Ampyx Cyber Blog

The Intersection of Regulation & Resilience

What DOE's EO 14421 FAQ Puts in Writing
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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One Incident, Several Reports: What GAO's Panel & CISA's Town Halls Say About Harmonization [Updated]
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

One Incident, Several Reports: What GAO's Panel & CISA's Town Halls Say About Harmonization [Updated]

A single cyber incident at a utility can owe reports to several federal agencies, each with its own clock and definition. The Government Accountability Office's latest panel heard that again, and electric, gas, oil, and water groups told the Cybersecurity and Infrastructure Security Agency the same thing in June. This post looks at where the overlap sits and where the reporting rule stands.

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Four Things in the EO 14421 Webinar That Aren't in the RFI
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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Question H-3: DOE Asks Whether Industry Should Execute the Bulk-Power Order
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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Nothing Is Grandfathered: The EO 14421 RFI on Existing Equipment
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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Executive Order 14421 and the Bulk-Power System Supply Chain [Updated]
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

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.

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Analysis of the June 6th, 2025 Executive Order on Cybersecurity
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Analysis of the June 6th, 2025 Executive Order on Cybersecurity

On June 6, 2025, President Donald J. Trump issued a new Executive Order (EO) titled “Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Orders 13694 and 14144.” This directive serves as a recalibration of federal cybersecurity strategy, signaling a shift away from prescriptive mandates toward more targeted, agency-specific authority and risk-informed investment in critical initiatives. It amends prior EOs while preserving core elements of federal cybersecurity policy.

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Is SBOM the answer?
Deep Dive Patrick Miller Deep Dive Patrick Miller

Is SBOM the answer?

Government and industry experts have recently pointed to software bill of materials (SBOM) as a requirement for organizations, but what are you getting? David Foose spends some time exploring aspects of SBOM fever.

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