Unsolicited Proposals, Needed: More Access, More Flexibility, More Funding to Advance Game-Changing Projects

February 26, 2024

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by CJ Evans (Alternative Fuels & Chemicals Coalition/Project Financing Assistance/Biofuels Digest) Time is of the Essence in Addressing the Climate Crisis… every technology and innovation that can help needs to be deployed as rapidly as possible. Unfortunately, five obstacles stand in the way of advancing MUCH NEEDED innovations through federal grant programs.

These five obstacles Are:

The difficulty and delays in securing the development capital that is necessary for innovations to advance … and the lack of a federal grant program to fill this need.
The sometimes too narrowly focused, exclusionary, and limited visions of the notices of funding opportunities issued by federal agencies … that preclude many projects with great promise from applying.
The refusal by some federal agency offices and divisions to consider unsolicited proposals for funding outside of the strict limits of the funding opportunity notices they have issued.
The limitations of the DOE’s Title 17 (i.e., the lack of any federal assistance in securing development capital and the length of time and cost of applying for a Title 17 loan guarantee).
The limitations placed on the submission of unsolicited proposals when the proposal resembles or appears that it would have had the capability to address a previously issued funding opportunity notice, without a limit on how far back this limitation stretches.

These obstacles are described more fully below.

Here’s Why Unsolicited Proposals Are Important

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Despite these successes, ADE has encountered obstacles that stand in the way … and too often block … other projects that have tremendous promise:

The U.S. federal government offers more funding and grant programs than any ither country. These funding programs have been extremely successful in advancing thousands of projects.

Yet too many projects with the potential to be disruptive and game-changing are left by the wayside … because they cannot find a relevant funding opportunity … or they wait and wait for a funding opportunity that will allow them to advance, but can do so by only one step at a time through a single Technology Readiness Level (TRL) … or they are too much like a square peg that does not fit into a round hole – the targeted objectives, narrow focus, and, sometimes, limited vision – of available funding opportunity notices.

Application preparation firms, such as ADE, have tried many times to restructure a project to fit, as closely as possible, within the confines of a funding opportunity notice.

These efforts are not always successful, since a project’s trajectory to be disruptive and unique may have to be diverted away from what it could be into something different, to align more closely with a funding opportunity notice.

Thus, projects that could take a great leap forward do not apply … or come up short in what they are able to do, constrained by what an award will allow … or they lose out to projects that were designed to take smaller steps in a different, sometimes more circuitous direction.

The Availability of Funding through Unsolicited Proposals Needs to be Increased

“It is the policy of the Government,” as stipulated in 48 CFR 15.6 of the Federal Acquisition Regulation (FAR) System, “to encourage the submission of new and innovative ideas in response to … Government-initiated solicitation[s] or program[s]. When the new and innovative ideas do not fall under topic areas publicized under those programs or techniques, the ideas may be submitted as unsolicited proposals.”

FAR 15.603(a) goes on to state: “Unsolicited proposals allow unique and innovative ideas or approaches that have been developed outside the Government to be made available to Government agencies for use in accomplishment of their missions. Unsolicited proposals are offered with the intent that the Government will enter into a contract with the offeror for research and development or other efforts supporting the Government mission.”

The reason that FAR 15.6 is so critical … by allowing unsolicited proposals to be submitted to federal agencies for consideration … is because it provides a strategic opportunity … a pivotal opportunity … to advance disruptive, game-changing innovations … and the missions of federal agency programs … when no other federal funding pathway is open to them … so that the benefits they offer are not lost.

While many innovations are being advanced by the private sector and federal grants and loan guarantees … many, far too many … that are needed to mitigate the climate crisis … that will provide jobs … and serve as economic drivers and boost tax revenues for local communities … especially those in economically depressed part of the country … fall by the wayside.

This is why AFCC has included proposed language in its FY2025 appropriations requests to encourage federal agencies to:

Place more emphasis on, give greater consideration to, and offer more flexibility in funding unsolicited proposals … and,
Establish a 50/50 matching grant program within the Department of Energy (DOE) Loan Programs Office to provide development capital (described separately).