Ampyx Cyber Blog
The Intersection of Resilience & Regulation
What DOE's EO 14421 FAQ Puts in Writing
The Department of Energy (DOE) published a 22-question frequently asked questions (FAQ) document on Executive Order (EO) 14421 on October 6, three days before its request for information closed. Most of it puts on paper what DOE said at the September webinar, and a few answers go further, on data centers, on reliability standards, and on when a transaction counts as initiated.
Four Things in the EO 14421 Webinar That Aren't in the RFI
The Department of Energy (DOE) held its public webinar on the Executive Order (EO) 14421 request for information (RFI) on September 16. Most of the hour restated the notice, but four things came up that aren't in the RFI text at all. The one with the shortest fuse is that a phone call to DOE about this proceeding puts a memo in the public docket, and you're the one who has to write it.
Question H-3: DOE Asks Whether Industry Should Execute the Bulk-Power Order
DOE's Request for Information on Executive Order 14421 includes one question, H-3, asking whether industry standards bodies and third-party labs can execute the order instead of the federal government. The electric sector ran something close to this before, under the Electric Reliability Organization. This post looks at what changes when the statute is IEEPA, not the Federal Power Act, and what a working precedent outside the sector suggests.
Nothing Is Grandfathered: The EO 14421 RFI on Existing Equipment
DOE has opened a 30-day request for information on how it will implement Executive Order 14421, the order restricting foreign-produced bulk-power system equipment. The most consequential questions concern equipment already installed, since the order does not grandfather it, and how DOE will define "foreign-produced" in the first place. Comments are due October 9, with a public webinar on September 16.
Executive Order 14421 and the Bulk-Power System Supply Chain [Updated]
An executive order signed August 26, 2026 declares a national emergency over foreign-produced bulk-power system electric equipment. It reaches 69 kV and above, adds software, firmware, a list of OT/ICS gear, and vendor remote access to scope, and creates authority to condition or remove equipment already installed. Here is what changed since the 2020 order, where it meets CIP-003-9 and CIP-013-2, and what to do before December 24.