GENERAL SERVICES ADMINISTRATION
[Notice MVAC-2022-01; Docket No. 2022-0002; Sequence No. 23]
Notice of Request for Information on Photovoltaic Systems
AGENCY: Office of Acquisition Policy, General Services
Administration (GSA).
ACTION: Notice; request for information (RFI).
SUMMARY: The General Services Administration (GSA) is seeking
information from industry on the availability of domestically
manufactured solar photovoltaic (PV) panels and components and
feasibility of requiring the use of such PV panels and
components for future projects.
DATES: Interested parties should submit comments to the address
shown below on or before [INSERT DATE 60 DAYS AFTER DATE OF
PUBLICATION IN THE FEDERAL REGISTER].
ADDRESSES: Comments to the RFI must be provided in writing.
Interested parties are to submit their written comments
electronically to https://www.regulations.gov. Submit comments
via the Federal eRulemaking portal by searching for “RFI
Photovoltaic Systems”. Select the link “Comment Now” that
corresponds with the RFI and follow the instructions provided on
the screen. Please include your name, company name (if any), and
“RFI Photovoltaic Systems” on your attached document. If your
comment cannot be submitted using https://www.regulations.gov,
call or email the points of contact in the FOR FURTHER
INFORMATION CONTACT section of this document for alternate
instructions.
You are not required to answer all of the questions in the RFI,
but the more information we receive, the better GSA’s

understanding of the domestically manufactured solar panel and/or
components market.
Comments received generally will be posted without change to
https://www.regulations.gov, including any personal and/or
business confidential information provided. To confirm receipt of
your comment(s), please check https://www.regulations.gov
approximately two-to-three days after submission to verify
posting.
FOR FURTHER INFORMATION CONTACT: Ms. Adina Torberntsson,
Procurement Analyst, at gsarpolicy@gsa.gov, for clarification of
content. For information pertaining to status or publication
schedules, contact the Regulatory Secretariat at 202-501-4755 or
gsaregsec@gsa.gov. Please cite RFI Photovoltaic Systems.
SUPPLEMENTARY INFORMATION:
Purpose
To obtain relevant information from domestic commercial PV panel
and system component manufacturers and resellers, PV panel
purchasers and installers, and renewable electricity providers,
including small businesses.
The information received will help GSA develop a procurement
strategy, to potentially include a procurement standard for use
in future solicitations where the use of PV panels and
components are required.
GSA intends to use the information generated from 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), as well as the White House Fact Sheet,

titled President Biden Takes Bold Executive Action to Spur
Domestic Clean Energy Manufacturing (June 6, 2022).
GSA seeks to learn more from industry regarding the use of
domestically manufactured PV panels and components in contract
types including: Power Purchase Agreements (PPA), Energy Savings
Performance Contracts (ESPC), Utility Energy Service Contracts
(UESC), solar array development contracts, and other acquisition
vehicles depending on future need. This RFI is also being issued
in anticipation of future projects that may be funded by the
Inflation Reduction Act (IRA) (Pub. L. 117-169). GSA is
particularly interested in the impacts of this initiative on
underserved or disadvantaged communities.
This RFI is for general fact-gathering purposes. Interested
parties will not be reimbursed for any costs related to
providing information in response to this RFI. The Government
does not intend to award a contract on the basis of this RFI.
Requested Information from Industry
In submitting your response, please number your answers with
which question you are answering, for example: Requested
Information Specific to Manufacturing 2(a)(i).
For purposes of organizing the data received, please provide the
following information in your response:
●

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

●

What is the nature of your company or organization?
â—‹

Are you a solar panel or component provider,
manufacturer, re-seller, or retailer (for residential,
commercial, or utility scale); developer, utility
company, or other (specify)?

â—‹

Describe your business in a few sentences, to include
how long your company or organization has provided
these services.

●

What is your company or organization's primary North
American Industry Classification System (NAICS) code?
â—‹

The NAICS code for photovoltaic cell manufacturing is
334413, Semiconductor and Related Device
Manufacturing. If you operate under a different NAICS
code for other elements of this RFI please provide
your primary NAICS code.

●

With your primary NAICS code in mind, what is your
company’s size status, is your company a large or small
business?
â—‹

As defined by the Small Business Administration, the
size standard to qualify as a small business for NAICS
code 334413 is fewer than 1,250 employees.

â—‹

What, if any, small business socio-economic categories
apply to your business, such as Small Disadvantaged
Business, Woman-Owned Small Business, Veteran-Owned
Small Business, Service-Disabled Veteran-Owned, or
Historically Underutilized Business Zone?

Requested Information Specific to Manufacturing
1. Is your company an established PV panel or component
manufacturer (defined for the purposes of the RFI as the panel
or component being in commercial production for 2 or more
years)?
2. Does your company or organization manufacture PV panels or
system components for the arrays domestically?

a. If yes, please provide a brief description to include the
place of manufacture and where in the supply chain your
product falls, i.e., do you manufacture a component or
assemble the final panel system or components?
i.

What is your company’s production capacity of
domestically manufactured solar panels?

ii.

Are you anticipating an increase or decrease in
production capacity in the next 10-year timeframe? Why
or why not?

b. From which countries do you or your suppliers source the
majority of the raw materials for the PV panels or
components?
i.

Please provide the countries of origin for each major
component if purchased outside of the U.S.

ii.

Please describe current traceability tools and how
effective they are.

iii. Has your due diligence in monitoring your supply chain
changed as a direct result of the Uyghur Forced Labor
Prevention Act (UFLPA)? Is implementation of the UFLPA
a help or hindrance to domestic manufacturing?
iv.

Do you have capacity to trace and certify that your
products meet the component test for manufactured
goods of 55% called out in the Infrastructure
Investment and Jobs Act (IJA) and 55%, incrementally
increasing to 75% over time, for federal procurements?

v.

With recent legislative changes, are there now more
mechanisms to trace the country of origin for the
components? Please describe.

3.

Has your company experienced availability, quality,
workability, or durability challenges with PV panels and/or
components?
a. Have you seen any differences in the availability,
quality, workability, or durability between PV panels
manufactured foreignly or domestically?
b. Are there good examples of quality assurance and quality
control procedures/programs for PV panels or components
that you trust?

4.

If your company has been in panel/component commercial
production for fewer than two years, please disclose which
part of the domestic PV supply chain your company will
support.

5.

It is our understanding that there are primarily two types
of panels commercially available: crystalline silicon and
tellurium. Is your firm developing or close to
commercializing new panel technology outside of these two
types?

6.

Please provide as many details as you can in response to
the questions listed below:
a.

What is the rated wattage of your PV panels?

b.

What is the efficiency rating of your PV panels?

c.

What is the weight of your PV panels?

d.

What type of warranty do you offer for your PV panels?

e.

What is the product warranty period for your PV
panels?

f.

What is the power warranty after 25 years of
operation?

g. Do you have embodied carbon product declarations (EPDs)
for the panels that you produce or sell? If yes, how is
this calculated and are shipping logistics included?
h. Do you perceive a difference in efficiency expectations
between residential, commercial, and utility-scale PV
panels, and if yes what is the difference?
7.

What steps would be needed to increase circularity (or
recyclability) in the PV manufacturing sector?
a.

What are roadblocks to circularity/recyclability in
the PV industry and are those barriers alleviated with
federal subsidies?

b.

Describe your recycling process for PV panels or its
components (if any). What technology is needed in
order to improve on recycling?

Requested Information Specific to Installers
8.

Is your company or organization taking action to source
domestically manufactured PV panels and/or components?
a.

If yes, what actions are you taking and why are you
taking those actions?

9.

Other than the price, are there other obstacles to sourcing
domestically made PV panels and/or components?
a.

Are there obstacles to identifying skilled labor to
complete the installations?

10.

Has your company or organization experienced availability,
quality, workability, or durability challenges with PV
panels and/or components?
a.

Have you seen any differences between foreign and
domestic products for PV panels and system components?

Requested Information Specific to Developers

11.

If you are a developer who anticipates construction of new
solar generation facilities in the next five years, what
barriers can you identify to using domestically
manufactured PV panels and/or components?
a.

Are there state laws or regulations preventing energy
providers from requiring domestically made PV panels
and components?

12.

What opportunities, if present, would encourage use of
domestically manufactured PV panels and/or components for
such generation facilities?
a.

Is your company aware of any disruptive technologies
that could render current PV panels and/or components,
or system designs outdated or incompatible with
existing systems?

Requested Information on Market Availability
13.

What are the technical, economic, logistical, or regulatory
obstacles that exist to domestically manufacturing PV
panels or purchasing renewable energy as a commodity? Does
the IRA resolve any of these obstacles for your company?

14.

How will the IRA and potentially more federal opportunities
for use of domestically manufactured PV panels or
components help you expand or increase your rate of growth?
Are there other initiatives or factors that impede or spur
growth in this area? How will the IRA impact the purchase
of power versus the PV systems themselves?

15.

If you are not a manufacturer, to what extent do you
acquire PV panels systems or components from domestic
sources? Do you expect your purchasing behavior will change
as a result of federal subsidies?

Requested Information on Acquisition Practices
16.

What would be the likely impacts of the Government
requiring in its procurements that solar energy under such
contracts be generated using domestically manufactured PV
panels or components?
a.

What are the risks/downsides?

b.

What are the opportunities/upsides?

c.

If you are a developer, would such a requirement
change your willingness to participate in future
federal opportunities?

17.

Other than establishing a requirement, what steps could the
Government take to use federal acquisition to leverage
domestic PV panel or component manufacturing?

18.

If the Government were to pursue developing a procurement
standard for domestically manufactured PV panels or
components, what key elements should be contained in that
standard to encourage domestic manufacturing?

19.

What components in PV panels would be difficult to source
domestically?
a.

Do different components in PV panels need different
timeframes for being domestically sourced without
difficulty?

20.

There is an Electronic Product Environmental Assessment
Tool (EPEAT) ecolabel for PV panels and inverters. Please
share your company’s plan/timeline to get your PV panels
EPEAT registered.
a.

What percentage of the components of your EPEAT
registered solar panels do you anticipate would be
domestically sourced?

b.

How does your company ensure that your solar supply
chain does not utilize forced labor? Will your
company’s supply chain be impacted by the recently
passed Uyghur Forced Labor Prevention Act?

c.

What steps can the Government take to further protect
your supply chain from forced labor concerns?

d.

If the EPEAT criteria for PV panels and/or components
were updated to address forced labor within the supply
chain, what approach would you recommend be taken in
the new criteria?

21.

If there is anything else that you want the Government to

consider in encouraging domestic manufacturing of PV panels and
components, please address.

Jeffrey A. Koses,
Senior Procurement Executive,
Office of Acquisition Policy,
Office of Government-wide Policy,
General Services Administration.
Billing Code: 6820-61
[FR Doc. 2022-20138 Filed: 9/16/2022 8:45 am; Publication Date: 9/19/2022]