Supporting Federal Agency Procurement of Carbon Pollution-Free Electricity

In 2022, the federal government established aggressive carbon pollution-free electricity goals that require agencies to procure 100 percent of their electricity from CFE sources on an annual basis, and 50 percent on an hourly basis by 2030. Federal agencies face many challenges in meeting these goals. For example, the CFE requirements are new to many agencies and stringent regarding the location, type, and placed-in-service date for electricity generators. Many federal agencies use decentralized utility procurement approaches, creating a lack of standardization and transparency. In addition, reliable utilities are critical to operational continuity but also a major cost center facing budget pressures due to increased electricity rates. Federal agencies need integrated strategies to meet the CFE requirements while also addressing these other challenges.  

ERG has been helping the U.S. Environmental Protection Agency and U.S. Department of Justice headquarter offices develop CFE strategies. We began by offering education and training on CFE requirements to headquarters, component, and facility staff. Building on existing agency renewable energy certificate procurements, our team demonstrated how generation resources must meet “additionality” criterion to be considered CFE and how CFE can provide cost certainty in the face of electricity rate escalations. We also outlined how U.S. General Services Administration areawide utility contracts can be used to transition to CFE. For DOJ, we established a Decarbonization Working Group to support ongoing coordination. In addition, ERG has been providing direct support for individual EPA and DOJ CFE initiatives, annual reporting for CFE procurements and on-site generation, strategy development, and goal setting through 2030. We have also researched CFE offerings and coordinated with electric utilities that serve EPA and DOJ facilities across the United States, prioritizing utilities that serve the largest agency loads. In addition, as part of climate resilience assessments we conduct for EPA, we identify opportunities for on-site CFE to increase the electricity supply resilience and to mitigate operational disruptions due to climate change.