NAM to DOE: Focus on High-Risk Threats to the U.S. Bulk-Power System

Before imposing broad import restrictions on certain bulk-power system equipment, the Department of Energy must provide workable and clear guidance that will preserve the reliability of the electric grid and avoid adversely affecting manufacturers in the U.S. that are working to meet increasing energy demand, the NAM told the agency recently.
What’s going on: On Aug. 26, the Trump administration issued an executive order to ban transactions of certain foreign-produced electrical equipment for the bulk-power system that could, according to the order, pose an undue risk to the United States. Following the issuance of the EO, the Department of Energy, which is the lead agency responsible for implementation, issued a request for information to gather stakeholder input on the EO and solicit feedback on what should be included in the agency’s implementation guidance, which is expected in December.
In response, the NAM submitted a formal comment letter drafted with member feedback to share how the EO and any follow-on implementation guidance could put at risk the continued expansion of domestic manufacturing and undermine energy reliability and affordability.
- “If not carefully designed, actions intended to strengthen national security and reshore industrial supply chains could have the opposite effect,” the NAM warned, urging the DOE to consider the potential consequences of new regulations for national security and U.S. competitiveness.
What should be done: The NAM called on the DOE to:
- Preserve manufacturers’ ability to advance grid reliability, energy affordability and supply chain security by avoiding strict domestic-sourcing mandates or import restrictions that could delay grid expansion, increase costs and constrain the industry’s ability to grow;
- Clarify the scope and criteria for restrictions on grid equipment, including around supply chain sourcing requirements;
- Avoid restrictions on existing equipment or requirements that would force its replacement;
- Leverage and strengthen existing DOE frameworks that could be applied or expanded to avoid duplication with any new mandates;
- Explicitly outline a transparent regulatory process that provides predictable procedures and realistic timelines for manufacturers to utilize; and
- Resolve key outstanding questions surrounding process, supply chain sourcing thresholds, definitions, procurement alignment, existing contracts and projects, and compliance transparency.
The last word: Manufacturers support “the administration’s objectives of securing the United States bulk-power system from foreign cyberthreats as well as supporting a modern and strengthened grid,” NAM Vice President of Domestic Policy Chris Phalen and NAM Senior Director of Energy and Resources Policy Mike Davin told the DOE.
- “Final implementation guidance that is precise, risk-based and administrable will achieve these goals.”


