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The U.S. General Services Administration (“GSA”) recently released a Request for Information (“RFI”) seeking input from industry to help the federal government develop strategies for the procurement of carbon pollution-free electricity (“CFE”) in accordance with Executive Order 14057’s goal of achieving 100% CFE for the federal government by 2030. The RFI seeks to gather information about the “availability of CFE in the retail electricity market and ways for the Federal Government to incentivize additional production and delivery of CFE.”

CFE is defined as “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.

press release posted the same day as the RFI notes that GSA is one of the largest purchasers of energy for the federal government and is seeking to use the government’s buying power to make long-term investments and “spur demand” for CFE. GSA will use the RFI responses it receives to formulate upcoming solicitations nationwide.

The RFI requests CFE information related to six specific balancing authorities (CAISO, ERCOT, ISONE, MISO, NYISO, and PJM) and includes a series of 16 questions regarding CFE offerings, production, measurement, tracking, reporting, pricing, contracting methods, and challenges. It also requests information regarding respondents’ future plans to design and construct CFE-generation facilities as well as input on the types of opportunities that would encourage a business to invest in additional CFE offerings.

Responses to the RFI are due by 5:00 pm EST on Friday, March 3, 2023. GSA will hold an industry discussion call at 11:00 am EST on Thursday, February 9, 2023, to allow respondents to ask any clarifying questions. Written questions may be submitted by 5:00 pm EST on Thursday, February 23, 2023.

For additional information, see the joint RFI published by GSA and the Department of Defense in February 2022 and the E.O. 14057 Implementing Instructions published by the White House Council on Environmental Quality in August 2022.

Sheppard Mullin’s Government Business Group provides tailored, thoughtful guidance to members of the Government Business Industry. With decades of experience guiding hundreds of large and small businesses through their interactions with the Federal Government, the Sheppard Mullin GBG can help both commercial businesses and aerospace and defense companies deal with the novel and complex regulatory scheme imposed by the Federal Government.