission as the prime contractor, with an established Green-e®

Energy-certified REC supplier serving as a subcontractor. Please confirm whether NOAA considers this requirement a supply acquisition subject to the SBA nonmanufacturer rule and, if so, whether the prime contractor may satisfy the requirement using RECs supplied by a large-business subcontractor.

NOAA: No. Procurements under NAICS 221114 and 221115 are utility services, exempting them from the Nonmanufacturer Rule. Yes. Since the NMR does not apply, a small business prime contractor is permitted to partner with a large-business Green-e® Energy-certified REC supplier. The prime contractor must comply with FAR 52.219-14 (Limitations on Subcontracting) for service contracts. Under this clause, the prime cannot pay more than 50% of the total amount paid by the Government for contract performance to subcontractors that are not "similarly situated entities" (i.e., non-small businesses).

2. Must the successful prime contractor be the Green-e® Energy-certified seller of record, or may the certification be held by its REC supplier or subcontractor?

NOAA: Green-e® certification is not a requirement under this SOW. As long as the prime contractor ensures that the underlying RECs satisfy Section 2.0 (Technical Requirements) and delivers the required attestations and tracking system transfers under Section 3.0, utilizing a subcontractor or supplier to source and verify the RECs fully complies with this SOW.

3. Must the prime contractor maintain its own REC tracking-system account, or may the subcontractor transfer and retire the RECs through its account on NOAA’s behalf?

NOAA: The prime contractor is not required to own or maintain its own tracking-system account, provided the required deliverables are completed on NOAA’s behalf. The Prime must still deliver a signed statement certifying exclusive attribute ownership for NOAA and guaranteeing no double-counting. The subcontractor must provide the tracking system transfer/retirement confirmation report containing the required metadata (Facility Name, Commercial Operation Date, and NERC Region). A formal Confirmation of Retirement Certificate issued out of the subcontractor's account listing NOAA as the beneficiary.

4. Must the prime contractor take legal title to the RECs before they are transferred or retired for NOAA?

NOAA: No, the prime contractor does not need to take legal title to the RECs prior to transfer or retirement. The requirement is to ensure the Agency (NOAA) receives clean, exclusive, unencumbered ownership of the environmental attributes—not that the Prime held title at an intermediate step. The Prime must sign and submit the required Attestation of Ownership to NOAA, certifying that the Agency holds sole legal claim to the attributes and no double-counting has occurred.

5. REC Transfer Versus Retirement: The SOW references both transfer and retirement, but it does not clearly identify the designated registry account, retirement beneficiary, retirement language, or party responsible for final retirement. Will NOAA require the Contractor to transfer the RECs into a NOAA-controlled tracking-system account, retire the RECs on NOAA’s behalf, or complete both actions?

NOAA: NOAA does not maintain active, paid subscriber accounts in regional REC tracking systems. NOAA relies on the contractor/supplier to perform a direct retirement on their behalf inside the contractor's registry account. The standard mechanism (Direct Retirement on Behalf):

● The contractor/supplier generates/buys the 10,409 MWh of RECs in their registry account.

● The contractor moves those RECs to the registry's Retirement Account.

● The registry prompts for beneficiary details. The contractor inputs:

○ Beneficiary: National Oceanic and Atmospheric Administration (NOAA)

○ Reason for Retirement: FY 2026 Statutory Compliance under EPAct 2005 / E.O. 14148

● The registry issues an official Certificate of Retirement.

6. Eligible REC Vintage and Production Period: The solicitation requires facilities to have entered commercial operation on or after January 1, 2011, while also establishing an REC production window of April 1, 2025, through January 1, 2027. The Agency should clarify how those two eligibility requirements will be validated. Please confirm the precise eligible generation period and whether January 1, 2027, is an inclusive or exclusive end date. May RECs generated after the quotation date but before the stated deadline be proposed?

NOAA: Under Federal Energy Management Program (FEMP) guidelines, facilities placed into service within 15 years prior to the start of the reporting fiscal year qualify. A COD on or after January 1, 2011, directly satisfies this statutory rule for FY 2026 reporting. FEMP rules define the eligible generation window for a given fiscal year as 6 months prior to the start of the fiscal year through 3 months after the end of the fiscal year. For FY 2026 (Oct 1, 2025 – Sept 30, 2026), the official window is exactly April 1, 2025, through January 1, 2027. Because final retirement is required by December 15, 2026 (Section 4.0), the practical generation cutoff for your proposed RECs will be generation month October or November 2026 to allow time for tracking registry minting, transfer, and retirement before the December 15 deadline.

7. Acceptable Tracking Systems and Supporting Records: The solicitation identifies recognized electronic tracking systems but does not specify the required report format, serial-number detail, retirement certificate, or account-transfer procedure. Are WREGIS, M-RETS, NEPOOL GIS, GATS, and NAR all equally acceptable, and what specific registry reports or certificates must be submitted to demonstrate transfer, retirement, ownership, and absence of double counting?

NOAA: Under FEMP (Federal Energy Management Program) guidelines and federal sustainability practices, all five registries are equally recognized for verifying domestic green power claims. The location of your chosen generation facility naturally dictates which registry will issue and track the RECs.

A closeout deliverable package consisting of:

Official Registry Certificate/Report (Task 3.1 & 4.0): An automated export directly from the tracking platform (e.g., M-RETS Retirement Report or NAR Transfer Confirmation). This document confirms the 10,409 MWh quantity, the transfer/retirement date (before Dec 15, 2026), and lists NOAA as the owner or beneficiary.

Facility Metadata & Serial Ranges (Task 3.3): Registry reports natively output summary batch details including the Generator ID, Facility Name, Fuel Type (e.g., Solar/Wind), COD (verifying post- Jan 1, 2011), NERC Region, and the starting/ending serial numbers for the batch. Summary reports with starting/ending serial number ranges are universally accepted over multi-page printouts of individual serial numbers.

Contractor Attestation (Task 3.2): A signed statement on company letterhead confirming that the environmental attributes represented by the 10,409 RECs have been transferred/retired exclusively for NOAA, have not been separately sold or pledged, and have not been used toward any state Renewable Portfolio Standard (RPS).

8. Geographic and Generation-Source Preferences: The requirement permits several renewable-energy resource types and requires U.S.-based generation, but it does not explain whether location, technology, regionality, or grid proximity will affect technical acceptability or source selection. Does NOAA have a preference for a particular renewable technology, state, NERC region, balancing authority, or geographic delivery area within the United States?

NOAA: As long as the RECs meet Section 2.0 criteria (U.S.-based, eligible resource type, post-2011 COD, FY 2026 production window, and registry tracking), a proposal offering national wind or solar from any NERC region is 100% technically acceptable.

Standard Off-Grid / National RECs: 1 REC = 1.0 MWh toward federal targets.

On-Site / Federal Land RECs: Under Section 203 of EPAct 2005 (42 U.S.C. § 15852(c)), renewable energy produced on federal land, on-site at a federal facility, or used on a federal facility receives a 2.0x evaluation/compliance credit (i.e., 1 MWh counts as 2 MWh toward statutory goals).

9. On-Site and Federal-Land Generation Multiplier: The solicitation states that preference will be given to qualifying generation but does not define the evaluation methodology. How will the stated preference and

2.0 multiplier for on-site or federal-land generation be applied during evaluation and contract performance? Does the NOAA multiplier: Reduce the physical quantity of RECs that must be delivered;

Provide evaluation credit only; Apply only to specific qualifying projects; or Require separate documentation from the generating facility.

NOAA: Does it reduce physical REC delivery? NOAA’s goal is to satisfy an underlying 10,409 MWh statutory target; buying 5,205 MWh of 2.0x RECs achieves the full target. Is it evaluation credit only? No. The multiplier is a statutory accounting mechanism under EPAct 2005, not just a subjective "bonus point" system in source selection. Does it apply only to specific projects? Yes. It applies strictly to projects located on designated Federal real property, Federal public lands, or behind-the-meter at a Federal facility. Is separate documentation required? It is dependent on the registries (like NAR or M-RETS) whether it is tagged federal land. You will need proof from the generator (e.g., BLM land lease, federal facility PPA/interconnection agreement, or specific generator ID metadata) to submit with Task 3.3.

10. Pricing and Award Methodology: Should offerors provide one all-inclusive firm-fixed unit price per MWh, and must that price include registry charges, transfer fees, retirement costs, documentation, and all other transaction expenses?

NOAA: Yes. Under standard Federal Acquisition Regulation (FAR) procedures for Firm-Fixed-Price (FFP) contracts, offerors must provide a single, all-inclusive unit price per MWh.

11. Pricing and Award Methodology: Please confirm: Whether award will be made on a lowest-price technically acceptable basis; Whether non-price factors will be evaluated; Whether pricing must be provided by batch, technology, registry, or generation source.

NOAA: Because non-price factors are binary (acceptable or non-acceptable), the offeror meeting all Section 2.0 criteria with the lowest total extended price will win the award.

12. Offeror Eligibility and Required Quote Documentation: May a qualified REC broker, marketer, aggregator, or small-business reseller compete if it does not own or operate the underlying renewable-generation facilities?

NOAA: Yes. A qualified REC broker, marketer, aggregator, or small-business reseller may compete even if it does not own or operate the underlying generation facilities.

13. Can you advise if there were/are incumbent provider(s) for these services? If Yes – Who is/are the incumbent(s), and can you provide a previous contract number?

NOAA: The previous incumbent was GreenLight Energy Group, LLC., award 1364GC24C0002.

14. If there is an incumbent, is there a reason the known incumbent may be precluded from bidding on this new or existing requirement?

NOAA: No. Incumbent is not precluded from bidding.

15. We would like to know if this is a brand new contract OR if there is (was) an incumbent performing these services.

NOAA: This is a new requirement meeting federal statutory compliance for 2026.

16. If not brand new, could you please provide the current / previous contract number?

NOAA: Refer to #13