RFI PMPB01.2023CFE.pdf

Request for Information – Retail Supply of Carbon Pollution-Free Electricity

1. Introduction

The U.S. General Services Administration (GSA) is one of the primary agencies responsible for procuring electricity for the Federal Government based on its authority under 40 U.S.C. § 501(b) to enter into contracts for public utility services. Under this authority, GSA procures utility services for not only GSA facilities but also other Federal agencies and non-governmental organizations. GSA intends to use the information provided as a result of this Request for Information (RFI) in support of the goals expressed in Section 203 of Executive Order (E.O.)

14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability (December 8, 2021). This E.O. sets a goal for the Federal Government of achieving 100% carbon pollution-free electricity (CFE) by 2030, including 50% 24/7 CFE.

In March 2022, GSA and the U.S. Department of Defense published a joint RFI with the following objectives:

● Demonstrate intent to achieve targets set by E.O. 14057 using a whole-of-government approach;

● Understand ability of industry to supply the scale of CFE needed, and gather indicative pricing information based on increments of scale; and

● Gather information from industry on potential approaches to and key considerations for meeting the targets set by E.O. 14057.

This RFI intends to build on that request following the issuance of the E.O. 14057 Implementing Instructions, released in August 2022, which provide Federal executive departments and agencies with direction for implementing E.O. 14057.

The information received from this RFI will help GSA develop procurement strategies that may be implemented as soon as Fiscal Year 2023 (FY23).

2. Purpose of this RFI

The purpose of this RFI is to obtain relevant information regarding the availability of CFE in the retail electricity market and ways for the Federal Government to incentivize additional production and delivery of CFE. Pursuant to the Implementing Instructions, CFE 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 Environmental Protection Agency (EPA) requirements (Sec. 603(d) of E.O. 14057).

To count toward the Federal Government’s goal of achieving 100% CFE by 2030, Energy Attribute Certificates (EACs) must be sourced from generation resources that:

● Produce CFE (based on the above definition);

https://www.whitehouse.gov/briefing-room/presidential-actions/2021/12/08/executive-order-on-catalyzing-clean-energy-industries-and-jobs-through-federal-sustainability/ https://www.sustainability.gov/pdfs/EO_14057_Implementing_Instructions.pdf https://www.sustainability.gov/pdfs/EO_14057_Implementing_Instructions.pdf

● Were placed in service on or after October 1, 2021, either as a new resource or as new capacity at an existing resource modified to increase output1; and

● Deliver CFE to the same Balancing Authority of Federal facility consumption.

An EAC is an instrument that conveys information (attributes) about a unit of energy, including the resource used to create it, and the emissions associated with its production and use. A renewable energy certificate, or REC, is a type of EAC where the unit of measure is one MWh.

There are 66 balancing authorities in the U.S. For purposes of this RFI, GSA’s retail electric supply contracts serve customers in the CAISO, ERCOT, ISONE, MISO, NYISO and PJM balancing authorities. These are the balancing authorities for which we are requesting CFE information. GSA seeks to tie CFE supply generated within each of these balancing authorities to the retail electric accounts it buys for in each of these balancing authorities. Table 1, below, provides a projection of GSA’s total annual kWh load by balancing authority for its entire current retail electric buy portfolio (which includes other Federal agencies for which GSA purchases electricity) including planned FY23 buys.

Table 1: GSA’s Total Retail Electric Portfolio by Balancing Authority

Balancing Authority Projected Annual kWh Load

CAISO 56,368,199

ERCOT 378,700,723

ISONE 242,678,790

MISO 54,484,579

NYISO 354,256,301

PJM 2,976,587,311

Grand Total 4,063,075,902

GSA’s expectation is that CFE procured through retail electric supply contracts will work similarly to GSA’s current retail electric supply contracts that include voluntary RECs. In those contracts, GSA specifies the percentage of voluntary renewable energy it requires and awards a fixed per kWh price to the supplier to include both energy supply and RECs. The contracts include specific attestation and reporting requirements where the supplier must verify the type, generation source and number of RECs retired on behalf of the Federal Government.

3. Requested Information

1 Note that this in-service date requirement does not apply to Grid-Supplied CFE.

* In submitting your response, please number your answers with which question you are answering, for example: Question 1.

1. What is your company or organization name, point of contact, telephone number, and email address?

2. Retail Electric Supplier Defined:

a. For purposes of this RFI, a retail electric supplier sells electricity from generation to an end-use consumer as a final sale. Based on this definition, are you a retail electric supplier (for residential, commercial, or utility scale) or other (specify)?

Describe your business in a few sentences, to include how many years your company or organization has provided these services, the average size load you supply on an annual basis, and whether or not you have been awarded previous government contracts.

3. As part of your retail supply portfolio, do you currently offer CFE from generation placed in service on or after October 1, 2021, either as a new resource or as new capacity at an existing resource modified to increase output?

a. If so, what kind of CFE do you offer (i.e., wind, solar, 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 Environmental Protection Agency (EPA) requirements (Sec. 603(d) of E.O. 14057)).

b. If so, approximately how much CFE (in kWhs or MWhs), available at the time of the closing of this RFI, are you able to offer on an annual basis?

c. CFE must be delivered to the same balancing authority of Federal facility consumption. Balancing authority, also known as Control Area, is an electric power system or combination of electric power systems bounded by interconnection metering and telemetry to which a common generation control scheme is applied. For example, ERCOT operates as one balancing authority.

Do you know your balancing authority or authorities? If so, in which balancing authorities do you offer CFE? The respondent may choose to use Table 2 below to structure their response as useful, or to supply information from the table in narrative format.

4. How could Grid-Supplied CFE be measured and accounted for within a retail electric contract? (Grid-Supplied CFE is CFE delivered in the electricity grid mix, including CFE from existing generation that complies with state renewable portfolio or clean energy standards.)

a. Could EACs be obtained and retired for all Grid-Supplied CFE?

b. Should there be a maximum level of Grid-Supplied CFE determined in a retail electric contract to ensure that the Federal Government is not claiming CFE that other electricity consumers might claim?2

c. What challenges or risks may be posed in a retail electric contract that includes both Grid-Supplied CFE and CFE from generation placed in service after October 1, 2021?

5. Can you provide bundled CFE (EACs that are sold with their associated energy) to the Federal Government through a retail electric contract?

a. If you answered “yes” to the above question, specify whether you could increase the percentage of CFE you offer in future years if GSA enters into long-term supply contracts such as 60 to 120 month contracts.

6. Can you provide any indicative pricing information for CFE in relation to the loads and balancing authorities described above?

7. Does your firm currently have the capability to track and report on CFE, as described in E.O. 14057 and this RFI?

8. If you offer CFE, what type of EAC and documentation, if any, can you provide to the Federal Government confirming retirement?

9. Approximately how many months does it take from the production of CFE to produce an EAC? Specify the unit of measure for the CFE (kWh, MWh, etc.).

10. A NERC e-Tag from an eligible specified generation source may be used as a proxy EAC for CFE from a non-renewable energy resource that is sourced outside the applicable Balancing Area and delivered into the Balancing Area provided that the load serving entity purchasing this CFE generation must be identified as recipient in the e-Tag and the applicable Balancing Area must be identified as the delivery point in the e-Tag.

Are you familiar with NERC e-Tags? Can you provide NERC-eTags for CFE delivered to a balancing authority where it was not originally produced?

11. Are you currently or are you in the process of planning to design or construct CFE-generation facilities within the next two, three, or five years? If so, please explain.

12. In order to purchase CFE directly from you (outside of retail electric supply contracts), would GSA be required to enter into any Power Purchase Agreements with your company and/or project developers and financiers? If so, explain. If an alternative form

2 In vertically integrated utility markets, for example, Grid-Supplied CFE could be limited to the Federal Government’s load ratio share of CFE from a utility’s existing resource portfolio.

of procurement contract (e.g., a specialized customer rate/tariff or a “sleeved PPA”) is required, please provide this detail and an associated explanation.

13. Please describe the different term lengths available for delivery of CFE that meets the requirements of E.O. 14057. For example, are 1-year, 3-year, 5-year, or 10-year purchase agreements available? Please describe any price trade-offs associated with different term lengths.

14. Expanding on the above question, what, if any, connection and/or transmission challenges does your business face when procuring CFE in relation to timelines for project permitting and approval, ISO/RTO/utility approval of new projects and supply-chain challenges?

15. Keeping in mind the above requirements for CFE, is there any particular quality that makes it more challenging for you to offer (i.e., a new resource that achieved commercial operation after October 1, 2021; must emit no carbon emissions; produced in or delivered to the same balancing authority as the government facility)?

16. What opportunities, if present, would encourage your business to invest in additional CFE offerings?

Table 2: CFE Offering*

Balancing Authority: [RTO/ISO]

Target supply quantity range: [GWh annually]

Contract start date: [MM/DD/YYYY]

2023 2024 2025 2026 2027 2028 2029 2030

CFE amount delivered (GWh)

Of the total amount, indicate the expected % from different sources. Note: % should sum to 100%.

Wind (%)

Solar (%)

Other CFE (%, type of CFE)

Total estimated capacity (MW)

Wind (MW)

Solar (MW)

Other CFE (MW, type of

CFE)

Price range ($/MWh)

Describe location of supply

CFE capacity that is new or additional to the grid (% of total estimated capacity;

preference for CFE supply to be from new or previously underutilized generation sources)

For this portfolio, describe what type of RECs or other CFE claims are included and any associated price. [Fill in answer here]

* Updated responses requested from RFI # S P 0 6 0 4 - 2 2 - 0 4 1 1

4. Response Guidelines

1. Response Format: Interested parties are requested to respond to this RFI by completing and submitting the requested information identified in Section 3, in both Portable Document Format (PDF) and Excel for Office 2000 compatible format. The response is limited to 20 single-sided pages (12-point font Arial, 1-inch margins).

2. Submission: Your response must be provided no later than 5:00 pm EST on Friday, March 3, 2023. To respond to the questions below, please complete this questionnaire and submit your responses as instructed by this notice. You are not required to answer all of the questions; however, we ask that every respondent answer questions 1 and 2.

3. Request for Information only, not Request for Proposal: This RFI is issued solely for information and planning purposes – it does not constitute a RFP or a promise to issue a RFP in the future. This RFI does not commit the Federal Government to contract for any supply or service whatsoever. Further, the Federal Government is not at this time seeking proposals and will not accept unsolicited proposals.

Respondents are advised that the Federal Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the interested party’s expense. Not responding to this RFI does not preclude participation in any future RFP, if any is issued. If a solicitation is released, it will be synopsized on the SAM.gov website. It is the responsibility of the potential offerors to monitor this website for additional information pertaining to this requirement.

4. Industry Discussions: GSA will hold a call at 11:00 AM EST on Friday, February 9, 2023, to provide RFI respondents the opportunity to ask any clarifying questions regarding this RFI. The call-in number is 1-484-841-4066, passcode 844 555 266#. GSA will post answers to the questions received no later than 5:00 pm EST on Friday, February 16, 2023.

5. Questions: Questions regarding this announcement shall be submitted in writing by e-mail to CFESupport@gsa.gov no later than 5:00 pm EST on Friday, February 23, 2023. Please address the email subject line as, “RFI: PMPB01-2023CFE Company Name.” Oral questions will NOT be accepted.

6. Summary: THIS IS A REQUEST FOR INFORMATION ONLY to identify sources that can provide carbon pollution-free electricity to the Federal Government. The information provided in the RFI is subject to change and is not binding on the Federal Government. The Federal Government has not made a commitment to procure any of the items discussed, and release of this RFI should not be construed as such a commitment or as authorization to incur cost for which reimbursement would be required or sought. All submissions become Federal Government property and will not be returned.

mailto:CFESupport@gsa.gov