By Tom Ewing for Renewable Energy World

The U.S. Department of Energy published a “Request for Information (RFI)” last November, seeking information to help the department evaluate America’s energy sector supply chains.

The RFI was prompted by President Biden’s Executive Order 14017 “America’s Supply Chains” which directed the Secretary of Energy to submit a report “on supply chains for the energy sector industrial base.” And, as a corollary issue, to help define the energy industrial base.

Renewable energy will require the U.S. to largely remake its electric generation and transmission systems and much of the complex infrastructure and equipment within those systems. For many projects, remake does not mean rebuild, which implies more of the same, just upgraded or next-generation.

Electrical storage, for example, is not a major part of America’s electrical supply, other than pumped hydro. Going forward, however, utility-scale battery storage will be critical to compensate for intermittent solar and wind generation.

Hence DOE’s questions: Does America have the raw materials to build a safe and reliable renewable energy system? If not, what steps are needed to ensure those materials are available – sooner, not later – and accessible in increasing quantities? A related focus: moving this work, particularly manufacturing, back to the United States to capture related economic benefits, especially regarding employment.

DOE received replies to its inquiry from a wide range of energy and material experts. Most comments encouraged DOE’s supply chain initiative and the concurrent efforts at economic development. At the same time, the comments were grounded in the widely accepted reality that the next steps will be difficult.

Consider, for example, that environmental operating permits and regulatory streamlining are contentious issues within green economy debates. Businesses may be eager to take on renewable energy projects, but they don’t want to take on the lengthy and litigious US regulatory system. Getting a mining permit, for example, can take up to 20 years.

These regulatory challenges also impact and delay new energy projects.

Some communities may resist energy-related industrial expansions. Again, consider energy storage. The American Chemistry Council noted in its comments to DOE that fluoropolymers are key components of lithium-ion batteries and conversion technologies. These compounds, while different, can be linked to PFAS — per- and polyfluoroalkyl substances — the so-called “forever chemicals” threatening many public water systems. ACC wrote that “lithium-ion batteries cannot be manufactured without fluoropolymers” and inadvertent restrictions on fluoropolymers “would have a catastrophic impact on the domestic EV battery business.”

Indeed, in March 2021, a company called SungEel withdrew efforts to establish a lithium battery recycling facility in Endicott, New York; local opposition was a major factor even though New York’s renewable energy goals are among the highest in the nation. With lithium and similar metals, recycling is critical because it keeps those key materials accessible within U.S. markets.

DOE appears to be aware of such controversy. In fact, DOE referenced the SungEel initiative in its February “Deep Dive Assessment” report: “Addressing real and perceived environmental concerns with the public is critical for developing a domestic grid ESS (energy storage system) manufacturing supply chain.” DOE said it is looking to a new Interagency Working Group, convened in March by the Department of Interior, to help with facility siting.

Storage was one of 14 broad energy categories listed by DOE in its RFI. (See below for the full list.) Within each category, DOE asked detailed questions about, for example, supply chain vulnerabilities, productive next steps for the U.S. and the barriers that hamper those next steps.

The Ultra Low-Carbon Solar Alliance, a manufacturing trade group, commented on supply chain challenges.

The Alliance wrote that solar projects depend on Chinese resources and manufacturing, impacting prices and making the U.S. and foreign customers vulnerable to numerous direct and indirect issues.

The Alliance presented a number of suggestions:

• Enact a production tax credit like the credit set within the proposed Solar Energy Manufacturing for America Act (SEMA). This “would help manufacturers rapidly scale to multi-gigawatt scale,” the Alliance said.
• Support policies establishing a market-based competitive footing, such as carbon-cognizant trade policies.
• Implement “Buy Clean” legislation with “targets for embodied carbon in building materials.”

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This isn’t just about money. Chinese production, the Alliance contended, presents “significant sustainability concerns (because) the Chinese electricity grid is roughly 40% more carbon-intensive than the U.S. grid.”

Polysilicon manufacturing in China depends on subsidized coal-fired electricity, the Alliance said. It added that if projected solar demand is met primarily by Chinese supply growth that could result in a cumulative 14-18 billion tons of additional carbon emissions by 2040, a calculation attributed to the Clean Energy Buyers Alliance. The Alliance also referenced the use of alleged forced labor in the Chinese solar industry.

In a lengthy set of comments, American Clean Power wrote to support U.S. manufacturing growth. However, ACP cautioned that “harmful mandates and restrictions – including undue tariffs and duties – are ineffective tools for increasing domestic manufacturing. Such tariffs and duties are already creating artificial price increases without benefiting U.S. manufacturing.”

ACP said that the U.S. needs to catch up with other countries’ renewable investments. To do that, ACP advised that federal spending focus on leveraging private capital and creating incentives. Such incentives might include “a broad suite of federal and state investments in domestic manufacturing.” It suggested manufacturing tax incentives, research and development support, low-cost loans, and other tools.

Sandia National Labs, part of DOE’s research laboratory network, referenced work needed on a number of fronts, including ports and manufacturing yards, training for repair and installation technicians, the equipment needed for offshore installation and coordinated grid development to support large-scale offshore generation.

Wind energy company Orsted suggests three broad focus areas:

• For offshore wind, develop industrial strategies tailored to U.S. production capabilities. Two focus areas should be procuring advanced machinery and workforce training.
• Invest in new transportation infrastructure to handle the local and regional transport of monopiles, towers, and blades.
• Develop supply chains around constrained materials and components. This focus needs to go beyond just rare earth materials (for example, neodymium, critical for magnets used in wind turbines) and should expand to include monopile steel, high voltage submarine export cables, high voltage direct current components and wind turbine blades greater than 300 feet. Orsted wrote that a green energy transformation requires “significant amounts of mineral and metals,” including copper, rare earth, iron, cobalt, manganese, and nickel.

Gina Coplon-Newfield, is chief of staff for DOE’s Office of Policy, said the comments have informed DOE’s work in a number of areas. One major work product was publication in February of the “America’s Strategy to Secure the Supply Chain for a Robust Clean Energy Transition. The Strategy includes 13 “deep-dive assessments” on specific technologies and crosscutting topics, work undertaken by researchers from DOE and several of its national laboratories, in consultation with energy sector stakeholders. The Deep Dive topics align with the subject areas in the original RFI.

Coplon-Newfield said the public comments would also be used to inform implementation of the actions presented in the Strategy. “We have just started the implementation phase,” she said, “and we are looking forward to engaging many industry, governmental, community, and academic stakeholders, including those that submitted RFI comments.”

Coplon-Newfield also commented on how DOE will likely move forward to help expand domestic production, for example, of “grain oriented electric steel” (GOES), which is critical for transformers and related equipment. That type of steel in particular, was mentioned in many of the comments to the supply chain docket since most GOES currently is imported. She said the DOE, in coordination with other agencies, “plans to expand funding mechanisms such as competitive grants, direct loans, and loan guarantees that support domestic manufacturing capabilities – key areas will include supporting domestic manufacturing of GOES.”

Regarding permitting challenges, Coplon-Newfield referenced the start of the February 2022 interagency working group led by the Department of Interior (DOI) and focusing on “reforming hardrock mining laws, regulations and permitting policies in the United States.” On March 31, DOI published a Federal Register announcement about this new effort and described upcoming public participation venues, although the Working Group itself is apparently limited to government personnel.

Coplon-Newfield said the new group will identify gaps and potential reforms useful in promoting domestic production of critical materials. DOE will share its supply chain information with the new group. Coplon-Newfield added that DOE will work closely with regulatory agencies such as EPA, focusing on the need to “help revitalize domestic manufacturing without jeopardizing environmental and health standards.”

1. Crosscutting topics relating to the energy sector industrial base

2. Solar PV Technology

3. Wind Energy Technology

4. Energy Storage Technology

5. Electric Grid—Transformers and HVDC (high voltage direct current)

6. Hydropower and Pumped Storage Technology

7. Nuclear Energy Technology

8. Fuel Cells and Electrolyzers

9. Semiconductors

10. Neodymium Magnets

11. Platinum Group Metals and other materials used as Catalysts

12. Carbon Capture, Storage, and Transportation Materials

13. Cybersecurity and Digital Components

14. Commercialization and Competitiveness