The Biden administration wants to buy more than 2.7 million MWh of carbon-free electricity (CFE) per year to power hundreds of federal and military facilities across the 13 states served by PJM, according to a request for information jointly issued by the General Services Administration and Department of Defense on Feb. 9. 

The RFI also sets out an ambitious timetable for the procurement, which it describes as “one of the federal government’s largest-ever clean electricity purchases.” The official request for proposals could go out in May, with awardees announced in September and the first clean electrons going online by the end of the year.  

In line with President Joe Biden’s 2021 executive order establishing a 100% clean energy goal for federal facilities by 2030, GSA and DOD are looking to make half of the CFE procurement matched hour for hour with demand on a 24/7 basis.  

With over 300,000 buildings, the U.S. government is the nation’s largest energy consumer and “a steady customer prepared to make long-term investments,” GSA Administrator Robin Carnahan said in the RFI press announcement. “We’re using the government’s buying power to spur demand for clean, carbon pollution-free electricity, and we’re partnering with industry to drive toward the triple win of good jobs, lower costs for taxpayers and a healthier planet for future generations.” 

Brendan Owens, assistant secretary of defense for energy, installations and environment, stressed the link between clean energy and national security, and DOD’s leadership in “greening federal government operations.”  

“Today’s announcement will help facilitate grid transformation to address the climate crisis and to provide clean, reliable and affordable electricity that ensures mission resilience for DOD operations,” Owens said. 

The RFI specifies that the government is looking to procure the CFE through retail electricity contracts rather than traditional power purchase agreements. Contracts could be for up to 10 years, with fixed per-kWh prices.  

Critically, the government is only interested in retail contracts for “bundled CFE,” which means “the original associated energy attributes have not been separately sold, transferred or retired,” according to the RFI. Renewable energy certificates (RECs) are the most used measure of clean energy attributes, with each REC certifying that 1 MWh of new wind or solar energy has been put on the grid.  

“Unbundled” RECs or similar energy attribute certificates (EACs) can be sold separately from the power that produced them. Solar installers may sell them to bring down the costs of an installation, and utilities or other companies often buy them to meet state-level clean energy mandates, passing on the cost to customers through increased rates. 

In other words, the Biden administration wants to make sure that the EACs for any clean electricity used to power federal facilities will not be sold for profit or used as a substitute for putting additional, clean energy on the grid.  

The RFI specifically asks that retail electricity suppliers be able to track and document that that any bundled CFE does not include EACs that have previously been counted for a state renewable portfolio standard. Companies are also expected to be able to track and report how much of the CFE provided is matched hour for hour with demand.  

1 Million MWh for BGE

The RFI does not list the federal or military facilities to be powered with CFE or their locations, but it does provide some hints. 

GSA intends to include 650 accounts in the solicitation, with contracts possibly awarded in phases. 

The RFI also provides a list of the megawatt-hours the government will need in the service territories of each of the investor-owned utilities in the PJM states. Baltimore Gas and Electric leads the list with 1,031,740 MWh. The massive military base at Fort Meade is part of the utility’s service territory. 

Commonwealth Edison comes second, with 403,774 MWh, while 201,297 MWh will be needed for Pepco’s service territory, which includes the high concentration of federal buildings in Washington, D.C.  

All three utilities are owned by Exelon Corp., which also owns Delmarva Power (1,381 MWh) and Atlantic City Electric (2,273 MWh). How will Exelon and other utilities handle the additional clean power this procurement could produce? 

In a statement emailed to RTO Insider, Exelon said it has been “modernizing our [transmission and distribution] assets over the last decade, allowing us to continue delivering safe, reliable, affordable energy to our customers even with a growing share of renewable and distributed energy resources.” 

Exelon’s long-range plan calls for $31 billion in investments “to strengthen our infrastructure — both physical and IT — to prepare our assets for an influx of renewable energy sources. … When these sources are built — we will be ready to deliver the energy.” 

GSA does recognize that the size and scope of the procurement may mean it will have to be rolled out in phases, and the agency may not be able to get all the clean energy it wants at the time contracts are awarded. The RFI notes that “GSA is considering including minimum CFE requirements describing how much bundled CFE can be delivered and when.” 

In such cases, “it is anticipated that contractors will be required to provide traditional retail electricity supply to meet [GSA’s] requirements,” the RFI says. 

A key question is how much new clean electric power will be needed to meet the government’s procurement targets. The RFI specifically says any clean power that has come online since Oct. 1, 2021, could be awarded a contract. 

In addition, beginning in July, PJM began its new “first-ready, first-served” interconnection process aimed at clearing a backlog of 260,000 MW from its interconnection queue.  

According to a year-end post on the RTO’s website, it estimates it will be able to clear 300 projects totaling 26,000 MW for interconnection this year. However, the overlap between the PJM queue and the federal procurement could be minimal as the RFI differentiates the bundled CFE it wants to purchase from “grid-supplied” CFE. 

The comment period on the RFI will run through March 18. GSA is holding an “industry day” Feb. 20 to talk about the RFI with retail electricity suppliers and other stakeholders. For more information, email CFESupport@GSA.gov.